SEC Comment Letter for EBAY INC (EBAY) (CIK 0001065088) (EBAY) — Dec 12, 2014
EBAY INC (EBAY) (CIK 0001065088)
Date: Dec. 12, 2014 · CIK: 0001065088 · Accession: 0000000000-14-064442
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-24821
Referenced dates: December 4, 2014
Letter
December 12, 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 December 9 , 2014 File No. 000-24821
Dear Mr. Donahoe :
We have reviewed your response dated December 9 , 2014 and have the following additional comment. In our comment , 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 d o not believe our comment applies 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 this comme nt, 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. We note your response to co mment 1 in our letter dated December 4, 2014. As the information you provided was not responsive to our comment, we reissue our comment. Tell us the portion of GMV represented by transactions that are closed but not consummated for each year presented. In addition, please separately explain in more detail why you believe “the total mix of information in [y]our financial statements, as well as the nature of the metric” support your conclusion that is it not meaningful or
John J. Donahoe eBay Inc. December 12, 2014 Page 2
material to disclose this informat ion to your investors, particularly since you use GMV to explain changes in your revenue.
You may contact Jarrett Torno, Staff Accountant, at (202) 551 -3703 or me at (202) 551 - 3737 if you have questions regarding our comment or any other questions.
Sincerely,
/s/ Jennifer Thompson
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December 12, 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 December 9 , 2014 File No. 000-24821 Dear Mr. Donahoe : We have reviewed your response dated December 9 , 2014 and have the following additional comment. In our comment , 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 d o not believe our comment applies 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 this comme nt, 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. We note your response to co mment 1 in our letter dated December 4, 2014. As the information you provided was not responsive to our comment, we reissue our comment. Tell us the portion of GMV represented by transactions that are closed but not consummated for each year presented. In addition, please separately explain in more detail why you believe “the total mix of information in [y]our financial statements, as well as the nature of the metric” support your conclusion that is it not meaningful or John J. Donahoe eBay Inc. December 12, 2014 Page 2 material to disclose this informat ion to your investors, particularly since you use GMV to explain changes in your revenue. You may contact Jarrett Torno, Staff Accountant, at (202) 551 -3703 or me at (202) 551 - 3737 if you have questions regarding our comment or any other questions. Sincerely, /s/ Jennifer Thompson Jennifer Thompson Accounting Branch Chief