SecProbe.io

Mail Stop 4561
May 22, 2017

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, 2016
Filed February 24, 2017
File No. 001-33647

Dear Mr. Arnt :

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 these comments within ten business days by providing the requested
information or advi se us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments, we may have additional comments.

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

Description of line items

Sales and marketing expenses, page 46

1. Please explain your basis for including the charges related to the buyer protection
program in sales an d marketing and refer to the authoritative guidance you relied upon
when determining your classification.

Pedro Arnt
MercadoLibre, Inc.
May 22, 2017
Page 2

 Results of operations

Net revenues, page 5 6

2. You disclose that the increases in Non -Marketplace revenue in Brazil and Argentina
during 2016 wer e mainly driven by the volumes of financing transactions, off -platform
transactions, items shipped and ad sales.  To the extent material, please quantify the
contribution of each of these factors in future filings.  As part of your response, please
explain  to us why you do not disclose the impact of the local currency devaluation on
Non-Marketplace revenues.  Refer to Item 303(a)(3)(iii) of Regulation S -K and Section
III.D of SEC Release No. 33 -6835.

3. You disclose on page 23 that your MercadoPago  business has not obtained the requisite
authorization of the Brazilian Central Bank to carry out certain payment processing
functions, which may have a material adverse effect on your business and results of
operations.  Please tell us the amount of reven ue earned from your MercardoPago
business in Brazil during each annual period presented  and how you considered
quantifying in your MD&A the potential adverse impact this uncertainty may have on
your operations.  Refer to Item 303(a) of Regulation S -K and S ections III.B.3 and IV.B.1
of SEC Release No. 33 -8350.

Consolidated Financial Statements

Notes to Consolidated Financial Statements

Note 2. Summary of significant accounting policies

Revenue recognition, page 14

4. Please describe for us the various off erings under MercadoPago and the respective
revenue recognition policy for each offering.  Distinguish the fees earned for providing
financing directly and any other fees earned before the credit card receivables are sold to
third parties.  Revise your dis closure in future filings to provide a more comprehensive
policy for financing revenues.

Note 7. Segments, page 32

5. Please tell us how you considered disclosing revenue for each Non -Marketplace service
or groups of similar services pursuant to ASC 280 -10-50-40.  In your response, quantify
the revenues from financing fees, off -platform payment fees, shipping fees and
advertising services during each annual period  presented .

Pedro Arnt
MercadoLibre, Inc.
May 22, 2017
Page 3

 We remind you that the company and its management are responsible for the accura cy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Mengyao Lu, Staff Accountant , at (202) 551 -7271 , or Christine Dietz,
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
Office of Information Technologies
and Services