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CORRESP
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CORRESP

 eBay Inc.

2065 Hamilton Avenue

San Jose, CA 95125

 October 24, 2014

Via EDGAR

 Division of Corporation Finance

Securities and Exchange Commission

 100 F Street, N.E.

Washington D.C. 20549

Attention:
Ms. Jennifer Thompson

 Mr. Jarrett Torno

Re:

eBay Inc.

 Form 10-K for the Fiscal Year Ended December 31, 2013

Filed January 31, 2014

File No. 000-24821

 Ladies and
Gentlemen:

 Thank you for your letter dated September 25, 2014 addressed to eBay Inc. (the “Company”) setting forth
comments of the staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Commission”) on the Company’s Annual Report on Form 10-K for the fiscal year ended
December 31, 2013 (the “Form 10-K”).

 To facilitate the Staff’s review, we have keyed our responses to the headings
and numbered comments used in the Staff’s comment letter, which are reproduced in italics below. Our responses follow each comment.

 Form 10-K for
the Fiscal Year Ended December 31, 2013

 Item 1. Business, page 4

Payments, page 6

1.
 We note your disclosure on page 7 regarding your partnership with Discover in the U.S., similar relationships with merchant acquirers and
electronic point of sale providers in the U.S. and Europe, and PayPal Here in certain countries. Please tell us what consideration was given to disclosing any metrics and revenue amounts associated with these offerings to allow your readers to
understand the significance of these relationships to your results, or if

the impact is not material, making a statement to that effect. In your response, please quantify for us the financial impact of these platforms.

Company response:

 The arrangement with Discover and
similar relationships with merchant acquirers and electronic point of sale providers in the U.S. and Europe and from transactions processed through PayPal Here devices were undertaken to expand our offline strategy of our Payments segment. During
2013, the revenue from the Discover relationship in the U.S., similar relationships with merchant acquirers and electronic point of sale providers in the U.S. and Europe and transactions processed through PayPal Here devices in the aggregate
represented less than 1% of our total Payments net transaction revenues. We have not disclosed this information separately as it is not material. We intend to continue to pursue additional opportunities to expand our offline strategy, which is why
we discuss these initiatives in our business overview. The revenue generated through these platforms is similar in nature to our other Payments net transaction revenues as the revenue generated is calculated as a percentage of the related TPV. As
such, we do not disaggregate this information in our disclosures. To the extent that the revenue from transactions processed through these relationships becomes material, we will disclose this information where applicable.

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

Overview, page 62

2.
We read that GMV is the total value of all successfully closed items between users on your Marketplaces trading platforms (excluding eBay’s classifieds websites, brands4friends and Shopping.com) during the
applicable period, regardless of whether the buyer and seller actually consummated the transaction. Please tell us and revise your disclosure to clearly explain why GMV does not consider whether the transaction was consummated.

 Company response:

 GMV is a volume
metric representing items processed through our Marketplaces platforms. The purpose of the metric is to provide information on the volume of closed transactions for a period that flow through our Marketplaces segment and a useful measure of overall
transaction volume. We use GMV as it has a high correlation to our Marketplaces net transaction revenues. We do not believe that the inclusion of closed transactions that are not ultimately consummated reduces the meaningfulness or usefulness of our
GMV metric. In future filings beginning with our Annual Report on Form 10-K for the fiscal year ending December 31, 2014, we will include a statement similar to the following, with such changes as may be necessary to reflect changed
circumstances: “We believe that GMV provides a useful measure of the overall volume of closed transactions that flow through our Marketplaces trading platforms in a given period, notwithstanding the inclusion in GMV of closed transactions that
are not ultimately consummated.”

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 Results of Operations, page 63

Marketplaces Net Transaction Revenues, page 66

3.
You state that the percentage increase in Marketplaces net transaction revenues was consistent with the increase in GMV excluding vehicles. Your statement implies that you expect a direct relationship between the
change in Marketplaces net transaction revenues and the change in GMV excluding vehicles; however, it is unclear to us why you expect a direct relationship. Please tell us and disclose in reasonable detail why you expect a direct relationship
between these two items. Your response should quantify the percentage of Marketplaces net transaction revenues consisting of fees based on a percentage of GMV excluding vehicles. In this regard, we note your statement on page 5 that the majority of
your Marketplaces revenue comes from a take rate on GMV; however, if a significant portion of your Marketplaces net transaction revenue is not generated as a percentage of GMV, it appears that additional disclosures would be necessary to explain the
factors that contributed to fluctuations or stability in that portion of your revenue. Also explain whether and why your take rate is a consistent percentage of GMV from year to year. Your response also should explain why the change in revenue is
not expected to be influenced by vehicle sales.

