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CORRESPONDENCE

 MERCADOLIBRE, INC

ARIAS 3751, 7TH FLOOR

 BUENOS AIRES, C1430CRG

 ARGENTINA

TEL +5411
Ÿ 4640 Ÿ 8000

 PEDRO ARNT

DIRECT DIAL: +5411 Ÿ 4640 Ÿ 8006

EMAIL: pedro@mercadolibre.com

July 13, 2012

 Ms. Kathleen Collins

 Accounting Branch Chief

 United
States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549-4561

Re:
MercadoLibre, Inc.

Form 10-K for Fiscal Year Ended December 31, 2011

Filed February 28, 2012

Form 10-Q for Fiscal Quarter Ended March 31, 2012

Filed May 9, 2012

File No. 001-33647

 Dear Ms. Collins,

 MercadoLibre, Inc. a Delaware corporation (the “Company,” “MercadoLibre”, “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, 2011 filed on February 28, 2012 and its Form 10-Q for the Fiscal Quarter Ended March 31, 2012 filed on May 9, 2012 (File No. 001-33647), contained in your comment letter dated June
28, 2012 (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 your comment letter and is followed by the corresponding response of the Company.

 Form 10-K for Fiscal Year Ended December 31, 2011

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

Year ended December 31, 2011 compared to year ended December 31, 2010, page 56

1.
You state that the increase in cost of revenues from fiscal 2010 to fiscal 2011 was primarily attributable to the increase in collection fees associated with the
MercadoPago payment solution. Please explain further the nature of these “collection fees.” Also, tell us how collection fees may differ based on payment solutions, country, marketplace, etc.

Response: In response to the Staff’s comment, we advise the Staff that the “collection fees” relate to the fees that banks,
the credit card issuers and other means of payment charge us for processing payments pursuant to such means of payment. MercadoLibre offers to its users different options for making payments in the different countries in which it operates. Costs
depend on the specific country and the provider of the means of payment, and the costs charged by a specific provider generally do not differ whether they relate to our “on” or “off”-platform solutions. Most payment transactions
are carried out using means of payments where collection costs are agreed between the provider and the Company as a percentage of the amount of the payment, while fewer payment transactions are completed using a mean of payment that charges to us a
fixed amount per transaction in local currency instead of a percentage. With respect to those payment transactions that involve collection costs calculated as a percentage of the amount of the payment, collection fee charges vary depending on the
specific provider and has not changed significantly since the beginning of 2010. More specifically, most credit card fees range from 2% to 3%, while non-credit card fees range from 1.5% to 3% or are a fixed amount per transaction in local currency,
in those countries in which our volume of transaction is significant.

 The increase in the amount of cost of revenues generated by collection
fees in fiscal year 2011 relates to the increase in the total number and amount of transactions made using our payments platform which includes transaction costs derived mainly from credit cards. The main reasons for the increased use of our
payments platform are:

•

 The increase in the number of total transactions made in our marketplace which were settled through MercadoPago. Since mid-2010, we have made available
MercadoPago in Brazil at no added cost to our users. During 2011, we followed the same approach in Mexico and Venezuela. This resulted in a higher penetration and use of our payments platform in those countries.

•

 During 2011 there was an increased usage of MercadoPago off-platform payment in Argentina and Brazil. MercadoPago off-platform payment solution allows
users to utilize MercadoPago for payments on their own independent commerce websites, allowing for payments for transactions that occur outside of our platform. In mid-2010, the Company elected to make available off-platform transactions through
this new direct payments product to any website in Brazil that chose to adopt it. In 2011, the Company started processing off-platform transactions in Mexico and Venezuela.

 Liquidity and Capital Resources, page 66

2.
In your response to comment 4 in your March 29, 2011 letter you provided disclosures regarding the amount of cash and investments of foreign investments as well as
the percentage of your consolidated cash and investments that are held outside the U.S. and indicated that you would include this information in future filings. While we note that you included this information in your quarterly reports on Form 10-Q,
it appears that you have not included it in your annual report on Form 10-K. Please confirm that you will also include this information in your future Form 10-K filings.

