SecProbe.io

May 9, 2013

Via E -mail
Pedro Arnet
Executive VP & CFO
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc .
 Form 10-K for Fiscal Year Ended December 31, 201 2
 Filed February 28, 201 3
File No. 001-33647

Dear Mr. Arnet :

We have reviewed your filing and have the following comments.  Comments, if any,
related to disclosure in Part III of your Form 10 -K, will be provided under separate cover.  In 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 facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your fil ing and the information you provide in
response to these comments, we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 201 2

Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of
Operation s

Critical Accounting Policies and Estimates

Foreign Currency Translation, page 49

1. We note that no dividends were declared by your Venezuelan subsidiaries during the year
ended December 31, 2012.  Tell us if you were restricted from making distributions  from
these subsidiaries during 2012 as a result of the SITME regulations in place.  Also, tell us
whether you expect the elimination of the SITME on February 9, 2013 and the

Pedro Arnet
MercadoLibre, Inc.
May 9, 2013
Page 2

 implementation of the SICAD on March 19, 2013 to restrict your Venezuelan
subsidi aries’ ability to make dividend distributions in the future.  While we note your
discussion of volume restrictions imposed by the SITME, it is unclear to what extent
these restrictions impacted your ability to make distributions .  Please tell us what
consi deration you gave to disclosing these factors.   Also, to the extent that you believe
these restrictions will not have a material adverse effect on your overall business as you
currently indicate on page 51, tell us your consideration to further enhance yo ur
disclosure to explain such conclusions.

2. We note the risk factor disclosure on page 27 of your December 31, 2011 Form 10 -K
where you state, if current volume restrictions on foreign exchange imposed by the
government worsen significantly or new regulations are implemented , which impact your
ability to settle transactions at either the official rates or SITME rate, you could be
required to deconsolidate your Venezuelan operations for accounting purposes.   Please
tell us whether  deconsolidation o f your Venezuelan subsidiary is still a potential risk to
the company and if so, tell us why you have not included a discussion of this risk in your
current Form 10 -K.  Also, tell us what impact the elimination of the SITME in February
2013  and the creatio n of the SICAD  in March 2013  will have on the accounting for your
Venezuelan operations.  As part of your response, please tell us how your current
inability to access the auction process by which acquisition of foreign currencies will be
made under the ne w system impacts the accounting for your Venezuelan operations.

Results of Operations

Year Ended December 31, 2012 compared t o year ended December 31, 2012, Page 61

3. We note your disclosure of the percentage increases in gross merchandise volume,
financing and off -platform payments, and classified and add sales  revenues . Please tell us
what consideration you gave to quantifying the dollar amount for each of  these re venue
streams and how changes in such amounts and the related metrics impacted your
revenues.  We refer you to Item 303(a)(3)(iii) of Regulation S -K and Section III.D of
SEC Release No. 33 -6835.

4. We note your disclosure of growth in net revenues measured in local currencies. Please
tell us what consideration you gave to also disclosing changes in expenses and segment
revenues measured in local currencies.

5. Please tell us what consideration you gave to disclosing explanations for changes in your
segment net revenues and direct costs. We refer you to Item 303(a) of Regulation S -K
and Sect ion III.F.1 of SEC Release No. 33 -6835.

6. Also, please tell us why you do not include a  discussion of your key metrics  (i.e., gross
merchandise volume, successful items sold and payment volume) and their impact on the

Pedro Arnet
MercadoLibre, Inc.
May 9, 2013
Page 3

 related geographic/segmental revenues.  In your response, please address whether there
are any material geographic differences or trends.  See Item 303(a) of Regulation S -K,
and for guidance, refer to Sections I.B and III.B of SEC Release No. 33 -8350.

Liqui dity and Capital Resources, page 72

7. We note from your response  to comment 4 in your March 29, 2011 letter and comment 2
in your July 13, 2012 letter that you would disclose  the amount of cash and investments
held by foreign subsidiaries as well as the per centage of your consolidated cash and
investments that are held outside the U.S.  However, it does not appear that you have
disclosed this information.   Please advise.

Item 10.  Directors, Executive Officers and Corporate Governance, page 80

8. You indica te that disclosure required by this Item is incorporated by reference from your
definitive proxy statement, but you have not clearly identified, by caption or otherwise,
the material incorporated by reference as required by Securities Exchange Act Rule 12b -
23(b).   In future filings, please ensure that the Part  III disclosure identifies by title the
section of your definitive proxy statement from which you are incorporating by reference
the required disclosure, or otherwise clearly identify the material inco rporated by
reference.   This comment also applies to Items 11 – 14 of Part III of your Form 10 -K.

Item 15.  Exhibits, Financial Statement Schedules

Notes to Consolidated Financial Statements

Note 7.  Segments

9. Tell us how you considered the guidance in ASC 280 -10-50-40 to include a breakdown
of revenues for each of your products and services (i.e., marketplace, online payment
solutions, advertising services and online stores).  In your response, pleas e provide us
with a breakdown of these  revenue  streams  for each period presented.

Note 8.  Fair Value Measurement of Assets and Liabilities, page 34

10. Please tell us what consideration you gave to disclosing the countries in which your
sovereign debt is invested and any risk factors associated with thes e countries.

Pedro Arnet
MercadoLibre, Inc.
May 9, 2013
Page 4

 Note 15.  Commitments and Contingencies, page 45

11. Please tell us the factors you considered in determining the risk of loss relating to the City
of Sao Paulo Tax Claims for the years 2005 through 2010 is remote.  In this regard, we
note that in 2007 the tax authorities ruled against the Brazilian subsidia ry and you made a
deposit in court of $5.1 million relating to the 2005 through 2007 claims.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the  Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 t hey have made.

 In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 federal securit ies laws of the United States.

You may contact Laura Veator , Staff Accountant , at (202) 551 -3716  if you have
questions regarding comments on the financial statements and re lated matters.  If you have any
other questions, please contact Gabriel Eckstein, Attorney -Advisor, at (202) 551 -3286 or Maryse
Mills -Apenteng, Special Counsel, at (202) 551 -3457.   If you require further assistance, do not
hesitate to contact me at (202) 551 -3499.

Sincerely,

 /s/  Kathleen Collins

Kathleen Collins
Accounting Bra nch Chief

cc:   Marcel o Melamud
 Chief Accounting Officer