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CORRESP Filing

EBAY INC
Date: May 9, 2025 · CIK: 0001065088 · Accession: 0001552781-25-000173

Regulatory Compliance Financial Reporting Internal Controls

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File numbers found in text: 001-37713

Referenced dates: May 8, 2025

Date
May 9, 2025
Author
/s/ Samantha Wellington
Form
CORRESP
Company
EBAY INC

Letter

VIA EDGAR Division of Corporation Finance Office of Trade & Services Re: eBay Inc. Form 10-K for Fiscal Year Ended December 31, 2024 Form 10-Q for Fiscal Quarter Ended March 31, 2025 File No. 001-37713

Dear Mr. Kim and Mr. Friedman:

This letter responds to the letter dated May 8, 2025 from the staff (the "Staff") of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the "Commission") relating to the above-referenced Annual Report on Form 10-K for the fiscal year ended December 31, 2024, and Quarterly Report on Form 10-Q for the fiscal quarter ended March 31, 2025 (the "2025 Q1 10-Q"), of eBay Inc. ("we"), filed with the Commission on February 27, 2025 and May 1, 2025, respectively. To facilitate your review, we have reproduced the text of the Staff's comments in italicized print below.

Form 10-Q for Fiscal Quarter Ended March 31, 2025

Item 6: Exhibits

Exhibit 31.02, page 55

1. We note your Section 302 certification is not signed by your principal financial officer. Please file an amended Form 10-Q along with updated certifications that are signed and currently dated.

Response:

We note this administrative error in the filed version of the Section 302 certification. We confirm that today we have filed an amended version of the 2025 Q1 10-Q with updated certifications that are signed and currently dated.

* * *

We greatly appreciate your attention to this matter. If you have any further comments or questions regarding this letter, please contact the undersigned at (408) 595-0441.

Sincerely,
/s/ Samantha Wellington

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CORRESP
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 eBay Inc.

 2025 Hamilton Avenue

 San Jose, CA 95125

 May 9, 2025

 VIA EDGAR

 Mr. Stephen Kim

 Mr. Abe Friedman

 Division of Corporation Finance

 Office of Trade & Services

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

 Re:
 eBay Inc.

 Form 10-K for Fiscal Year Ended December 31, 2024

 Form 10-Q for Fiscal Quarter Ended March 31, 2025

 File No. 001-37713

 Dear Mr. Kim and Mr. Friedman:

 This letter responds to the letter dated May 8, 2025 from the staff (the
"Staff") of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the "Commission")
relating to the above-referenced Annual Report on Form 10-K for the fiscal year ended December 31, 2024, and Quarterly Report on Form
10-Q for the fiscal quarter ended March 31, 2025 (the "2025 Q1 10-Q"), of eBay Inc. ("we"), filed with the Commission
on February 27, 2025 and May 1, 2025, respectively. To facilitate your review, we have reproduced the text of the Staff's comments
in italicized print below.

 Form 10-Q for Fiscal Quarter Ended March 31, 2025

 Item 6: Exhibits

 Exhibit 31.02, page 55

 1. We note your Section 302 certification is not signed by your principal financial
officer. Please file an amended Form 10-Q along with updated certifications that are signed and currently dated.

 Response:

 We note this administrative error in the filed version of the Section 302 certification.
We confirm that today we have filed an amended version of the 2025 Q1 10-Q with updated certifications that are signed and currently dated.

 * * *

 We greatly appreciate your attention to this matter. If you have any further
comments or questions regarding this letter, please contact the undersigned at (408) 595-0441.

 Sincerely,

 /s/ Samantha Wellington

 Samantha Wellington

 Senior Vice President, Chief Legal Officer and Secretary