SEC Comment Letter for EBAY INC (EBAY) (CIK 0001065088) (EBAY) — Nov 27, 2018
EBAY INC (EBAY) (CIK 0001065088)
Date: Nov. 27, 2018 · CIK: 0001065088 · Accession: 0000000000-18-036323
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Reasoning
File numbers found in text: 001-37713
Letter
Mail Stop 3561 November 27 , 2018 Devin N. Wenig President and Chief Executive Officer eBay Inc. 2025 Hamilton Avenue San Jose, CA 95125
Re: eBay Inc. Form 10 -Q for the fiscal quarter ended June 30, 2018 Filed July 19, 2018 File No. 001-37713
Dear Mr Wenig :
We have reviewed your October 9, 2018 response to our comment letter 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 24, 2018 letter.
Form 10 -Q for the quarter ended June 30, 2018
Notes to Condensed Consolidated Financial Statements
Note 1 – The Company and Summary of Significant Accounting Policies
Revenue Recognition, page 7
1. We note your response to comment 3 regarding revenue generated from your Marketplace platform. Please quantify for us the amount of revenue you recognized from basic and advanced listing services for each of the three years ended December 31, 2017 and the nine months ended September 30, 2018, and t ell us whether such amounts are considered significant to your financial statements, individually or in the aggregate, for
Devin N. Wenig eBay Inc. November 27 , 2018 Page 2
each period presented. In addition, please revise your disclosure in future filings to clarify that revenue from your basic and adva nced listing services is not material, if appropriate.
2. We note your response to comment 4. Please revise your disclosure in future filings to clarify that your most significant revenue share arrangements are with shipping service providers and that you h ave determined you are acting as an agent in these arrangements. Also clarify when the performance obligations are satisfied and revenue is recognized. Refer to ASC 606 -10-50-12.
You may contact Lisa Sellars, Staff Accountant, at (202) 551 -3348 or Andrew Blume, Staff Accountant, at (202) 551 -3254 or me at (202) 551 -3737 with any questions.
Sincerely,
/s/ Jennifer Thompson
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Mail Stop 3561 November 27 , 2018 Devin N. Wenig President and Chief Executive Officer eBay Inc. 2025 Hamilton Avenue San Jose, CA 95125 Re: eBay Inc. Form 10 -Q for the fiscal quarter ended June 30, 2018 Filed July 19, 2018 File No. 001-37713 Dear Mr Wenig : We have reviewed your October 9, 2018 response to our comment letter 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 24, 2018 letter. Form 10 -Q for the quarter ended June 30, 2018 Notes to Condensed Consolidated Financial Statements Note 1 – The Company and Summary of Significant Accounting Policies Revenue Recognition, page 7 1. We note your response to comment 3 regarding revenue generated from your Marketplace platform. Please quantify for us the amount of revenue you recognized from basic and advanced listing services for each of the three years ended December 31, 2017 and the nine months ended September 30, 2018, and t ell us whether such amounts are considered significant to your financial statements, individually or in the aggregate, for Devin N. Wenig eBay Inc. November 27 , 2018 Page 2 each period presented. In addition, please revise your disclosure in future filings to clarify that revenue from your basic and adva nced listing services is not material, if appropriate. 2. We note your response to comment 4. Please revise your disclosure in future filings to clarify that your most significant revenue share arrangements are with shipping service providers and that you h ave determined you are acting as an agent in these arrangements. Also clarify when the performance obligations are satisfied and revenue is recognized. Refer to ASC 606 -10-50-12. You may contact Lisa Sellars, Staff Accountant, at (202) 551 -3348 or Andrew Blume, Staff Accountant, at (202) 551 -3254 or me at (202) 551 -3737 with any questions. Sincerely, /s/ Jennifer Thompson Jennifer Thompson Accounting Branch Chief Office of Consumer Products