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UPLOAD Filing

MERCADOLIBRE INC
Date: May 13, 2025 · CIK: 0001099590 · Accession: 0000000000-25-005109

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File numbers found in text: 001-33647

Date
May 13, 2025
Author
Division of
Form
UPLOAD
Company
MERCADOLIBRE INC

Letter

Re: MercadoLibre, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 File No. 001-33647 Dear Mart n de los Santos:

May 13, 2025

Mart n de los Santos Executive Vice President and Chief Financial Officer MercadoLibre, Inc. WTC Free Zone Dr. Luis Bonavita 1294, Of. 1733, Tower II Montevideo, Uruguay, 11300

We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s).

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

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

Form 10-K for Fiscal Year Ended December 31, 2024 Consolidated Financial Statements Consolidated Statements of Cash Flows, page 83

1. We note consumers have access to credit lines for loans that can be used for a purchase on the Mercado Libre Marketplace. Please tell us how you classify cash receipts for loans from inventory sales reflected as "commerce product sales" in Note 10. Refer to ASC 230-10-45-16a. May 13, 2025 Page 2

In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Scott Stringer at 202-551-3272 or Adam Phippen at 202-551-3336 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 13, 2025

Mart n de los Santos
Executive Vice President and Chief Financial Officer
MercadoLibre, Inc.
WTC Free Zone
Dr. Luis Bonavita 1294, Of. 1733, Tower II
Montevideo, Uruguay, 11300

 Re: MercadoLibre, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
 File No. 001-33647
Dear Mart n de los Santos:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for Fiscal Year Ended December 31, 2024
Consolidated Financial Statements
Consolidated Statements of Cash Flows, page 83

1. We note consumers have access to credit lines for loans that can be used
for a
 purchase on the Mercado Libre Marketplace. Please tell us how you
classify cash
 receipts for loans from inventory sales reflected as "commerce product
sales" in Note
 10. Refer to ASC 230-10-45-16a.
 May 13, 2025
Page 2

 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Scott Stringer at 202-551-3272 or Adam Phippen at
202-551-3336 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>