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CORRESP
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CORRESP

 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

May 23, 2013

 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, 2012

Filed February 28, 2013

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, 2012 filed on February 28, 2013 (File No. 001-33647), contained in your comment letter dated May 9, 2013 (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, 2012

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

Critical Accounting Policies and Estimates

 Foreign Currency Translation, page 49

1.
We note that no dividends were declared by your Venezuelan subsidiaries during the year ended December 31, 2012. Tell us if you were restricted from making
distributions from these subsidiaries during 2012 as a result of the SITME regulations in place. Also, tell us whether you expect the elimination of the SITME on February 9, 2013 and the implementation of the SICAD on March 19, 2013 to
restrict your Venezuelan subsidiaries’ ability to make dividend distributions in the future. While we note your discussion of volume restrictions imposed by the SITME, it is unclear to what extent these restrictions impacted your ability to
make distributions. Please tell us what consideration you gave to disclosing these factors. Also, to the extent that you believe these restrictions will not have a material adverse effect on your overall business as you currently indicate on page
51, tell us your consideration to further enhance your disclosure to explain such conclusions.

 Response: In
response to the Staff’s comment, we respectfully advise the Staff that no legal prohibition exist in Venezuela, in connection with dividends distribution or with the remittance of dividends abroad and that the SITME regulations did not prevent
our Venezuelan subsidiaries from declaring and paying dividends in 2012. We further advise the Staff that the acquisition of U.S. dollars for dividends remittance abroad in foreign currency was not within the scope of SITME or the SICAD, but falls
within the scope of CADIVI, as disclosed on pages 25 and 77 to our Form 10-K for fiscal year ended December 31, 2012 filed on February 28, 2013 (Form 10-K). As discussed in our Form 10-K, SITME imposed limits to the foreign exchange
trading activity relating to the acquisition of U.S. dollars to import goods, services or capital inputs for entities domiciled in Venezuela.

Foreign currency exchange regulations have continued to be subject to changes by the Venezuelan government. In that regard, we have included additional
information about subsequent developments in our Form 10-Q as of March 31, 2013. We will continue assessing the effects of additional developments for further disclosure in our future filings.

In response to the Staff’s request, we advise the Staff that we continue to believe that the current restrictions to acquire U.S. dollars will not
have a material adverse effect on our overall business plan in the long run, considering that our Venezuelan operations are not dependent on third parties’ imported goods or services. Moreover, because our Venezuelan business has demonstrated
consistent growth that we believe is sustainable for the near future, our current plans contemplate continued reinvestment in our Venezuelan businesses with the proceeds of our business in that country.

Finally, given the current availability of cash from our various geographic segments, we do not expect that the current Venezuelan foreign exchange
situation will affect our ability to distribute cash dividends from MercadoLibre, Inc. to its stockholders as planned.

2.
We note the risk factor disclosure on page 27 of your December 31, 2011 Form 10-K where you state, if current volume restrictions on foreign exchange imposed by
the government worsen significantly or new regulations are implemented, which impact your ability to settle transactions at either the official rates or SITME rate, you could be required to deconsolidate your Venezuelan operations for accounting
purposes. Please tell us whether deconsolidation of your Venezuelan subsidiary is still a potential risk to the company and if so, tell us why you have not included a discussion of this risk in your current Form 10-K. Also, tell us what impact the
elimination of the SITME in February 2013 and the creation of the SICAD in March 2013 will have on the accounting for your Venezuelan operations. As part of your response, please tell us how your current inability to access the auction process by
which acquisition of foreign currencies will be made under the new system impacts the accounting for your Venezuelan operations.

 Response: We advise the staff that while we continue to believe that we are subject to the risk that “Local currencies used in the conduct of our business are subject to depreciation,
volatility and exchange controls.”, as we described in our Form 10-K, because of the manner in which foreign exchange regulations have been implemented by the Venezuelan government as of the date of our Form 10-K for the year ended
December 31, 2012, it did not imply the deconsolidation risk to be a material risk at the time of that filing. Accordingly, we determined that it was not necessary to include a risk factor to discuss the potential risk of deconsolidation.
Through the SITME mechanism, we have been able to obtain U.S. dollars for payments of intercompany services, and those restrictions have not altered our growth plans in Venezuela.