 Company response:

As noted in our consolidated financial statements in the Form 10-K, for the years 2012 and 2013 GMV (excluding vehicles) grew 12% and 13%, respectively, in
each case compared to the prior year. For the years 2012 and 2013 our Marketplaces net transaction revenues (excluding vehicles) increased approximately 13% for each period.

As stated in Note 1 to our consolidated financial statements in the Form 10-K, our Marketplaces segment generates net transaction revenues primarily from
listing fees and final value fees. The revenue from both of these fees is driven by volume. Listing fees consist of insertion fees and feature fees and are stated as a fixed amount per listing while final value fees are calculated as a percentage of
the final selling price of an item closed on our Marketplaces platforms. For the year ended December 31, 2013, final value fees were approximately 89% of total Marketplaces net transaction revenues, indicating a high degree of correlation
between GMV (our volume metric) and net transaction revenues.

 Take rate (excluding vehicles) is calculated as total net transaction revenue divided by
GMV (excluding vehicles). Our take rate is relatively consistent year to year, with our take rate (excluding vehicles) at 8.59%, 8.62% and 8.59% for 2011, 2012 and 2013, respectively. Absent material changes in pricing due to competitive or other
market factors, we would expect take rate to be consistent from period to period.

 Revenue generated as a percentage of GMV is not expected to be
influenced by vehicles as we earn revenue on vehicles listings differently than other categories. Revenue from vehicles is derived primarily from a subscription fee model, where a flat fee is charged. In light of this, during the first quarter of
2014 we reclassified revenues from our vehicles category from net transaction revenues to marketing services and other revenue, as this revenue stream now more closely aligns with our classifieds formats. This change has been applied retrospectively
so, going forward, vehicles GMV

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will have no impact on Marketplaces net transaction revenue and the prior periods presented will be presented on a comparable basis.

4.
You state on page 66 that your increase in net transaction revenues was due in part to growth in mobile. On pages 5 and 7, you describe the payment volume processed through mobile devices during 2013 for your
Marketplaces and Payments segments, respectively. Additionally, on your January 22, 2014 earnings call, you discuss the combined 88% growth in your mobile-enabled commerce volume for eBay and PayPal. Furthermore, you disclose on page 7 that
your acquisition of Braintree was completed to help strengthen your position in mobile payments and extend your coverage to a new class of retailers. As these statements may imply that growth in mobile is a significant component of your business
strategy, and you disclose on page 66 in MD&A that it was one of the reasons for the growth in your Marketplaces segment’s net transaction revenues, please tell us and disclose the revenue generated from your mobile platforms for the
periods presented for applicable reportable segments.

 Company response:

Growth in mobile volume is a significant component of our business strategy. As the lines between online and offline commerce blur, mobile has become an
increasingly important source of volume on our Marketplaces platforms and Payments networks. In both of our segments, transactions may be executed online or on mobile devices. Regardless of the technology used, transaction fees charged and revenue
generated are identical; therefore, we do not separately report revenues generated from transactions executed utilizing a mobile device. We report transaction volume executed utilizing a mobile device because we believe this demonstrates the
increasing importance of our mobile device offerings.

 In future filings we will make clear that the reference to mobile growth refers to mobile volume
rather than growth in Marketplaces or Payments net transaction revenues.

 Payments Net Transaction Revenues, page 66

5.
You state that Payments net transaction revenues increased primarily due to net TPV growth. Your statement implies that you expect a direct relationship between the change in Payments net transaction revenues and the
change in net TPV; however, it is unclear to us why you expect a direct relationship. Please tell us and disclose in reasonable detail why you expect a direct relationship between these two items. Your response should quantify the percentage of
Payments net transaction revenues consisting of fees based on a percentage of net TPV. In this regard, we note your statement on page 6 that the majority of your Payments revenue comes from a take rate on net TPV; however, if a significant portion
of your Payments net transaction revenue is not generated as a percentage of net TPV, it appears that additional disclosures would be necessary to explain the factors that contributed to fluctuations or stability in that portion of your revenue.

