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The tomb of Ninetjer could best be described as a subterranean path or corridor tomb. It extends over an area of about 77 m by 50 m and is divided into 192 rooms, running through the rock in amaze of winding paths. The different architectural elements will be discussed and compared with contemporary tombs at Saqqara. The substructure could be interpreted as magazines, amodel-palace, three model cult places and a model-residence. Over the course of time, from Old Kingdom even up to Late Antiquity, many intrusions have hit the Second Dynasty galleries. In addition, and in the light of the development direction of a burial place and of its cultic traditions, the reuse of this tomb is also discussed.