SecProbe.io

March 15, 2011
 Via E-Mail

Hernán Kazah Chief Financial Officer MercadoLibre, Inc. Arias 375, 7
th Floor
Buenos Aires, C1430CRG, Argentina
Re: MercadoLibre, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2010
Filed February 25, 2011 File No. 001-33647

Dear Mr. Kazah:
 We have reviewed your filing 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the Fiscal Year Ended December 31, 2010

 Item 1A. Risk Factors

 “Political and economic conditions in Venezuela . . .”, page 26

1. We note your disclosure on page 27 where you st ate that you requested U.S. dollars at the
official exchange rate for the first time for dividend distribut ions, which is pending
approval from the Venezuelan Commission of  Foreign Exchange Administration.  Please
clarify and quantify the restri ction this pending approval has on the distribution of your
net assets from your Venezuelan operations  to either the parent company or your
shareholders, if any (see Rule 4-08(e) of Regulation S-X).
2. In addition, given the risks presented by cu rrency restrictions di scussed, as well as
concern over whether the official rate is re flective of economic re ality, tell us if you

Hernán Kazah MercadoLibre, Inc. March 15, 2011
Page 2

 considered providing summarized financial in formation for your Venezuelan operations,
including sales, total assets, liabilities and net assets as of the periods  presented in either
your MD&A or liquidity discussion.  In your  response, please provi de us with balance
sheet information for your Venezuel an operations as of December 31, 2010.

Item 7.  Management’s Discussion and Analys is of Financial Condition and Results of
Operations
 Critical Accounting Policies and Estimates

 Accounting for Income Taxes, page 61

3. Tell us your consideratio n to provide disclosures that expl ain in greater detail the impact
on your effective income tax rates and ob ligations of having proportionally higher
earnings in countries where you have lower statut ory tax rates.  In this regard, you should
consider explaining the relati onship between the foreign and domestic effective tax rates
in greater detail as it appear s as though separately discussing  the foreign effective income
tax rates may be important information necessary to understanding your results of
operations.  To the extent that  one or two countries have ha d a more significant impact on
your effective tax rate, then tell us how you considered disclosing this information and
including a discussion regarding how potential changes in such countries’ operations may
impact your results of operations.  Also, tell us if you have entered into any agreements
with the Internal Revenue Se rvice with regard to certain  foreign jurisdictions (e.g.
advanced pricing agreements), and if so te ll us what considerat ion you have given to
including a discussion of the material terms of such agreements. We refer you to Item
303(a)(3)(i) of Regulation S-K and S ection III.B of SEC Release 34-48960.

Liquidity and Capital Resources, page 71
4. You indicate on page F-48 that some of your non-U.S. subsidiaries’ undistributed
earnings are intended to be indefinitely rei nvested in your international operations and
potential acquisitions related to  those operations.  Please clarify and disclose in future
filings what portion of the $45.6 million in to tal non-U.S. subsidiaries’ undistributed
earnings are considered to be i ndefinitely reinvested.  If it is  material to your operations,
tell us your consideration to  disclose the amount of cash and investments that are
currently held outside of the U.S. and th e impact of repatriating the undistributed
earnings of foreign subsidiaries. We refer you to Item 303(a)(1) of Regulation S-K and
Section IV of SEC Release 34-48960.

Hernán Kazah MercadoLibre, Inc. March 15, 2011
Page 3

 Item 15. Exhibits and Financial Statement Schedules

 Note 2. Summary of Significant Accounting Policies

 Revenue Recognition, page F-16

5. We note that you earn revenue from various fees, such as listing and optional fees
(upfront fees), final value fees, and on-lin e payment fees in certain instances.  Please
provide us with and tell us how you cons idered disclosing your accounting policy for
recognizing revenue for multiple element arrangements pursuant to ASC 605-25-50.

Highly Inflationary status in Venezuela, page F-20
6. We note that the Company accounted for its Ve nezuela operations as highly inflationary
beginning on January 1, 2010 in accordance wi th ASC 830-30-S99.  Please tell us the
differences, if any, between the amounts report ed for financial reporting purposes versus
the underlying U.S. dollar denominated values for each relevant line item while using the
parallel rates.  Additionally, please tell us  if such amounts were recognized through the
income statement or the cumulative translation adjustment and how you determined this classification was appropriate.  To the extent this information is material, tell us how you
considered disclosing it pursuant to th e disclosure guidance in ASC 830-30-S99.

Note 8. Fair Value Measurement of Assets and Liabilities, page F-40

7. For your available for sale securities with gr oss unrealized loss pos itions, please tell us
how you considered providing all of the disc losures required by AS C 320-10-50-6(b).

Note 14. Income Taxes, page F-46
8. Tell us how you considered disclosing the am ounts and expiration dates of operating loss
and tax credit carry-forward s for tax purposes pursua nt to ASC 740-10-50-3(a).
9. We also note that you reversed $4.6 million and $4.1 million of your deferred tax asset
valuation allowance in fiscal 2010 and 2009, re spectively.  Please describe in further
detail the tax planning strategies you implem ented during both of these years to more
efficiently use your accumulated tax loss carry -forward credits from acquired companies.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Hernán Kazah MercadoLibre, Inc. March 15, 2011
Page 4

  In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Melissa Feid er at (202) 551-3379 if you have questions regarding
comments on the financial statements and relate d matters.  Please contact me at (202) 551-3499
with any other questions.
Sincerely,  /s/  Kathleen Collins

Kathleen Collins Accounting Branch Chief