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CORRESP
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MERCADOLIBRE,
INC.

ARIAS 3751, 7TH FLOOR

BUENOS AIRES,
C1430CRG

ARGENTINA

TEL +5411 — 4640 — 8000

PEDRO
ARNT

DIRECT DIAL:
+5411 — 4640 — 8006

EMAIL: pedro@mercadolibre.com

June
28, 2017

Via
EDGAR Correspondence

Mr. Stephen
Krikorian

Accounting
Branch Chief

United States
Securities and Exchange Commission

Division of
Corporation Finance

Office of Information
Technologies and Services

100 F Street,
N.E.

Washington,
D.C. 20549-4561

    Re:
    MercadoLibre, Inc.

Form
10-K for Fiscal Year Ended December 31, 2016

Filed
February 24, 2017

File
No. 001-33647

Dear
Mr. Krikorian,

MercadoLibre,
Inc., a Delaware corporation (the “Company,” “MercadoLibre”, “we” or “us”), responds
below to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange
Commission (the “SEC”), with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31,
2016 (the “Form 10-K”) filed on February 24, 2017 (File No. 001-33647), contained in your comment letter
dated June 15, 2017 (the “Comment Letter”).

For
convenience of reference, each Staff comment contained in the Comment Letter is reprinted below in italics, numbered to correspond
with the paragraph number assigned in the Comment Letter and is followed by the corresponding response of the Company.

Form
10-K for Fiscal Year Ended December 31, 2016

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

Description of line items

Sales and marketing expenses, page 46

 1. Please tell us whether your buyer protection program represents
a guarantee that should be accounted for under ASC 460-10. If this is the case, revise to provide the required disclosures pursuant
to ASC 460-10-50 in the footnotes to the financial statements.

Response: We advise the Staff
that we believe that our buyer protection program is effectively a guarantee and subject to the disclosure requirements under ASC
460-10-50.

This program provides protection on Marketplace
transactions that are processed through our online payment solution (“MercadoPago”), and as a result, the maximum potential
exposure is related to the volume of payments on our marketplace during the period for which
customer protection claims may be raised under existing user agreements. Based on historical losses to date, we do not believe
that the maximum potential exposure is representative of our actual potential exposure. We disclose our total volume of payments
on marketplace on page 40 of our Form 10-K for the fiscal year ended December 31, 2016.

We advise the Staff that we have assessed the
disclosure requirements under ASC 460-10-50 to be immaterial from both a qualitative and quantitative perspective as of December
31, 2016. Nevertheless, due to the expected increase in the buyer protection program in future periods, in future filings, beginning
with our Form 10-Q for the period ended June 30, 2017, we will include in the “Commitments and Contingencies” footnote
to the financial statements a description of the nature, the maximum potential exposure to, and the amount provisioned from, our
buyer protection program, as follows:

Example disclosure:

The Company provides consumers with a buyer
protection program (“BPP”) for all transactions completed through the Company’s online payment solution (“MercadoPago”).
This program is designed to protect buyers in the Marketplace from losses due primarily to fraud or counterparty non-performance.
The Company’s BPP provides protection to consumers by reimbursing them for the total value of the unfulfilled transaction,
if a purchased item does not arrive or does not match the seller’s description. The Company is entitled to recover from the
third-party carrier companies performing the shipping service certain amounts paid under the BPP. Furthermore, in some specific
circumstances (i.e. Black Friday, Hot Sale), the Company enters into insurance contracts with third party insurance companies in
order to cover contingencies that may arise from the BPP.

The maximum potential exposure under this program
is estimated to be the volume of payments on the Marketplace, for which claims may be made under the Company’s existing user
agreements. Based on historical losses to date, the Company does not believe that the maximum potential exposure is representative
of the actual potential exposure. The Company records a liability with respect to losses under this program when they are probable
and the amount can be reasonably estimated.

As of June 30, 2017, management's estimate
of the maximum potential exposure related to the Company’s buyer protection program is $[●], for which we recorded
an allowance as of that date of $[●].

Results of operations

Net revenues, page 56

 2. We reissue prior comment 2. Your response indicates that your
current disclosures allow investors to understand the material factors; however, it does not quantify the contribution of each
factor to the change. Please confirm that you will quantify the contribution of each factor when there is a material change in
your Non-Marketplace revenue. We refer you to Item 303 of Regulation S-K and Section III.D of SEC Release No. 33-6835.

Response:
We advise the Staff that in future filings, beginning with our Form 10-Q for the period ended June 30, 2017, we will quantify
the contribution of each significant factor to the extent there is a material change in our
Non-Marketplace revenue.

Consolidated financial statements

Notes to Consolidated financial statements

Note 7. Segments, page 32

 3. It remains unclear to us how payment related fees, which are
a significant revenue stream, are similar to other services that you consider to be ancillary. In this regard, we note that payment
related fees appear to be very different from shipping or advertising fees. Please provide separate quantification of payment related
fees in future filings.

Response: We
advise the Staff that in future filings, we will provide separate quantification of payment fees.

In response to the Staff’s
comment, below is how the disclosure would look in our Form 10-Q for the period ending June 30, 2017:

Example disclosure:

    Six-months Ended June 30,

    Three-months Ended June 30,

    Consolidated Net Revenues

    2017

    2016

    2017

    2016

    (In thousands)

    (In thousands)

    Marketplace

     $[●]

    $         207,375

     $[●]

    $         113,252

    Non-marketplace (*) (**)

    $[●]

    $         149,899

    $[●]

    $           86,392

    Total

    $[●]

    $         357,274

    $[●]

    $         199,644

(*) Includes mainly Payment Fees,
Ad Sales, Real Estate, Motors, Shipping Fees and other ancillary services.

(**) Includes $[●] and $87,186
of Payment Fees for the six-month periods ended June 30, 2017 and 2016, respectively; and $[●] and $50,570 for the three-month
periods ended June 30, 2017 and 2016, respectively.

If you have any questions or comments
regarding the foregoing, please contact our Chief Accounting Officer, Marcelo Melamud at +5411 4640 8053, marcelo.melamud@mercadolibre.com.
We look forward to working with you on these matters.

Sincerely,

 /s/ Pedro Arnt

Name: Pedro Arnt

Title: Executive Vice President and Chief Financial Officer

    cc:

        Jacobo Cohen Imach

        Pedro Arnt

        Marcelo Melamud

        Federico Gómez Martínez