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Correspondence

MERCADO LIBRE, INC

ARIAS3751, 7TH FLOOR

BUENOS AIRES, C1430CRG

ARGENTINA

TEL 011• 5411 • 4640 • 8000

HERNAN KAZAH.

DIRECT DIAL: 011-5411-4640-8004

EMAIL: hernan@mercadolibre.com

March 29, 2011

VIA E- MAIL

Ms. Kathleen Collins

Accounting Branch Chief

United States Securities and Exchange Commission

Division of Corporation Finance

One Station Place

100 F Street, N.E.

Washington, D.C. 20549-4561

    Re:

    MercadoLibre, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2010

Filed February 25, 2011

File No. 001-33647

Dear Ms. Collins:

MercadoLibre, Inc. a Delaware corporation (the “Company,” “we” or “us”), is transmitting for filing
the Company’s responses 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, 2010 filed on February 25, 2011
(File No. 001-33647), contained in your comment letter dated March 15, 2011.

For convenience of reference, each Staff comment contained in your March 15, 2011 comment letter is
reprinted below in italics, numbered to correspond with the paragraph number assigned in your
comment letter and is followed by the corresponding response of the Company.

Page 2

Form 10-K for the Fiscal Year Ended December 31, 2010

Item 1A. Risk Factors

“Political and economic conditions in Venezuela . . .”, page 26

    1.

    We note your disclosure on page 27 where you state that you requested U.S. dollars at the
official exchange rate for the first time for dividend distributions, which is pending
approval from the Venezuelan Commission of Foreign Exchange Administration. Please clarify and
quantify the restriction this pending approval has on the distribution of your net assets from
your Venezuelan operations to either the parent company or your shareholders, if any (see Rule
4-08(e) of Regulation S-X).

Response: We advise the Staff that during 2010 and previous years we were able to obtain
U.S. dollars using alternative mechanisms other than the Venezuelan Commission of Foreign Exchange
Administration (“CADIVI”). These dollars, obtained at a higher exchange rate than the one offered
by CADIVI, and held in balance at U.S. Bank accounts of our Venezuelan subsidiaries, were used for
dividend distributions from our Venezuelan subsidiary. As a result, during 2010, lack of CADIVI
approval did not restrict our ability to distribute the full amount of our retained earnings as
dividends related to fiscal years 2008 ($0.8 million), and 2009 ($1.8 million).

We also plan to distribute dividends related to earnings for fiscal year 2010, in the approximate
amount of $4.2 million, using existing cash balances held in the U.S. bank accounts of our
Venezuelan subsidiary and to reinvest the additional cash generated by our Venezuelan operations by purchasing
our own office space in that country. As disclosed on page 50 and F-19 of our filing, the alternative mechanisms
mentioned above are no longer available. The new mechanisms available as a result of the new rules
implemented by the Government of Venezuela in June of 2010 imply increased restrictions, which are discussed in our Form 10-K.

Net assets of our Venezuelan subsidiary amount to approximately 8% of our consolidated net assets,
and cash and investments of our Venezuelan subsidiary held in local currency in Venezuela amount
only to approximately 5% of our consolidated cash and investments.

As a result of the foregoing, we do not expect the current restrictions to have a
significant adverse effect on our business plans with regard to our investment in Venezuela.

Page 3

Beginning with our next quarterly Form 10-Q filing, we will include the description of the above
paragraphs and any new significant developments and their relative effect.

    2.

    In addition, given the risks presented by currency restrictions discussed, as well as concern
over whether the official rate is reflective of economic reality, tell us if you considered
providing summarized financial information for your Venezuelan operations, including sales,
total assets, liabilities and net assets as of the periods presented in either your MD&A or
liquidity discussion. In your response, please provide us with balance sheet information for
your Venezuelan operations as of December 31, 2010.

Response: We advise the Staff that we provided both the amount of net assets and net
revenues for Venezuelan operations. Specifically, on page 50 of our MD&A we provide our Venezuelan
net assets and on page 62 and 66 our net revenues appear as one of our operating segments.
Venezuelan net revenues also appear on page 77 under the caption “Foreign Currency Risk”. For the
2010 Form 10-K, we did not believe that providing more detailed information relating to our balance
sheet for our Venezuelan operations was relevant since, as of the end of fiscal year 2010, our
Venezuela operation’s net assets mainly consisted of monetary assets and liabilities relating to
the ordinary course of business, except for the goodwill balance which is already disclosed
segregated by geography in our financial statements. However, in future filings (beginning in the
first quarter of 2011), we will include the detail of total assets and total liabilities to
complement the information we already disclose for our Venezuelan operations as disclosed below.