 Response: In response to the Staff’s comment, we confirm the Staff that in our future Form 10-K filings we will include the amount of cash and investments of foreign subsidiaries as
well as the percentage of our consolidated cash and investments that are held outside the U.S. We hereby advise the Staff that as of December 31, 2011, cash and investments of foreign subsidiaries amounted to $151.4 million and approximately 45% of
our consolidated cash and investments were held outside the U.S.

3.
Please explain to us your billing and collection procedures for both your up-front and final value fees. In your response, tell us when you bill the sellers
for these services, what the typical payment terms are and how payments are received. For example, as it relates to the final value fees, tell us if the company retains a portion of the fee charged by the seller when processing the buyer’s
payment. Also, tell us whether the allowance for doubtful accounts relates primarily to receivables due from up-front service fees, final value fees or both.

 Response: In response to the Staff comment, we advise the Staff as follows regarding our billing and collection procedures:

 Users are billed once a month. As established in the “Terms of Use” accepted by our users when they agree to use our platform, we bill final value fees once the seller reports the transaction as
completed.

 With respect to up-front fees, once a seller publishes an item on MercadoLibre’s site, our billing system automatically
generates a charge to be billed to the seller in the next billing cycle.

 In both cases, the bill is due within 5 working days following the
date of the invoice. At the fifth day, if the invoice remains unpaid, an automatic process sends an email to the user to notify its unpaid balance. If the invoice remains unpaid on the tenth day following the date of the invoice, the user receives
an email notifying that they are not permitted to use our marketplace until the invoice is paid. If the invoice remains unpaid on the tenth day after this email notice is sent, an additional notification is sent to the user claiming for its unpaid
bills. After an invoice becomes thirty days past due, we send the receivable to a collection management agency in order to try to collect the unpaid amounts from the user.

 We can bill our customers for up-front and final value fees in a single invoice if the conditions for billing final value fees are met in the same month as for the up-front fee, otherwise we bill them in
separate invoices. Therefore, we can collect up-front and final value fees jointly, or separately, as the case may be.

 As established in our Terms of Use accepted by users, a marketplace user may settle the bill for services
provided by us through:

A.
Our payments platform:

a)
MercadoPago retains the final value fee charged to the seller when processing the buyer’s payment; or

b)
the user may settle the bill (up-front fee or final value fee) using their MercadoPago balances available in their accounts

B.
Direct bank transfer, credit cards or others local means of payments

 The allowance for doubtful accounts relates to receivables due from both up-front service fees and final value fees.

4.
Please provide us with an aging analysis of your receivable balances outstanding as of December 31, 2011 as compared to December 31, 2010, with explanations
for significant unreserved past due amounts. Further, to the extent there is a delay in the write-off of fully reserved receivables please explain the reason for this.

 Response: In response to the Staff’s comment, we provide the Staff with an aging analysis of our receivable balances outstanding as of December 31, 2011 and 2010, together with the
explanations for significant unreserved past due amounts, as well as the detail of fully reserved receivables not written-off as of December 31, 2011:

As of December 31, 2011 (in U.S. dollars)

Up to 10
days

11 – 30
days

31 – 45
days

> 45 days

Total

 Total receivables

17,465,707

2,478,880

2,028,182

10,793,815

32,766,584

 Allowance

(2,655,199
)

(1,622,480
)

(1,701,361
)

(9,972,457
)

(15,951,497
)

 Net balance

14,810,508

856,400

326,821

821,358

16,815,087

As of December 31, 2010 (in U.S. dollars)

Up to 10
days

11 - 30
days

31 - 45
days

> 45 days

Total

 Total receivables

13,894,285

2,054,130

1,705,870

6,524,456

24,178,741

 Allowance

(2,551,521
)

(1,349,679
)

(1,376,041
)

(6,283,327
)

(11,560,568
)

 Net balance

11,342,764

704,451

329,829

241,129

12,618,173

 The amount of past due balances greater than 45 days as of December 31, 2011 and 2010 corresponds mainly to
receivables from Advertising sales for which, due to the nature of this business, the allowance for doubtful accounts is estimated when the receivable is 90 days past due.

 As of December 31, 2011, there were past due balances over 180 days fully reserved from our Venezuelan and Colombian subsidiaries, amounting to approximately $ 3.8 million, which we plan to write-off
during 2012.