 In regards to the impact of the elimination of the SITME on the accounting of our Venezuelan operations, since exchange rate information resulting from auctions completed through the new mechanism SICAD
is not publicly available, there is only one official and legal exchange rate in Venezuela. That exchange rate was set at 6.3 Bolivares Fuertes per U.S. dollar on February 9, 2013 by the Venezuelan government. As a result, from that date, our
net monetary assets have been re-measured using the official exchange rate.

 Finally, we advise the Staff that we expect the government to
implement a mechanism that will allow us to obtain (either SICAD or any other mechanism implemented by the government) U.S. dollars for the payment of foreign services by our Venezuelan subsidiaries. If the corresponding government body begins to
make publicly available the exchange rate, resulting from SICAD or any other equivalent mechanism, and we are able to access that mechanism to obtain U.S. dollars for our operations, we will assess using those published exchange rates for
re-measurement purposes based on the actual facts and circumstances at that time.

 Results of Operations

 Year Ended December 31, 2012 compared to year ended December 31, 2012, Page 61

3.
We note your disclosure of the percentage increases in gross merchandise volume, financing and off-platform payments, and classified and add sales revenues. Please
tell us what consideration you gave to quantifying the dollar amount for each of these revenue streams and how changes in such amounts and the related metrics impacted your revenues. We refer you to Item 303(a)(3)(iii) of Regulation S-K and
Section III.D of SEC Release No. 33-6835.

 Response: In response to the Staff’s comment, we advise
that we considered the rules prescribed by Item 303(a)(3)(iii) of Regulation S-K and Section III.D of SEC Release No. 33-6835, when preparing our disclosures relating to material changes in our net revenues. In preparing this disclosure,
we considered those metrics that we believe are most relevant and necessary to allow readers to understand our financial condition, changes in financial condition and results of operations and have included those metrics in the “Management
Discussion and Analysis of Financial Condition and Results of Operations” section of our Form 10-K for the fiscal year ended December 31, 2012. We also advise the Staff that we have historically quantified gross merchandise volume on a
consolidated basis in our prior periodic reports. That said, we acknowledge the Staff’s comment and we advise that in future filings we will quantify the dollar amount of our Marketplace and Non-Marketplace Services revenues in the format set
forth below and will expand our discussions relating to changes in those service categories and their impact on our net revenues. We further advise the Staff that we believe disclosure of revenues for our Marketplace and Non-Marketplace Services is
the most appropriate format for providing this disclosure (as compared to providing quantitative disclosures for each individual service category that make up these revenue streams, such as Ad Sales, Real Estate, Motors, Off Platform Payment fees,
Financing Fees, etc.), as the categories are comprised generally of a number of service categories (or types of services) that are ancillary to our Marketplace Services and represent, on an individual-basis, a small percentage of the Company’s
net revenues.

 The breakdown of our consolidated net revenues by each of our Marketplace and Non-Marketplace Services categories for the years
ended December 31, 2012, 2011 and 2010 is as follows:

 Revenue streams

2012

2011

2010

 Marketplace

261,997,020

217,932,814

132,742,374

 Non-Marketplace Services (*)

111,604,474

80,998,811

83,973,339

 Total

373,601,494

298,931,625

216,715,713

(*)
 Includes Ad Sales,
Real Estate, Motors, Financing Fees, Off-platform Payment Fees, etc.

4.
We note your disclosure of growth in net revenues measured in local currencies. Please tell us what consideration you gave to also disclosing changes in expenses and
segment revenues measured in local currencies.

