QUNR [Qunar Cayman Islands] DRSLTR: (Original Filing)

[September 16, 2013 The Company currently contemplates to publicly file the Registration Statement on September 27, 2013 and complete the offering, subject to market conditions, in late October or early November of 2013. As such, we would be greatly grateful if the Staff could respond promptly with additional comments, if any, on the Registration Statement prior to the contemplated public]

QUNR [Qunar Cayman Islands] DRSLTR: September 16, 2013 The Company currently contemplates to

[September 16, 2013 The Company currently contemplates to publicly file the Registration Statement on September 27, 2013 and complete the offering, subject to market conditions, in late October or early November of 2013. As such, we would be greatly grateful if the Staff could respond promptly with additional comments, if any, on the Registration Statement prior to the contemplated public]

QUNR [Qunar Cayman Islands] DRS/A: (Original Filing)

[CALCULATION OF REGISTRATION FEE Title of Each Class of Securities to be Registered (1) (2) Proposed Maximum Amount Of Class B Ordinary shares, par value US$0.001 per share (3) US$ US$ (1) (2) (3) American depositary shares issuable upon deposit of the Class B ordinary shares registered hereby have been registered under a separate registration statement on Form F-6 filed] [Place of Incorporation Subsidiaries Queen’s Road Investment Management Limited Hong Kong Beijing Qunar Software Technology Company Limited People’s Republic of China Shanghai Qianlima Network Technology Co. Ltd. People’s Republic of China Variable Interest Entity Beijing Qu Na Information Technology Company Limited People’s Republic of China Subsidiaries of Variable Interest Entity Beijing Jia Xin Hao Yuan Information Technology Company Ltd. People’s] [Qunar Cayman Islands Limited 17th Floor, Viva Plaza, Building 18, Yard 29, Suzhou Street, Haidian District Beijing 100080 The People’s Republic of China Dear Sirs/Madams: Re: Qunar Cayman Islands Limited PRC Company Registration Statement Offering ADSs Ordinary Shares Offered Securities We are qualified lawyers of the People’s Republic of China (the “ Opinion With respect to the Offering, you have]

QUNR [Qunar Cayman Islands] DRS/A: CALCULATION OF REGISTRATION FEE Title of Each Class

[CALCULATION OF REGISTRATION FEE Title of Each Class of Securities to be Registered (1) (2) Proposed Maximum Amount Of Class B Ordinary shares, par value US$0.001 per share (3) US$ US$ (1) (2) (3) American depositary shares issuable upon deposit of the Class B ordinary shares registered hereby have been registered under a separate registration statement on Form F-6 filed] [Place of Incorporation Subsidiaries Queen’s Road Investment Management Limited Hong Kong Beijing Qunar Software Technology Company Limited People’s Republic of China Shanghai Qianlima Network Technology Co. Ltd. People’s Republic of China Variable Interest Entity Beijing Qu Na Information Technology Company Limited People’s Republic of China Subsidiaries of Variable Interest Entity Beijing Jia Xin Hao Yuan Information Technology Company Ltd. People’s] [Qunar Cayman Islands Limited 17th Floor, Viva Plaza, Building 18, Yard 29, Suzhou Street, Haidian District Beijing 100080 The People’s Republic of China Dear Sirs/Madams: Re: Qunar Cayman Islands Limited PRC Company Registration Statement Offering ADSs Ordinary Shares Offered Securities We are qualified lawyers of the People’s Republic of China (the “ Opinion With respect to the Offering, you have]

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