The following table sets forth the Venezuelan Assets, Liabilities, Net Assets and Net Revenues for
the three years ended December 31, 2010.

    December 31,

    2010

    2009

    2008

    Venezuelan operations

    Net Revenues

    20,885,541

    27,331,095

    23,123,837

    Assets

    21,928,340

    15,471,344

    34,251,432

    Liabilities

    (8,212,581
    )

    (6,557,337
    )

    (12,366,560
    )

    Net Assets

    13,715,759

    8,914,007

    21,884,872

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of

Operations

Page 4

Critical Accounting Policies and Estimates

Accounting for Income Taxes, page 61

    3.

    Tell us your consideration to provide disclosures that explain in greater detail the impact
on your effective income tax rates and obligations of having proportionally higher earnings in
countries where you have lower statutory tax rates. In this regard, you should consider
explaining the relationship between the foreign and domestic effective tax rates in greater
detail as it appears as though separately discussing the foreign effective income tax rates
may be important information necessary to understanding your results of operations. To the
extent that one or two countries have had a more significant impact on your effective tax
rate, then tell us how you considered disclosing this information and including a discussion
regarding how potential changes in such countries’ operations may impact your results of
operations. Also, tell us if you have entered into any agreements with the Internal Revenue
Service with regard to certain foreign jurisdictions (e.g. advanced pricing agreements), and
if so tell us what consideration you have given to including a discussion of the material
terms of such agreements. We refer you to Item 303(a)(3)(i) of Regulation S-K and Section
III.B of SEC Release 34-48960.

Response: As disclosed on page 65 of our Form 10-K for the Fiscal Year Ended December 31,
2010, our effective income tax rate is defined as the provision for income taxes (net of charges
related to dividend distribution from foreign subsidiaries which are offset with domestic foreign
tax credits) as a percentage of pre-tax income. The effective income tax rate excludes the effects
of the deferred income tax and of the Mexican tax called “Impuesto Empresarial a Tasa Única”
(“IETU”).

The following table sets forth our effective income tax rate related to our main locations as of
December 31, 2010

    Argentina

    Brazil

    Mexico

    Venezuela

    Effective Income Tax rate

    18.2
    %

    31.9
    %

    33.9
    %

    41.9
    %

As disclosed on page F-21 of our 2010 Financial Statements, the Company’s Argentine subsidiary is a
beneficiary of a software development law granting it a relief of 60% of total income tax
determined in each year. Mainly for that reason, as of December 31, 2010, our Argentine operation’s
effective income tax rate of 18.2% is currently lower than the local statutory rate of 35%. If the
Company had not been granted the Argentine tax holiday, the Company would have pursued an alternative tax planning strategy and, therefore, the impact of not
having this particular benefit could result in a higher effective tax rate in Argentina, but not
necessarily in a 35% effective tax rate.

Page 5

As of December 31, 2010, our Brazilian effective income tax rate is lower than the local statutory
rate of 34% mainly because of the business reorganization generated as part of our tax planning
strategy, which permitted us to use tax loss carryforwards in that country.

As of December 31, 2010, our Mexican and Venezuelan effective income tax rates are higher than the
local statutory rate of 30% and 34%, respectively, mainly because of variations in both temporary
and permanent tax differences.

Our effective tax rate reflects the tax effect of significant operations outside the United States,
which are generally taxed at rates lower than the U.S. statutory rate of 35 percent, especially in
the case of Argentina, where we have significant operations with an effective tax rate of
approximately 18%. A future change in the mix of pretax income from these various tax jurisdictions
would impact the Company’s periodic effective tax rate.

In connection with the relationship between the foreign and domestic income tax rate, we do not
expect it to have a significant impact in the domestic effective income tax rate related to
dividend distributions from foreign subsidiaries since our strategy is to reinvest our cash surplus
in our international operations, and to distribute dividends when they can be offset with available
tax credits.

In future filings (beginning in the first quarter of 2011) we will include in our MD&A quantitative
disclosure related to the individual effective income tax rate of our main operations and the above
explanations relating to the countries that have a significant impact on our effective tax rate and
how potential changes in such countries’ operations may impact our results of operations.