 Response: In response to the Staff’s comment, we advise that we have considered
disclosing such changes as noted in the comment but determined that by providing the year-over-year consolidated net revenue growth in local currencies, readers of our Form 10-K would have an understanding of the foreign currency effects on our net
revenues. However, we acknowledge the Staff’s comment and advise that in future filings we will disclose changes in segment revenues measured in local currencies. Finally, we consider that providing revenue growth in local currencies will be
sufficient information for readers of our Form 10-K to calculate expense growth measured in local currencies since they typically follow the same change pattern.

5.
Please tell us what consideration you gave to disclosing explanations for changes in your segment net revenues and direct costs. We refer you to Item 303(a) of
Regulation S-K and Section III.F.1 of SEC Release No. 33-6835.

 Response: In response to the Staff’s
comment, we advise that we considered the rules prescribed by Item 303(a) of Regulation S-K and Section III.F.1 of SEC Release No. 33-6835 when preparing disclosures relating to material changes in our segment net revenues and direct costs
and determined that the disclosures included in the “Management’s Discussion and Analysis of Financial Condition and Results of Operations” section of our Form 10-K provide the information that we believe is necessary to an
understanding of our financial condition, changes in our financial condition and results of operations. Particularly, it is our view that an explanation of material changes on a consolidated basis provides a reader with the most relevant information
regarding our business and provides the reader with an understanding of the business as a whole. However, we acknowledge the Staff’s comment, and considering that we are involved in a continuously evolving business, in future filings we will
provide additional information with respect to changes in our segment net revenues and direct costs.

6.
Also, please tell us why you do not include a discussion of your key metrics (i.e., gross merchandise volume, successful items sold and payment volume) and their
impact on the related geographic/segmental revenues. In your response, please address whether there are any material geographic differences or trends. See Item 303(a) of Regulation S-K, and for guidance, refer to Sections I.B and III.B of SEC
Release No. 33-8350.

 Response: In response to the Staff’s comment, we advise that we have
considered the rules prescribed by Item 303(a) of Regulation S-K, and for guidance, refer to Sections I.B and III.B of SEC Release No. 33-8350, when preparing disclosures relating to material changes to our net revenues. As discussed in
our response above to the Staff’s comment #5, it is our view that an explanation of material changes on a consolidated basis provides a reader with the most relevant information regarding our business and provides the reader with an
understanding of the business as a whole. However, we acknowledge the Staff’s comment, and considering that we are involved in a continuously evolving business, we advise the Staff that, in future fillings, we will quantify our revenues
generated by Marketplace and Non-Marketplace Services for each of our geographic segments (similar to the format provided in our response above to the Staff’s comment #3) and will expand our discussions relating to changes in those service
categories and their impact on our net revenues for each of our geographic segments. In addition, we advise the Staff that no significant changes or trends in key metrics occurred in relation to each of our geographic/segmental revenues that we
deemed necessary for further disclosure under Item 303(a).

 Liquidity and Capital Resources, page 72

7.
We note from your response to comment 4 in your March 29, 2011 letter and comment 2 in your July 13, 2012 letter that you would disclose the amount of cash
and investments held by foreign subsidiaries as well as the percentage of your consolidated cash and investments that are held outside the U.S. However, it does not appear that you have disclosed this information. Please advise.

 Response: In response to the Staff’s comment, we respectfully advise the Staff that although we included the
percentage of our consolidated cash and investments that are held outside the U.S. in Note 2 – Summary of significant accounting policies – Principles of consolidation, on page 10 to our consolidated financial statements for the year ended
December 31, 2012 included in our Form 10-K for fiscal year ended December 31, 2012, we have not included in our “Liquidity and Capital resources” section the amount of cash and investments held by foreign subsidiaries. We will
include cash and investments held by foreign subsidiaries as well as consolidated cash and investments that are held outside the U.S., in that section in future filings. Please, note that we have included such information in the “Liquidity and
Capital Resources” section of our Form 10-Q for the periods ended March 31, June 30 and September 30, 2012 and for the period ended March 31, 2013.

 We advise the Staff that as of December 31, 2012, cash and investments held by foreign subsidiaries amounted to $2