 Item 9A. Controls and Procedures, page 73

5.
We note that you conduct substantially all of your operations outside of the United States. In order to enhance our understanding of how you prepare your financial
statements and assess your internal control over financial reporting, we ask that you provide us with information that will help us answer the following questions.

•

 How do you evaluate and assess internal control over financial reporting?

In connection with your process to determine whether your internal control over financial reporting was effective, please describe
whether and how you considered controls to address financial reporting risks that are relevant to all locations where you have operations. If you have an internal audit function, please describe it and explain how, if at all, that function impacted
your evaluation of your internal control over financial reporting.

 Response: We confirm for the Staff that under Section
404 of the Sarbanes-Oxley Act of 2002 (the “Sarbanes-Oxley Act”), MercadoLibre’s management, with the participation of our principal executive and principal financial officers, assess and evaluate the effectiveness of its internal
control over financial reporting (“ICFR”) as of the end of each fiscal year end and each fiscal quarter reports on its assessment (in the case of a fiscal year-end review) or discloses any change that has materially affected, or is
reasonably likely to materially affect, the Company’s internal controls over financial reporting (in the case of a fiscal quarter review). In making its assessment, MercadoLibre’s management uses the criteria established by the Committee
of Sponsoring Organizations of the Treadway Commission (“COSO”) framework and the SEC’s guidance on management’s assessment of ICFR. These criteria cover the following five areas: control environment; risk assessment; control
activities; information and communication; and monitoring. MercadoLibre’s ICFR is designed to provide reasonable assurance regarding the reliability of its financial reporting and the preparation of financial statements in accordance with U.S.
GAAP.

 Our business model, technological platform, business processes and most relevant controls are substantially managed in a centralized
way. Our accounting and reporting processes are performed and managed centrally for all countries through an ERP system and controls that are based substantially in our headquarters in Argentina. So, due to those common processes and the
centralization of financial reporting process, risks are usually common to all countries. Our approach to the evaluation of internal controls over financial reporting takes advantage of such centralization.

 Control Environment: At an entity-wide control level, we have established the “tone at the
top” by demonstrating a commitment to character, integrity, and high ethical values through our attitudes and actions. We adopted a Code of Business Conduct and Ethics for all employees regarding acceptable business practices, conflicts of
interest, and expected standards of ethical behavior, which was approved by the board of directors. All new employees are required to sign an acknowledgement indicating that they have read and understand the Code of Business Conduct and Ethics. The
signed acknowledgement is maintained by our human resources department in the respective employee file. In addition, our Audit Committee understands and actively exercises oversight responsibility over our financial reporting and the internal
control over financial reporting process. The Audit Committee meets at least once each quarter. Meetings are held in advance of each earnings release and filing of the quarterly and annual reports with the SEC. We retained individuals competent in
financial reporting and related oversight roles and we maintained accounting policies and treatments conforming to U.S. GAAP. In addition, for anti-fraud purposes, we also established whistle blowing procedures, which include a hotline monitored by
the Head of Internal Audit and Audit Committee to receive any complaints regarding potential fraud activities. The Audit Committee will delegate either internal or external resources to investigate complaints, if necessary, and review the report on
the investigation results.

 Risk Assessment: Our management is in charge of specifying the financial reporting objectives with
sufficient clarity and criteria to enable the identification of risks to reliable financial reporting. Financial reporting objectives include preparing financial statements for external purposes that are fairly presented in conformity with U.S.
GAAP. We have procedures in place to ensure timely and proper identification of business risks relevant to financial reporting objectives, including the risks of material misstatement in significant accounts and related potential errors in the
financial statements. Regular executive staff meetings are held to discuss current developments, risks and other factors relevant to the Company. These meetings generally occur on a quarterly basis and include our Chief Executive Officer (the
“CEO”), Chief Financial Officer (the “CFO”), Chief Operational Officer (“COO”), Country Managers (“CMs”) and Heads of each business area”. We conduct an entity wide risk assessment at least every year and
assessment results are analyzed in risk matrices by the Internal Audit Department (“IAD”) who facilitates the assessment and discussions of its assessment with the Audit Committee. The risk evaluation is