SecProbe.io

July 3, 2014

Via E -mail
Pedro Arnt
Chief Financial Officer
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc .
 Form 10 -K for the Fiscal Year Ended December 31, 201 3
 Filed March 3, 2014
 Form 8 -K
Filed May 16, 2014
File No. 001 -33647

Dear Mr. Arnt :

We have reviewed your filing s 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 th is letter within ten business days by amending your filing s, by
providing the requested information, or by advising 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 filing s and the information you provide in
response to these comment s, we may have  additional comments.

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

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of operations

Net revenues, page 59

1. Tell us what consideration you gave to explaining your increases in revenues by segment
in the local cur rency, including quantifying the extent to which increases are due to
changes in prices and changes in unit sales. In this regard, we note that inflation has had a
significant impact on several of your geographies. Further, to the extent that there are

Mr. Pedro Arnt
Mercado Libre, Inc.
July 3, 2014
Page 2

 significant differences between the rate of inflation in these geographies and the rate of
currency devaluation against the U.S. dollar, in either your revenue or expenses, tell us
what consideration you gave to disclosing this.

Quantitative and Qualitative  Disclosures About Market Risk, page 73

2. We note your disclosures on page 106 regarding the controls and restrictions on the
acquisition of foreign currencies in Argentina, and your disclosure on page 145 regarding
the increase in the Argentinean peso exch ange rate against the U.S. dollar during January
2014. Tell us what consideration you gave to disclosing summarized financial
information and the net monetary assets and liabilities held by your subsidiary in
Argentina, as well as sensitivity information r egarding potential impacts of changes in
exchange rates.

Form 8-K filed May 16, 2014

3. Your disclosure indicates that you are reviewing your long -lived assets, goodwill and
intangible assets with indefinite useful life for impairment considering the lower  U.S.
dollar -equivalent cash flows now expected from your  Venezuelan business as well as
considering their “current expected use in the new context.”  Please explain what you
mean by “current expected use in the new context” and explain how this impact s the
recoverability of your assets.

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 t he disclosures they 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 securities laws of the United States.

Mr. Pedro Arnt
Mercado Libre, Inc.
July 3, 2014
Page 3

 You may contact Laura Veator, Staff Accountant , at (202) 551 -3716, or Christine Davis,
Assistant Chief Accountant, at (202) 551 -3408, if you have questions regarding comments on the
financial statements and  related matters. If you require further assistance, do not hesitate to
contact me at (202) 551 -3488.

Sincerely,

 /s/ Stephen Krikorian

Stephen Krikorian
Accounting Branch Chief

cc:   Marcelo Melamud
 Chief Accounting Officer