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August 9, 2022
Damian Scokin
Chief Executive Officer
Despegar.com, Corp.
Juana Manso 1069, Floor 5
Ciudad Autónoma de Buenos Aires, Argentina C1107CBU
Re:Despegar.com, Corp.
Form 20-F for Fiscal Year Ended December 31, 2021
Filed April 29, 2022
File No. 001-38209
Dear Mr. Scokin:
            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 20-F for the Year Ended December 31, 2021
Item 5. Operating and Financial Review and Prospects, page 70
1.You disclose that one of the significant estimates underlying your financial statements is
the allowance for expected credit losses.  You acquired a majority equity stake in Koin in
August 2020 and acquired the remaining equity stake in January 2022.  Koin is a financial
services company focused on the buy-now pay-later business in Brazil that you plan to
grow and expand into other markets in Latin America.  Please discuss and analyze the
results of operations of your financial services business.  Also discuss known material
trends and uncertainties that will have, or are reasonably likely to have, a material impact
on your income, expenses or cash flows.  For example, the buy-now-pay-later business
model could result in high past due amounts and loan defaults for borrowers with limited
access to traditional financial services.  Refer to Item 303(b)(2)(ii) of Regulation S-K and
to the Commission's Guidance Regarding Management's Discussion and Analysis of
Financial Condition and Results of Operations, SEC Release No. 33-8350.

 FirstName LastNameDamian Scokin
 Comapany NameDespegar.com, Corp.
 August 9, 2022 Page 2
 FirstName LastName
Damian Scokin
Despegar.com, Corp.
August 9, 2022
Page 2

Financial Statements
Notes to the Consolidated Financial Statements
3. Summary of significant accounting policies
Revenue Recognition, page F-17
2.You recognize revenue when the booking is completed, paid and confirmed, less a reserve
for cancellations based on historical experience.  You had an allowance for cancellations
of $19.2 million at December 31, 2021.  Actual deductions for cancellations were $0 in
2019, $302 in 2020 and $1,982 in 2021.  Please tell us the factors you considered in
determining the allowance for cancellations of $19.2 million at December 31, 2021 given
your much lower aggregate amount of cancellations over the last two years of a global
pandemic.
            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 Yolanda Guobadia, Staff Accountant, at (202) 551-3562 or Gus
Rodriguez, Accounting Branch Chief, at (202) 551-3752 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation