SEC Comment Letter for EBAY INC (EBAY) (CIK 0001065088) (EBAY) — Jun 7, 2013
EBAY INC (EBAY) (CIK 0001065088)
Date: June 7, 2013 · CIK: 0001065088 · Accession: 0000000000-13-031266
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-24821
Referenced dates: May 9, 2013
Letter
June 7 , 2013 Via E -Mail John J. Donahoe President and Chief Executive Officer eBay Inc. 2065 Hamilton Avenue San Jose, California 95125
Re: eBay Inc. Form 10-K for the Fiscal Year Ended December 31, 2012 Filed February 1, 2013 File No. 000-24821
Dear Mr. Donahoe :
We have reviewed your response submitted on May 23 , 2013 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 this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2012
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Off-Balance Sheet Arrangements, page 72
1. We note your response to commen t 2 in our letter dated May 9, 2013. Please expand your accounting policy disclosure within your footnotes on page F -11 to disclose the requirement to hold liquid assets equal to at least 100% of customer balances, that customer deposits held as direct cl aims against you represent cash or cash equivalents , and that you have elected to restrict these funds and classify them separately on your consolidated balance sheets.
John J. Donahoe eBay Inc. June 7 , 2013 Page 2
Item 8. Financial Statements and Supplementary Data
Consolidated Statements of Cash Flows, page F -6
2. We note your response to comment 3 in our letter dated May 9 , 2013. It is our understanding that the line items “Funds receivable and customer accounts” and “Funds payable and amounts due to customers” within the financing activities sec tion of your consolidated statement of cash flows represents the net change in the related balance sheet line items. If our understanding is incorrect, please advise. Otherwise, please clearly indicate that these amounts are presented net.
You may contact Jarrett Torno, Staff Accountant , at (202) 551 -3703 or Donna Di Silvio, Staff Accountant, at (202) 551 -3202 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3720 with a ny other questions.
Sincerely,
/s/ Andrew D. Mew
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June 7 , 2013 Via E -Mail John J. Donahoe President and Chief Executive Officer eBay Inc. 2065 Hamilton Avenue San Jose, California 95125 Re: eBay Inc. Form 10-K for the Fiscal Year Ended December 31, 2012 Filed February 1, 2013 File No. 000-24821 Dear Mr. Donahoe : We have reviewed your response submitted on May 23 , 2013 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 this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 2012 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Off-Balance Sheet Arrangements, page 72 1. We note your response to commen t 2 in our letter dated May 9, 2013. Please expand your accounting policy disclosure within your footnotes on page F -11 to disclose the requirement to hold liquid assets equal to at least 100% of customer balances, that customer deposits held as direct cl aims against you represent cash or cash equivalents , and that you have elected to restrict these funds and classify them separately on your consolidated balance sheets. John J. Donahoe eBay Inc. June 7 , 2013 Page 2 Item 8. Financial Statements and Supplementary Data Consolidated Statements of Cash Flows, page F -6 2. We note your response to comment 3 in our letter dated May 9 , 2013. It is our understanding that the line items “Funds receivable and customer accounts” and “Funds payable and amounts due to customers” within the financing activities sec tion of your consolidated statement of cash flows represents the net change in the related balance sheet line items. If our understanding is incorrect, please advise. Otherwise, please clearly indicate that these amounts are presented net. You may contact Jarrett Torno, Staff Accountant , at (202) 551 -3703 or Donna Di Silvio, Staff Accountant, at (202) 551 -3202 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3720 with a ny other questions. Sincerely, /s/ Andrew D. Mew Andrew D. Mew Accounting Branch Chief