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May 5, 2020
Rachel Glaser
Chief Financial Officer
Etsy, Inc.
117 Adams Street
Brooklyn, NY 11201
Re:Etsy, Inc.
Form 10-K for Fiscal Year Ended December 31, 2019
Filed February 27, 2020
File No. 001-36911
Dear Ms. Glaser:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2019
Management's Discussion and Analysis of Results of Operations and Financial Condition
Non-GAAP Financial Measures, page 59
1.To avoid giving undue prominence to non-GAAP measures in your MD&A, please
consider moving this section so that it follows results of operations disclosure.
Comparison of Years Ended December 31, 2019 and 2018
Revenues, page 70
2.We note that on July 16, 2018, you increased your seller transaction fee from 3.5% to 5%,
and now apply it to the cost of shipping in addition to the cost of the item.  We also note
that GMS increased 26.5% in the year ended December 31, 2019.  Please revise to
quantify the impacts of changes in price and volume on your revenue.  Refer to Item
303(a)(3)(iii) of Regulation S-K.

 FirstName LastNameRachel Glaser
 Comapany NameEtsy, Inc.
 May 5, 2020 Page 2
 FirstName LastName
Rachel Glaser
Etsy, Inc.
May 5, 2020
Page 2
3.We note your disclosure of percentage changes in various components of marketplace and
services revenues, such as the 48.9% increase in transaction revenue and the 25.7%
increase in payments revenue.  The presentation of these percentages absent absolute
dollar amounts do not provide sufficient context for understanding the magnitude of the
changes on your results.  Please revise to provide absolute dollar amounts for material
components of your revenues to provide context for these percentage changes.  Refer to
Item 303(a)(3)(i) of Regulation S-K.
4.Your discussion and analysis of revenue begins with three paragraphs discussing metrics
such as gross merchandise sales (GMS) and active users in narrative form.  While we
understand you believe these metrics are important to understanding changes in revenue,
we believe your disclosure could be made more clear if these metrics were presented in
tabular form after revenue in the leading table in this section with the remaining narrative
text focused on explaining why revenue results (and the related metrics) changed.  We
also believe your narrative discussion should give prominence to the discussion of
revenue, with metrics being discussed secondarily to explain the changes in revenue as
applicable.
Notes to the Consolidated Financial Statements
Note 2 - Revenue, page 110
5.Please tell us whether this table is intended to provide disclosure of revenue on a
disaggregated basis pursuant to ASC 606-10-50-5.  We note from your disclosure in the
business section on page 2 and from your results of operations on page 70 that your
marketplace revenue includes separate amounts for transaction fees, listing fees, and
payment processing fees.  We also note that services revenue includes separate amounts
for advertising and shipping labels.  Finally, we note from your results of operations
disclosure that revenue growth from these various types of service fees increased at
varying rates, ranging from approximately 17% to over 51% (based on available
percentages disclosed).  Please tell us how you considered these different types of service
fees, some of which we note you adjust from time to time, when determining your
disaggregated revenue disclosure.  Refer to ASC 606-10-50-5 to 7 and 55-89 to 91.

 FirstName LastNameRachel Glaser
 Comapany NameEtsy, Inc.
 May 5, 2020 Page 3
 FirstName LastName
Rachel Glaser
Etsy, Inc.
May 5, 2020
Page 3
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Robert Shapiro, Senior Staff Accountant, at (202) 551-3273 or Lyn
Shenk, Accounting Branch Chief, at (202) 551-3380 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services