SecProbe.io

November 18 , 2014

Via E -mail
John J. Donahoe
President and Chief Executive Officer
eBay Inc.
2065 Hamilton Avenue
San Jose, CA 95125

Re: eBay Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2013
Filed January 31, 2014
Response dated October 24, 2014
File No. 000-24821

Dear Mr. Donahoe :

We have reviewed your response dated October 24, 2014  and have the following
additional comment s.  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, 2013

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations , page 62

Overview, page 62

1. Your response to comment 2 in our letter dated September 25, 2014 states that you “do
not believe that the inclusion of closed transactions that are not ultimately consummated
reduces the meaningfulness or usefulness of [y]our GMV metric.”  Please elaborat e on
this statement as it is not obvious to us why a metric that measures consummated sales
would not be more meaningful .  As part of your response, tell us whether you earn any
significant revenue from transactions that are closed but not ultimately consu mmated.

John J. Donahoe
eBay Inc.
November 18 , 2014
Page 2

 Also tell us whether you track transactions that are closed but not consummated and, if
possible, quantify the portion of GMV represented by these transactions.

Results of Operations , page 63

Marketplaces Net Transaction Revenues, page 66

2. Your response to comment 3 in our letter dated September 25, 2014 indicates that
approximately 11% of your total Marketplaces net transaction revenue results from
listing fees which are a fixed amount per listing.  Absent a narrow range of sales prices
for listings in your Marketplaces segment, it appears that GMV would not be directly
correlated to this listing fee revenue.  Please confirm that if listing fee revenue becomes
material, you will provide additional analysis of factors driving the change in thi s type of
revenue beyond your current discussion of GMV ; otherwise,  explain to us in more detail
how GMV is directly correlated to listing fee revenue .

3. We note your quantification of take rate within your response to comment 3 in our letter
dated September 25, 2014.  In future filings, please consider quantifying the take rate for
each segment within your table of Supplemental Operating Data along wi th GMV, TPV,
and Merchandise Sales.  While we note that investors can calculate take rate from each
segment’s net transaction revenues and the metrics currently presented within your table
of Supplemental Operating Data, we believe a best practice would be  to quantify this
important operating metric for your investors to allow them to assess at a glance any
significant change in the underlying factors that drive your net transaction revenue.
Please also provide a footnote to the table explaining how take rate was calculated.

Payments Net Transaction Revenues, page 66

4. We note your response to comment 6 in our letter dated September 25, 2014.  It appears
that this segment’s take rate decreased by approximately 1% from 2012 to 2013, which
appears to represent  a loss of approximately $ 1.8 billion in revenue.  Please tell us in
more detail what caused the shift to larger merchants who pay lower rates during 2013,
including whether there were any specific changes in your policies or pricing or any
external factors of which management is aware that may have driven this shift.   Also tell
us how you considered disclosing in mo re detail the underlying factors that contributed to
this shift so that investors would be able to better assess the likelihood that past results
are indicative of future results.

Enterprise Net Transaction Reven ues, page 67

5. We note your response to comment 7 in our letter dated September 25, 2014.  Since it
appears that the decline in this segment’s take rate resulted in an 8% decline in this
segment’s net transaction revenue, we continue to believe that a best practice would be to
provide your investors with some insight from management into why this take rate

John J. Donahoe
eBay Inc.
November 18 , 2014
Page 3

 declined during 2013.  Please consider providing an explanation of any significant
increase or decrease in take rate from period to period in future filin gs.

You may contact Jarrett Torno , Staff Accountant , at (202) 551 -3703  or me at (202) 551 -
3737  if you have questions regarding our comments or any other questions.

Sincerely,

 /s/ Jennifer Thompson

Jennifer Thompson
Accounting Branch Chief