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 Company response:

As noted in our consolidated financial statements in the Form 10-K, for the years 2012 and 2013 net TPV grew at 22% and 24%, respectively, in each case
compared to the prior year. For the years 2012 and 2013 our Payments net transaction revenues grew at 25% and 18%, respectively. In MD&A in the Form 10-K, we disclosed that the wider gap between net TPV growth and Payments net transaction
revenue growth is caused primarily by a shift to larger merchants comprising a greater percentage of our net TPV.

 As stated in Note 1 to our consolidated
financial statements in the Form 10-K, our Payments segment earns net transaction revenues primarily from processing transactions for customers. The Payments net transaction revenue from these fees is driven by volume. For the year ended
December 31, 2013, greater than 95% of our Payments net transaction revenues were generated from fees (or “take rate”) applied to the net TPV that we enable, indicating a high degree of correlation between net TPV (our volume metric)
and net transaction revenues.

6.
You state that the increase in net TPV was offset by a lower take rate and the impact of foreign currency movements and hedging. Please tell us and disclose the relative impact of each of these two factors that
reduced your Payments net transaction revenue. We believe it is important to disclose the relative significance of each factor you have listed so that your investors can better assess the likelihood that past results are indicative of future
results. Also tell us whether, at the time you prepared this Form 10-K, you reasonably expected the take rate to remain the same in 2014 or whether you expected the shift to larger merchants who pay lower rates to continue, resulting in a lower take
rate in 2014, and how you determined you did not need to disclose your expectations as to whether this was a trend that would continue.

Company response:

 The lower take rate is derived
primarily from a higher portion of net TPV with larger merchants who typically pay lower rates. As the portion of our net TPV with larger merchants has recently increased, our Payments net transaction revenue has also increased. At the time we
prepared the Form 10-K, we could not reasonably predict whether the increase in net TPV generated from larger merchants would continue in the future. Additionally, lower take rates are generally provided to large merchants in return for higher
payments volume. As a result, these lower take rates are partially offset by the positive impact of higher volumes. For this reason, at the time we prepared the Form 10-K, we did not believe that a shift to larger merchants would have a material
impact on our Payments net transaction revenues.

 We have disclosed in our Summary of Net Revenues on Page 64 of our Form 10-K, the impact of foreign
currency on the net revenues of our Payments segment. Foreign currency movements relative to the U.S. dollar for the year ended December 31, 2013 negatively impacted Payments net revenues by approximately $11 million compared to the prior year
(inclusive of the impact of hedging activities).

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 Enterprise Net Transaction Revenues, page 67

7.
You state that Enterprise net transaction revenues increased primarily due to the increase in Merchandise Sales, partially offset by a lower take rate. Given the net increase in Enterprise net transaction revenues of
6%, the lower take rate appears to have significantly influenced the revenue from this segment. Please tell us and disclose why this segment experienced a lower take rate in 2013. Also tell us whether, at the time you prepared this Form 10-K, you
reasonably expected the take rate to remain the same in 2014 or whether you expected the take rate to continue to decline in 2014, and how you determined you did not need to disclose your expectations as to whether this was a trend that would
continue.

 Company response:

 There
are multiple factors that influence our Enterprise take rate. These factors include volume, customer mix and channel mix and the relative impact of these factors can vary on an ongoing basis. Moreover, as in the case of our Payments segment, lower
take rates are typically granted to customers in return for higher volumes, and these higher volumes partially offset the lower take rates. Accordingly, at the time that we prepared the Form 10-K we were not able to predict how these factors would
impact overall take rates in 2014 and, in any event, we did not believe that any decline in take rates would have a material impact on our Enterprise net transaction revenues.

Liquidity and Capital Resources, page 72

 Commitments
and Contingencies, page 74

8.
Reference is made to your table of fixed contractual obligations and commitments as of December 31, 2012 on page 71 within your Form 10-K for the fiscal year ended December 31, 2012. We note the amounts
included in the “Purchase Obligations” column of the table for the years ending December 31