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SEC Comment Letter for PayPal Holdings, Inc. (PYPL) (CIK 0001633917) (PYPL) — Jul 2, 2019

PayPal Holdings, Inc. (PYPL) (CIK 0001633917)
Date: July 2, 2019 · CIK: 0001633917 · Accession: 0000000000-19-010564

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File numbers found in text: 001-36859

Date
July 1, 2019
Author
Not clearly detected
Form
UPLOAD
Company
PayPal Holdings, Inc. (PYPL) (CIK 0001633917)

Letter

July 1, 2019 Daniel H. Schulman President and Chief Executive Officer PayPal Holdings, Inc. 2211 North First Street San Jose, California 95131 Re:PayPal Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2018 Response Dated June 21, 2019 File No. 001-36859 Dear Mr. Schulman: We have reviewed your June 21, 2019 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our June 10, 2019 letter. Form 10-K for Fiscal Year Ended December 31, 2018 Risk Factors Our Business is subject to extensive government regulation.... Economic and Trade Sanctions, page 22 1.We note your response to comment number 1. As requested, please tell us the countries involved in the transactions that you self-reported to the Treasury Department’s Office of Foreign Assets Control.

FirstName LastNameDaniel H. Schulman Comapany NamePayPal Holdings, Inc. July 1, 2019 Page 2 FirstName LastName Daniel H. Schulman PayPal Holdings, Inc. July 1, 2019 Page 2

You may contact Sondra Snyder, Staff Accountant at (202) 551-3332 or Jennifer Thompson, Accounting Branch Chief at (202) 551-3737 with any questions. Sincerely, Division of Corporation Finance Office of Consumer Products

Show Raw Text
July 1, 2019
Daniel H. Schulman
President and Chief Executive Officer
PayPal Holdings, Inc.
2211 North First Street
San Jose, California 95131
Re:PayPal Holdings, Inc.
Form 10-K for Fiscal Year Ended December 31, 2018
Response Dated June 21, 2019
File No. 001-36859
Dear Mr. Schulman:
            We have reviewed your June 21, 2019 response to our comment letter and have the
following comment.  In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
            Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
June 10, 2019 letter.
Form 10-K for Fiscal Year Ended December 31, 2018
Risk Factors
Our Business is subject to extensive government regulation....
Economic and Trade Sanctions, page 22
1.We note your response to comment number 1.  As requested, please tell us the countries
involved in the transactions that you self-reported to the Treasury Department’s Office of
Foreign Assets Control.

 FirstName LastNameDaniel H. Schulman
 Comapany NamePayPal Holdings, Inc.
 July 1, 2019 Page 2
 FirstName LastName
Daniel H. Schulman
PayPal Holdings, Inc.
July 1, 2019
Page 2

            You may contact Sondra Snyder, Staff Accountant at (202) 551-3332 or Jennifer
Thompson, Accounting Branch Chief at (202) 551-3737 with any questions.
Sincerely,
Division of Corporation Finance
Office of Consumer Products