United States securities and exchange commission logo





                             December 13, 2022

       Rong Luo
       Chief Financial Officer
       Baidu, Inc.
       Baidu Campus
       No. 10 Shangdi 10th Street
       Haidian District, Beijing 100085
       The People   s Republic of China

                                                        Re: Baidu, Inc.
                                                            Form 20-F for the
Year Ended December 31, 2021
                                                            Filed March 28,
2022
                                                            Response Letter
filed October 31, 2022
                                                            File No. 000-51469

       Dear Rong Luo:

              We have reviewed your October 31, 2022 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       September 26, 2022 letter.

       Form 20-F for the Year Ended December 31, 2021

       Item 3. Key Information
       Cash Flows through our Organization , page 7

   1.                                                   In connection with your
response to comment 1, to enhance transparency, please revise
                                                        the Selected Condensed
Consolidating Cash Flows Information on page 11 to include
                                                        captions and
annotations for capital contributions, loans and principal repayments to/ from
                                                        the VIEs.
 Rong Luo
Baidu, Inc.
December 13, 2022
Page 2
Financial Information Related to the Consolidated Affiliated Entities, page 9

2.     We note your response to prior comment 3 and your proposed presentation
of Selected
       Condensed Consolidating Balance Sheets and Statements of Comprehensive
Income.
       With respect to the Condensed Consolidating Balance Sheets, please
explain why the
       Contractual interests in the VIEs and VIEs' subsidiaries are reported
under "Other
       Subsidiaries" instead of the "Primary Beneficiaries of VIEs."

3.     With respect to the Consolidating Statements of Comprehensive Income,
explain:
           why certain of the revenues of the VIEs and VIE subsidiaries are not
included in the
           revenues of the primary beneficiaries of the VIEs and appear to be
included under
           Other Subsidiaries; and
           why there is a difference between the net income (loss) reported by
the VIEs and VIE
           subsidiaries and the net income (loss) reported by the primary
beneficiaries.

        You may contact Kathryn Jacobson, Senior Staff Accountant at (202)
551-3365 or Robert
Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters.



                                                            Sincerely,
FirstName LastNameRong Luo
                                                            Division of
Corporation Finance
Comapany NameBaidu, Inc.
                                                            Office of
Technology
December 13, 2022 Page 2
cc:       Shu Du (Skadden)
FirstName LastName