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    Manuel Garciadiaz

    manuel.garciadiaz@davispolk.com

    Davis Polk & Wardwell llp

    450 Lexington Avenue

    New York, NY 10017

    davispolk.com

    January 6, 2023

    Re:
    DLocal Limited

Form 20-F for the Fiscal Year Ended December 31, 2021

Filed May 2, 2022

File No. 001-40451S

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

Attn: Linda Cvrkel

Rufus Decker

Ladies and Gentlemen:

On behalf of our client, DLocal Limited (the “Company”),
this letter sets forth the Company’s responses to the comments provided by the staff (the “Staff”) of the Division
of Corporation Finance of the U.S. Securities and Exchange Commission (the “Commission”) in its letter dated December
7, 2022 (the “Comment Letter”). On May 2, 2022, the Company publicly filed an Annual Report on Form 20-F for the fiscal
year ended December 31, 2021 (the “Annual Report”) via the Commission’s Electronic Data Gathering, Analysis and
Retrieval system (“EDGAR”) to the Commission.

For the convenience of the Staff, each comment from the Comment Letter
is restated in italics prior to the Company’s response to such comment. All references to page numbers and captions (other than
those in the Staff’s comments) correspond to pages in the filed version of the Annual Report. We have included as exhibits to this
letter the proposed changes that the Company expects to include in future filings.

Item 4. Information on the Company

B. Business Overview, page 61

1.       You disclose the metric
"net revenue retention" or "NRR" on page 64 and elsewhere in your filing. Please revise your presentation of this
metric to provide a clear definition of the metric and how it is calculated, a statement indicating why the metric is useful to investors,
and a statement indicating how management uses the metric in managing or monitoring your performance. Refer to SEC Release No. 33-10751.

Response: The Company respectfully acknowledges the Staff’s
comment. The Company advises the Staff that it has included a definition of “net revenue retention” or “NRR” in
certain other filings with the SEC, such as the Company’s quarterly earnings releases furnished on Form 6-K, but acknowledges that
no such definition was included in the Annual Report. The Company advises the Staff that in future filings (including in the Company’s
annual report on Form 20-F for the year ended December 31, 2022) the Company intends to include the specified information. The Company
expects to include such information in the

section titled “Presentation of Financial and Other Information”
in its next annual report on Form 20-F. The Company’s disclosure will be substantially consistent with the disclosures included
in Exhibit A hereto.

C. Organizational Structure

Our Corporate Reorganization, page 87

2.       The number of your outstanding
Class A and Class B shares as disclosed on pages 87 and 120 are inconsistent with the number disclosed on page F-36 of your financial
statements in Note 13. Please reconcile and revise these disclosures.

Response: The Company respectfully acknowledges the Staff’s
comment and advises the Staff that the Company reconciled the number of its outstanding shares and information about the total amount
of shares and share capital is correct in all respective sections of the Company’s Annual Report. Nevertheless, the Company acknowledges
that Note 13 to its Consolidated Financial Statements for the years ending December 31, 2021, 2020 and 2019 did not consider the one-to-one
conversion of Class B common shares to Class A common shares that occurred in October 2021. The Company advises the Staff that a materiality
assessment was performed, considering both quantitative and qualitative factors, and concluded that such inconsistency is not material
mainly due to the fact that, as both classes have identical economic rights, only the total number of shares is used to calculate the
Earnings Per Share, and no other metrics relevant for the users of the Financial Statements is affected. The Company intends to revise
its disclosure in future filings substantially consistent with the presentation set forth in Exhibit B.

Item 5. Operating and Financial Review and Prospects

Key Business Metrics, page 88

3.       When you present Adjusted
EBITDA and/or Adjusted EBITDA margin here and elsewhere in your filings, please also present your IFRS profit and profit margin with equal
or greater prominence. Refer to Item 10(e)(1)(i)(A) of Regulation S-K.

Response: The Company respectfully acknowledges the Staff’s
comment and advises the Staff that Adjusted EBITDA and Adjusted EBITDA margin are treated by the Company as IFRS measures, as explained
in section “Presentation of Financial and Other Information – Special Note Regarding Adjusted EBITDA and Adjusted EBITDA Margin”
of the body of the Company’s Annual Report.

Nevertheless, in response to the Staff’s comment, the Company
intends to present in its future filings of the annual report on Form 20-F profit for the year and profit margin with equal prominence
to the presentation of Adjusted EBITDA and/or Adjusted EBITDA margin. The Company’s disclosure will be substantially consistent
with the disclosures included in Exhibit C hereto.

