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 June 11, 2025

Jamie Miller
Chief Financial 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, 2024
 Filed February 4, 2025
 File No. 001-36859
Dear Jamie Miller:

 We have reviewed your May 16, 2025 response to our comment letter and
have the
following comment(s).

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our May 5,
2025 letter.

Form 10-K for Fiscal Year Ended December 31, 2024
MD&A
Net Revenue Analysis, page 36

1. Regarding your disclosure of total payment volume (TPV) metrics in
quarterly
 earnings presentations, you state in response to prior comment 1 TPV
does not
 directly relate to transaction revenues as TPV includes payment
transactions
 processed on our payments platform that do not earn revenue. However, in
MD&A
 you typically attribute changes in revenues to changes in TPV. Please
advise or revise
 your MD&A disclosure accordingly.
 June 11, 2025
Page 2

Notes to Consolidated Financial Statements
Note 2 - Revenue
Disaggregation of Revenue, page 76

2. We note your response to prior comment 1. Please tell us whether your
CODM
 regularly reviews transaction revenue by product when evaluating the
financial
 performance of your operating/reporting segment. If so, please tell us
how you
 considered ASC 606-10-55-90b. If not, tell us how the CODM makes
performance or
 resource allocation decisions within the segment.
3. In your response to prior comment 1 you state you may provide
product-specific
 revenue information when useful to explain consolidated results (e.g.,
the Xoom
 negative revenue trend in Q1 2024). In addition to the previously cited
example, we
 note the following:

 In your Q1 2025 earnings release you cite progress across branded
checkout, PSP,
 omnichannel, and Venmo as contributing to your results,
 In prepared remarks during the related earnings call, you cite 20%
revenue growth
 for Venmo,
 On slide 8 of the earnings presentation, you cite growth in
branded checkout and
 Venmo offsetting lower Braintree revenue,
 In your Q1 2025 Form 10-Q, you quantify the change in Braintree
revenue (-
 $200m) and Venmo/PayPal revenue (+$170m), and
 In your 2024 Form 10-K, you quantify the change in Braintree
revenue ($+1.3b),
 core PayPal (+$0.5b), and Venmo (+$0.2b).

 While you have not provided this information for all products on a
consistent basis
 nor provided actual revenue amounts, you have nonetheless disclosed
transaction
 product-specific revenue information outside the financial statements
and determined
 it useful in explaining results, which under ASC 606-10-55-90a is a
factor that must
 be considered when selecting disaggregation categories. Please advise.

 Regarding the above referenced Xoom negative revenue trend in Q1 2024
and the
 decline in Braintree revenue and increase in Venmo/PayPal revenue in Q1
2025,
 please explain to us why you believe these are not examples of
transaction revenue
 products being differently affected by economic factors and, therefore,
subject to
 different uncertainty than other products comprising transaction
revenue. Refer to
 ASC 606-10-50-5.
 June 11, 2025
Page 3

 Please contact Amy Geddes at 202-551-3304 or Lyn Shenk at 202-551-3380
if you
have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of Corporation
Finance
 Office of Trade &
Services
cc: Brian Yamasaki
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