SEC Comment Letter for MERCADOLIBRE INC (MELI) (CIK 0001099590) (MELI) — Aug 18, 2014
MERCADOLIBRE INC (MELI) (CIK 0001099590)
Date: Aug. 18, 2014 · CIK: 0001099590 · Accession: 0000000000-14-041729
AI Filing Summary & Sentiment
Referenced dates: July 18, 2014, July 3, 2014
Letter
August 18, 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 File No. 001 -33647
Dear Mr. Arnt :
We have reviewed your letter dated July 18, 2014 in connection with the above - referenced filing an d have the following comment. In our comment , 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 advising us when you will provide the requested response. If you do not believe our comment applies 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 and the information you provide in response to this comment, we may have additional comments . Unless otherwise noted , where prior comments are referred to they refer to our letter dated July 3, 2014 .
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. We note your response to prior comment 1. Please clarify how your disclosures on page 60 comply with the requirements of Item 303(a)(3)(iii) of Regulation S -K and Section III.D of SEC Release No. 33 -6835. In this regard, for each of your segments, you attribute increases in your marketplace revenues to increases in unit sales and growth in fees, without quantifying the amount that each source contributed to the change. While
Mr. Pedro Arnt Mercado Libre, Inc. August 18, 2014 Page 2
we note that your prices are fixed p ercentages of the prices which the sellers post on your web site, and you have not changed such percentages significantly, the increase in your revenues as a result of increases in seller prices represents a source of change that should be quantified, if m aterial. 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 re lated matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3488.
Sincerely,
/s/ Patrick Gilmore for
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August 18, 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 File No. 001 -33647 Dear Mr. Arnt : We have reviewed your letter dated July 18, 2014 in connection with the above - referenced filing an d have the following comment. In our comment , 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 advising us when you will provide the requested response. If you do not believe our comment applies 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 and the information you provide in response to this comment, we may have additional comments . Unless otherwise noted , where prior comments are referred to they refer to our letter dated July 3, 2014 . 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. We note your response to prior comment 1. Please clarify how your disclosures on page 60 comply with the requirements of Item 303(a)(3)(iii) of Regulation S -K and Section III.D of SEC Release No. 33 -6835. In this regard, for each of your segments, you attribute increases in your marketplace revenues to increases in unit sales and growth in fees, without quantifying the amount that each source contributed to the change. While Mr. Pedro Arnt Mercado Libre, Inc. August 18, 2014 Page 2 we note that your prices are fixed p ercentages of the prices which the sellers post on your web site, and you have not changed such percentages significantly, the increase in your revenues as a result of increases in seller prices represents a source of change that should be quantified, if m aterial. 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 re lated matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3488. Sincerely, /s/ Patrick Gilmore for Stephen Krikorian Accounting Branch Chief cc: Marcelo Melamud Chief Accounting Officer