SecProbe.io

September 19, 2024
Jamie Iannone
President and Chief Executive Officer
eBay Inc.
2025 Hamilton Avenue
San Jose, CA 95125
Re:eBay Inc.
Definitive Proxy Statement on Schedule 14A
Filed April 25, 2024
File No. 001-37713
Dear Jamie Iannone:
            We have limited our review of your most recent definitive proxy statement to those issues
we have addressed in our comment(s).
            Please respond to this letter by providing the requested information and/or confirming that
you will revise your future proxy disclosures in accordance with the topics discussed below. If
you do not believe a comment applies to your facts and circumstances, please tell us why in your
response.
            After reviewing your response to this letter, we may have additional comments.
Definitive Proxy Statement on Schedule 14A
Pay Versus Performance, page 67
1.We note that you have included “FX-Neutral Revenue,” a non-GAAP measure, as your
Company-Selected Measure pursuant to Item 402(v)(2)(vi) of Regulation S-K. While
Company-Selected Measure disclosure is not subject to Regulation G or Item 10(e) of
Regulation S-K, you must disclose how the measure is calculated from your audited
financial statements. Please tell us and revise future disclosure to explain how your
Company-Selected Measure is calculated from your audited financial statements. If this
information appears in a different part of the definitive proxy statement, you may satisfy
the disclosure requirement by a cross-reference thereto; however, incorporation by
reference to a separate filing will not satisfy this disclosure requirement.
Refer to the graphs on pages 69-70 showing the relationships between compensation
actually paid and net income, total shareholder return and your Company-Selected
Measure pursuant to Item 402(v)(5) of Regulation S-K. We note that you had two PEOs 2.

September 19, 2024
Page 2
in fiscal year 2020; however, it does not appear that your relationship graphs include
compensation actually paid information for both PEOs, either separately or on an
aggregate basis. Please revise future filings to include relationship disclosure for each
person who served as your PEO during the period covered by your pay versus
performance table. For guidance, refer to Regulation S-K Compliance and Disclosure
Interpretation 128D.13.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Charlotte Young at 202-551-3280 or Amanda Ravitz at 202-551-3412 with
any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program