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Response Letter

 March 24, 2015

Via EDGAR and Overnight Delivery

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street,
N.E.

 Washington, D.C. 20549-3720

 Attention: Jennifer Lopez

Re:
Etsy, Inc.

Registration Statement on Form S-1

Filed March 4, 2015

File No. 333-202497

 Dear Ms. Lopez:

On behalf of Etsy, Inc. (the “Company”), we submit this letter in response to comments from the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter dated March 19, 2015 relating to the Registration Statement on Form S-1 filed March 4, 2015 (the
“Registration Statement”).

 For the convenience of the Staff, we are providing to the Staff by overnight delivery copies
of this letter.

 In this letter, we have recited the comments from the Staff in italicized, bold type and have followed each comment with
the Company’s response. Except as otherwise specifically indicated, page references herein correspond to the Registration Statement.

 Gatefold of
Prospectus

1.
We note the fifth page of the artwork provided. Please provide additional context so a reader not familiar with your industry can understand the information included in your artwork. In this regard, we note the
following:

•

Your references to “several converging macroeconomic” trends and how each of them will “benefit millions of people” under the section titled “Our Opportunity.”

•

Your references to $280B and $695B under the section titled “Trends in our Favor.” Please clarify what these amounts represent (e.g. revenues).

 U.S. Securities and Exchange Commission

March 24, 2015

  Page
 2

•

Your depiction titled “Manufacturing” under the “Trends in our Favor” section. Please describe how your reference to “19 or fewer employees” relates to your reference to
“responsible manufacturers.”

 Please note that this comment is also applicable the Business section.

 In response to the Staff’s comment, the Company has revised the fifth page of the artwork, in the form attached hereto as
Exhibit A. As discussed with the Staff, the Company will include the revised artwork in an amendment to the Registration Statement expected to be filed the afternoon of March 31, 2015, prior to the expected launch of its roadshow
the morning of April 1, 2015. The Company will make corresponding changes to the graphics on page 100.

 With respect to the second
bullet in the Staff’s comments, the Company supplementally notes that the references to $280B and $695B under the section titled “Trends in our Favor” refer to global online and mobile retail sales (not revenue) as outlined in the
Euromonitor report referenced in the graphic and in the Registration Statement. Because the report uses the words “Global Online Retail Market,” the Company is limited in the additional context it can provide in the Registration Statement
but believes that the revised graphic assists the reader to see that such references refer to market data and not Etsy-specific data.

 Executive
Compensation

 Annual Cash Incentive Bonuses, page 128

2.
We note your disclosure that in 2014 payouts were made under the annual cash incentive plan. Please provide the material terms of the non-equity incentive plan award made to the named executive officers and a
general description of the formula or criteria applied in determining the amounts payable. Refer to Item 402(o)(5) of Regulation S-K.

In response to the Staff’s comment, the Company intends to revise the disclosure included on page 128 regarding the 2014 payouts under the
annual cash incentive plan, and file such disclosure in the amendment to the Registration Statement referred to above, as follows:

Annual Cash Incentive Bonuses

Prior to 2014, we did not have a regular annual cash incentive bonus program for our executive officers. In 2014, our compensation committee
approved an annual cash incentive plan in which certain of our employees, including our named executive officers, participated.

 In
general, funding for all bonus payouts is based upon our achievement of company-wide performance goals. The actual individual bonus payouts may be increased or decreased based upon the compensation committee’s consideration of each
participant’s performance during the year. For 2014, the bonus plan was funded based upon the satisfaction of company-wide Adjusted EBITDA margin and net revenue goals. Because we exceeded our Adjusted EBITDA margin goal, the bonus plan was
funded at 110% of target. The target bonuses for our named executive officers for 2014, as a percentage of base salary, were 75% for Mr. Dickerson, 59% for Ms. Salen and 50% for Mr. Breslow, and the actual bonus payouts were 110% of target for
Mr. Dickerson and 121% of target for Ms. Salen and Mr. Breslow, in light of both company performance against the Adjusted EBITDA margin and net revenue goals and their respective individual performance during 2014. The individual
bonus payments were approved by our compensation committee and our board of directors with input from Mr. Dickerson for the other named executive officers.

* * * * *

 U.S. Securities and Exchange Commission

March 24, 2015

  Page
 3

 Please contact me at (650) 321-2400 or, in my absence, Kenneth R. McVay, at
(212) 730-8133, if you have any questions about this confidential submission.

Sincerely yours,

 /s/ Richard C. Blake

Richard C. Blake

Gunderson Dettmer Stough Villeneuve Franklin & Hachigian, LLP

cc:
Chad Dickerson

 Kristina Salen

Jordan J. Breslow, Esq.

Etsy, Inc.

 Kenneth R.
McVay, Esq.

 Greg S. Volkmar, Esq.

Gunderson Dettmer Stough Villeneuve Franklin & Hachigian, LLP

Sarah K. Solum, Esq.

 Davis
Polk & Wardwell LLP

 Exhibit A