UPLOAD Filing
PayPal Holdings, Inc.
Date: July 10, 2025 · CIK: 0001633917 · Accession: 0000000000-25-007253
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-36859
Letter
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:
July 10, 2025
Jamie Miller Chief Financial Officer PayPal Holdings, Inc. 2211 North First Street San Jose, California 95131
We have reviewed your June 24, 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 June 11, 2025 letter.
Form 10-K for Fiscal Year Ended December 31, 2024 Notes to Consolidated Financial Statements Note 2 - Revenue Disaggregation of Revenue, page 76
1. We note your response to comment 2. In response to our comment asking whether your CODM regularly reviews transaction revenue by product, at the end of the first paragraph you state Revenue information...[provided to the CODM] may include product...information. Please directly tell us whether it does or does not include transaction revenue by product. In the first sentence of that paragraph, you state the "CODM...does not evaluate performance or make decisions on the basis of separate products. Please clarify whether this means solely on the basis of separate products or that the CODM does not review product revenue at all when evaluating the performance of your operating/reporting segment. July 10, 2025 Page 2
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
Show Raw Text
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> July 10, 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 June 24, 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 June 11, 2025 letter. Form 10-K for Fiscal Year Ended December 31, 2024 Notes to Consolidated Financial Statements Note 2 - Revenue Disaggregation of Revenue, page 76 1. We note your response to comment 2. In response to our comment asking whether your CODM regularly reviews transaction revenue by product, at the end of the first paragraph you state Revenue information...[provided to the CODM] may include product...information. Please directly tell us whether it does or does not include transaction revenue by product. In the first sentence of that paragraph, you state the "CODM...does not evaluate performance or make decisions on the basis of separate products. Please clarify whether this means solely on the basis of separate products or that the CODM does not review product revenue at all when evaluating the performance of your operating/reporting segment. July 10, 2025 Page 2 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 </TEXT> </DOCUMENT>