SecProbe.io

July 26, 2011
 Via-Email

Mr. John Donahoe  President and Chief Executive Officer eBay Inc. 2145 Hamilton Avenue San Jose, California  95125
Re: eBay Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2010
Filed January 28, 2011 File No. 000-24821

Dear Mr. Donahoe:
 We have reviewed the above referenced filing and your letter da ted June 27, 2011 in
response to our comment letter dated June 13, 2011 and have the following comments.  In our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the Fiscal Year Ended December 31, 2010

 Item1. Business, page, 1

 Overview, page 1

1. We note your response to comment two in  our letter dated June 13, 2011 and your
disclosure in Note 6 to your consolidated financial statements .  Please provide total assets
for each segment or tell us where this disclosure  is located in your f iling.  Please see Item
101(b) of Regulation S-K.

Mr. John Donahoe  eBay Inc.  July 26, 2011 Page 2

 Definitive Proxy Statement on Schedule 14A

 Nominees for Election for a Three-Year Term  Expiring at Our 2014 Annual Meeting, page 17

2. We note your response to comment 12 in our letter dated June 13, 2011 and your
proposed disclosure in Exhibit A of your re sponse letter dated J une 27, 2011.  Please also
provide us your proposed revisions for Mess rs. Cook, Ford and Tierney or tell us why
you believe this is unnecessary.  Please s ee Item 401(e)(1) of Regulation S-K.
 Compensation Discussion and Analysis, page 31

 Elements of Compensation/Executive  Compensation Practices, page 38

 Equity Incentive Awards, page 42

3. We note your response to comment 13 in our le tter dated June 13, 2011 that “[i]n future
filings…[you] will include the eIP component related to individual performance in a
separate row under the Grant of Plan Based Awa rds Table. In the new row for eIP grants
for individual performance, [you] will identi fy a target and a maximum.”  We further
note your response stating “[i]n future filings , [you] will revise th e disclosure in the
Summary Compensation Table to move the portio n of the eIP payout related to individual
performance from the Bonus column to the N on-Equity Incentive Plan column.”  Before
making these future revisions and with a vi ew to understanding how  this element of
compensation should be disclosed  the Summar y Compensation Table, please explain:

 the process associated with establishi ng the “target” and “maximum” amounts;
 the performance criteria used in de termining whether the “target” and
“maximum” amount is achieved and, if different, the goals that you communicate
to your named executive officers at the beginning of the year; and
 the level of discretion exercised when  assessing the ultimate funding of the
individual performance component.

Please see Question 119.02 in the Compliance an d Disclosure Interpre tations relating to
Regulation S-K, locat ed at our website.

Please contact Angie Kim, Staff Attorney, at (202) 551- 3535 or me, at (202) 551-3264,
with any questions.
Sincerely,
   /s/ Mara L. Ransom
Mara Ransom Legal Branch Chief