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UPLOAD Filing

StubHub Holdings, Inc.
Date: Sept. 3, 2025 · CIK: 0001337634 · Accession: 0000000000-25-009481

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File numbers found in text: 333-286000

Date
September 3, 2025
Author
Division of
Form
UPLOAD
Company
StubHub Holdings, Inc.

Letter

Re: StubHub Holdings, Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed August 26, 2025 File No. 333-286000 Dear Eric H. Baker:

September 3, 2025

Eric H. Baker Chief Executive Officer StubHub Holdings, Inc. 175 Greenwich Street, 59th Floor New York, New York 10007

We have reviewed your amended registration statement and have the following comment.

Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe the comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our May 16, 2025 letter.

Amendment No. 2 to Registration Statement on Form S-1 Comparison of the Six Months Ended June 30, 2025 and 2024 Revenue, page 87

1. Please quantify and further explain the cause of the increase in refunded fees as a result of higher event cancellations. Refer to Item 303(b) of Regulation S-K. September 3, 2025 Page 2

Please contact Joel Parker at 202-551-3651 if you have questions regarding comments on the financial statements and related matters. Please contact Alyssa Wall at 202-551-8106 or Erin Jaskot at 202-551-3442 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
cc: Adam J. Gelardi

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 3, 2025

Eric H. Baker
Chief Executive Officer
StubHub Holdings, Inc.
175 Greenwich Street, 59th Floor
New York, New York 10007

 Re: StubHub Holdings, Inc.
 Amendment No. 2 to Registration Statement on Form S-1
 Filed August 26, 2025
 File No. 333-286000
Dear Eric H. Baker:

 We have reviewed your amended registration statement and have the
following
comment.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe the comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our May 16, 2025
letter.

Amendment No. 2 to Registration Statement on Form S-1
Comparison of the Six Months Ended June 30, 2025 and 2024
Revenue, page 87

1. Please quantify and further explain the cause of the increase in
refunded fees as a
 result of higher event cancellations. Refer to Item 303(b) of Regulation
S-K.
 September 3, 2025
Page 2

 Please contact Joel Parker at 202-551-3651 if you have questions
regarding comments
on the financial statements and related matters. Please contact Alyssa Wall at
202-551-8106
or Erin Jaskot at 202-551-3442 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Adam J. Gelardi
</TEXT>
</DOCUMENT>