SecProbe.io

April 11, 2012
 Via E-mail

Robert Swan Senior Vice President and Chief Financial Officer eBay Inc. 2145 Hamilton Avenue San Jose, CA 95125
Re: eBay Inc.
Form 10-K for the Fiscal Year Ended December 31, 2011 Filed January 31, 2012
  File No. 000-24821

Dear Mr. Swan:
 We have reviewed your filing and have the following comments.  We have limited our
review to only your financial statements and re lated disclosures and do not intend to expand our
review to other portions of your documents.  In  some of 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, 2011

 Item 7: Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page 53
 Results of Operations, page 54

 Marketplaces Net Transaction Revenues, page 57

1. We note in your disclosure e xplaining that the increase in Marketplaces net transaction
revenues from 2009 to 2010 was partially offset by the impact of pricing initiatives.  Please tell us more about these pricing init iatives and what consideration you gave to
including this detail in your disclosure.  Additionally, pl ease tell us if these pricing
initiatives are a trend that you continue to implement.

Robert Swan eBay Inc. April 11, 2012 Page 2

Payments Net Transaction Revenues, page 57

2. We note the increase in the number of onlin e merchants offering PayPal as a payment
option was a primary driver to the increase in  your Merchant Services net TPV (Total
Payment Volume).  Please tell us the number of online merchants offering PayPal as a
payment option for each of the reporting peri ods presented.  Please also tell us what
consideration you gave to providing this detail  within the filing to provide a frame of
reference that allows readers to understand the effects of mate rial changes and events and
known material trends and uncertainties aris ing during the periods being discussed.
 Liquidity and Capital Resources, page 62

 Off-Balance Sheet Arrangements, page 66

3. We note your disclosure that “C ustomer balances held as direct claims against PayPal or
as an agent or custodian on be half of our customers are not reflected in our consolidated
balance sheet.”  This statement appears to co ntradict with the disclosure on page F-11
that “Customer balances held as direct claims against PayPal are  included on our
consolidated balance sheet. . .”  Please clarif y this apparent contradiction or revise future
filings, as appropriate.
 Notes to Consolidated Financial Statements, page F-8

 Note 1 – The Company and Summary of Si gnificant Accounting Policies, page F-8

 Customer Accounts, page F-11

4. We note your disclosure that based on di fferences in regulatory requirements and
commercial law in the jurisdictions where Pa yPal operates, the customer balances you
hold are either reflected on the consolidat ed balance sheet as funds receivable and
customer accounts with an offsetting liabili ty in funds payable and amounts due to
customers, when these funds are considered to be direct claims against Paypal; or, the
customer balances are not reflected in the consolidated balance sheet, when these funds
are considered to be held as an agent or custodian on behalf of your customer.  Please
revise to clarify the differe nt regulatory requirements or  commercial law that would
require the different classi fication and please provide us  the authoritative accounting
guidance you relied upon for your  current policy.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Robert Swan eBay Inc. April 11, 2012 Page 3

 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Jason Niethamer, Assist ant Chief Accountant, at (202) 551-3855 or
Donna Di Silvio, Staff Accountant, at (202)  551-3202 if you have que stions regarding our
comments.  Please contact me at (202) 551-3377 with any other questions.
Sincerely,
    /s/ Andrew Mew
 Andrew Mew Accounting Branch Chief

Via E-mail

cc:  Phillip DePaul