Consolidated Financial Statements

5. Segment Reporting, page F-28

4.       Revenues arise from operations
in more than twenty countries where merchant customers are based. To the extent that revenues from external customers attributed to an
individual foreign country are material, please separately disclose those revenues. In addition, also disclose non-current assets located
in your country of domicile and in all other foreign countries in total. If assets in an individual country are material, those assets
should also be separately disclosed. Refer to paragraphs 33(a) and (b) of IFRS 8.

Response: The Company respectfully acknowledges the Staff’s
comment and advises the Staff that an assessment of the applicable required information of IFRS 8 paragraph 33 was performed when preparing

    January 6, 2023 2

the Company’s annual consolidated financial statements and information
considered relevant about geographies was included in Note 5. Segment Reporting. Such disclosures are consistent with the information
reviewed by the Company's Chief Operating Decision Maker who reviews the performance of the Company's business with information by merchant
and region (Latin America and Asia and Africa). The Company has global agreements with international merchants that choose to process
payments with the Company in the countries of their preference. The Company’s commercial teams are internally organized by merchant
and not by country, and the Company does not set revenue or other key metrics objectives by country. The Company offers all the emerging
countries where it operates to their merchants indistinctly and the country revenue mix is a result of the strategy of the merchants.

Nevertheless, in future filings of the annual report on Form 20-F, the
Company intends to present additional information related to revenues from external customers attributed to foreign countries exceeding
10% of consolidated Revenues during the last year to enhance the disclosure on the Company’s geographical diversification. Revenues
are attributed to these countries based on the country where payments from/to merchant customers are processed. The Company also advises
the Staff that it does not have any material non-current asset located in the country of domicile of the Company and material non-current
assets in other foreign countries are detailed in Note 20 to the annual consolidated financial statements. The Company’s disclosure
in future filings will be substantially consistent with the disclosures included in Exhibit D hereto (which is expected to include the revenue amount per each country specified in such Exhibit).

14. Cash and Cash Equivalents, page F-38

5.       Merchant client funds
are included in cash and cash equivalents on your consolidated balance sheet and statements of cash flows. You state that these amounts
correspond to freely available funds collected from merchant customers that can be invested in secure, liquid low-risk assets, until they
are transferred to merchants in accordance with agreed conditions with them. Please explain the terms and conditions under which these
funds are required to be transferred to merchants including the related timeframe over which the transfers must occur. Additionally, since
it appears that you are holding these funds on behalf of your merchant clients, please explain why you believe it is appropriate to include
them in cash and cash equivalents in your consolidated financial statements. Refer to paragraphs 6 and 7 of IAS 7.

Response: The Company respectfully acknowledges the Staff’s
comment and advises the Staff that merchant client funds are received and held in separate bank accounts that are established for managing
merchant client funds. Merchant client funds are held in the emerging countries in which the Company operates and at the Company’s
operating companies in Malta and the United Kingdom. The accounts into which the Company receives and holds merchant client funds also
contain amounts representing fees attributable to the Company which are reconciled and transferred from such accounts to the Company’s
own accounts on a periodical basis.

The Company negotiates and agrees the settlement periods in which the
merchant funds are paid considering, among other things, the period of time it takes the Company to collect the funds from the users,
which is based on the payment methods of each country. This settlement period could range from one day to 30 days and the payment to the
merchant is not contractually restricted to the collection from the payments methods.

As previously mentioned, merchant client funds are received and held
in separate bank accounts that are established for managing merchant client funds. The legal ownership of those bank accounts is of dLocal
and its subsidiaries and such accounts can be accessed by the Company on demand. Additionally, merchant client funds may be invested in
short-term highly liquid investments that are readily convertible to known amounts of cash and are subject to an insignificant risk of
changes in value. The Company

    January 6, 2023 3

considered paragraphs 6 and 7 of IAS 7 and determined merchant customer
assets should be presented in cash and equivalents when considering the following:

 · dLocal and its subsidiaries are the legal owners of bank accounts established to hold merchant customer funds;

 · dLocal and its subsidiaries may access such funds on demand (i.e., the Company’s ability to access such accounts is unrestricted);
and

 · The Company may hold merchant customer funds in cash or short-term, low risk, highly liquid assets that are subject to an insignificant
market risk.

Consequently, it is appropriate to disclose merchant client funds
in cash and cash equivalents in our consolidated financial statements, in accordance with the definitions and requirements of IAS 7 paragraphs
6 and 7.