We advise the Staff that we have not entered into any agreements with the Internal Revenue Service
with regard to certain foreign jurisdictions.

Page 6

Liquidity and Capital Resources, page 71

    4.

    You indicate on page F-48 that some of your non-U.S. subsidiaries’ undistributed earnings are
intended to be indefinitely reinvested in your international operations and potential
acquisitions related to those operations. Please clarify and disclose in future filings what
portion of the $45.6 million in total non-U.S. subsidiaries’ undistributed earnings are
considered to be indefinitely reinvested. If it is material to your operations, tell us your
consideration to disclose the amount of cash and investments that are currently held outside of
the U.S. and the impact of repatriating the undistributed earnings of foreign subsidiaries. We
refer you to Item 303(a)(1) of Regulation S-K and Section IV of SEC Release 34-48960.

Response: We estimate that the portion of undistributed earnings to be indefinitely
reinvested in our international operations and in potential acquisitions amounts to approximately
$19.5 million. In future filings we will disclose the undistributed earnings that we plan to
reinvest indefinitely in our business.

As of December 31, 2010, cash and investments of foreign subsidiaries amount to $114.5 million or
81.2% of our consolidated cash and investments and approximately 55% of consolidated cash and
investments are held outside the U.S., mostly in Brazil.

Our strategy is to reinvest our undistributed earnings of our foreign operations in those
operations and to distribute dividends when they can be offset with available tax credits.

In addition, we advise the Staff that we do not expect a material impact in any repatriation of
undistributed earnings of foreign subsidiaries on our operations since the taxable domestic gains
generated by any dividend distributions will be mostly offset with foreign tax credits that arise
from income tax paid in our foreign operations, which we are allowed to compute for domestic income
tax purposes.

We will disclose in future filings the above paragraphs.

Item 15. Exhibits and Financial Statement Schedules

Note 2. Summary of Significant Accounting Policies

Revenue Recognition, page F-16

    5.

    We note that you earn revenue from various fees, such as listing and optional fees (upfront
fees), final value fees, and on-line payment fees in certain instances. Please provide us with
and tell us how you considered disclosing your accounting policy for recognizing revenue for
multiple element arrangements pursuant to ASC 605-25-50.

Page 7

Response: We generate revenues for different services that we provide. When more than one
service is included in one single arrangement with the customer, we recognize revenue according to
multiple element arrangements accounting, distinguishing between each of the services provided and
allocating revenues based on their respective fair value. Those services are separately recognized
as revenue according to the criteria described for each type of services on page F-16. The most
common case of multiple element arrangement includes two services in a single agreement. Due to the
nature of our services and the short-term duration of these agreements (typically with term of up
to 2 months), the timing of delivery of both services generally coincides so the effect of such
segregation has not been significant. Considering that, from time to time, we may implement new
forms of arrangements with our customers, we will start including in our filing for the period
ended March 31, 2011 an explanation of our multiple element arrangement accounting.

Highly Inflationary status in Venezuela, page F-20

    6.

    We note that the Company accounted for its Venezuela operations as highly inflationary
beginning on January 1, 2010 in accordance with ASC 830-30-S99. Please tell us the
differences, if any, between the amounts reported for financial reporting purposes versus the
underlying U.S. dollar denominated values for each relevant line item while using the parallel
rates. Additionally, please tell us if such amounts were recognized through the income
statement or the cumulative translation adjustment and how you determined this classification
was appropriate. To the extent this information is material, tell us how you considered
disclosing it pursuant to the disclosure guidance in ASC 830-30-S99.

Response: We advise the Staff that, as described on page F-18 of our consolidated financial
statements, the assets, liabilities, income and expense accounts of our Venezuelan subsidiaries
were translated at the official rate of 2.15 “Bolívares Fuertes” per US dollar up to September 30,
2009.

Furthermore, U.S. dollar assets and liabilities maintained by the Venezuelan subsidiaries were
first re-measured into the functional currency “Bolívares Fuertes” at a parallel exchange rate, and
then translated into the reporting currency at the official exchange rate of 2.15 “Bolívares
Fuertes” per US Dollars.

As a result of using the official rate to translate U.S. dollar denominated values of the
Venezuelan subsidiaries through September 30, 2009, the increase in the value of assets was
recorded in the “Other non-current assets” line by crediting Other Comprehensive Income.

Page 8

As disclosed on page 49 of our Form 10-K for the Fiscal Year Ended