The Company will include the additional disclosures proposed above in
its future filings of its annual report on Form 20-F.

Please do not hesitate to contact me at 212-450-6095 or manuel.garciadiaz@davispolk.com
or Drew Glover at 650 752 2052 or drew.glover@davispolk.com if you have any questions regarding the foregoing or if I can provide any
additional information.

Very truly yours,

/s/ Manuel Garciadiaz

Manuel Garciadiaz

cc: 	Diego Cabrera Canay, Chief Financial Officer, DLocal Limited

    January 6, 2023 4

Exhibit A

Set forth below are the definitions of the “net revenue retention
rate” or “NRR” metric, how NRR is calculated and a statement indicating why the metric is useful to investors and how
management uses the metric in managing or monitoring our performance, which we expect to include in future filings under the caption “Presentation
of Financial and Other Information.”

Net Retention Rate or “NRR”

Net Revenue Retention Rate or “NRR” is a U.S. dollar-based
measure of retention and growth of our merchants. We calculate the NRR for a period or year by dividing the Current Period/Year Revenue
by the Prior Period/Year Revenue. The Prior Period/Year Revenue is the revenue billed by us to all our customers in the prior period.
The Current Period/Year Revenue is the revenue billed by us in the current period to the same customers included in the Prior Period/Year
Revenue. Current Period/Year Revenue includes revenues from any upselling and cross-selling across products, geographies, and payment
methods to such merchant customers, and is net of any contractions or attrition, in respect of such merchant customers, and excludes revenue
from new customers on-boarded in the preceding twelve months.

As most of dLocal revenues come from existing merchants, the NRR rate
is a key metric used by management, and we believe useful for investors in order to assess retention of existing customers and growth
in revenues from our existing customer base.

Exhibit B

13.       Capital Management

(a)       Share capital and capital
reserve

Authorized shares, as well as issued and fully paid up shares, are presented
below:

    2021
    2020

    Amount
    USD
    Amount
    USD

    Authorized Shares of USD 0.002
 USD each

    Class A common shares
      1,000,000,000
      2,000
      —
      —

    Class B common shares
      250,000,000
      500
      —
      —

    Undesignated shares
      250,000,000
      500
      —
      —

    Authorized Shares of USD 1.1211
 USD each

    Common shares
      —
      —
      618,363
      693

      1,500,000,000
      3,000
      618,363
      693

    Issued and Fully Paid Up Shares of USD 0.002 each

    Class A Common Shares
      160,974,249
      322
      268,598,000
      602

    Class B Common Shares
      134,054,192
      268
      —
      —

      295,028,441
      590
      268,598,000
      602

    Share Capital evolution

    Share Capital as at January 1
      268,598,000
      602
      268,598,000
      602

    Issue of common shares at
 USD 1.1211
      19,906,000
      45
      —
      —

    Par value change
      —
      (70 )
      —
      —

    Issue of common shares at the IPO
      4,411,765
      9
      —
      —

    Warrant exercise
      2,112,676
      4
      —
      —

    Share capital as of December 31
      295,028,441
      590
      268,598,000
      602

Exhibit C

Item 5. Operating and Financial Review and Prospects

Key Business Metrics

We review the following key metrics
to evaluate our business, measure our performance, identify trends affecting our business, formulate business plans and make strategic
decisions:

    2021
    2020
    2019

    TPV(1)
      6,049,044
      2,064,789
      1,287,713

    Revenues
      244,120
      104,143
      55,289

    Adjusted EBITDA(2)
      99,157
      41,931
      20,070

    Adjusted EBITDA Margin(3)
      40.6 %
      40.3 %
      36.3 %

    Profit for the year
      77,853
      28,187
      15,602

    Profit Margin(4)
      31.9 %
      27.1 %
      28.2 %

 (1) For information on how we define TPV, see “Presentation of Financial and Other Information-TPV.”

 (2) For information on how we define Adjusted EBITDA, see “Presentation of Financial and Other Information-Special Note Regarding
Non-GAAP Financial Measures.”

 (3) For information on how we define Adjusted EBITDA Margin, see “Presentation of Financial and Other Information-Special Note Regarding
Non-GAAP Financial Measures.”

 (4) Profit Margin results from dividing Revenues by Profit for the year reported in our Consolidated Statements of Comprehensive Income
for the years-ended December 31, 2021, 2020 and 2019.

We have included below a reconcili