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 May 30, 2025

Mart n de los Santos
Executive Vice President and Chief Financial Officer
MercadoLibre, Inc.
WTC Free Zone
Dr. Luis Bonavita 1294, Of. 1733, Tower II
Montevideo, Uruguay, 11300

 Re: MercadoLibre, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
 File No. 001-33647
Dear Mart n de los Santos:

 We have completed our review of your filing. 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.

 Sincerely,

 Division of Corporation
Finance
 Office of Trade &
Services
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 Document MERCADOLIBRE, INC. WTC FREE ZONE DR. LUIS BONAVITA 1294, OF. 1733 TOWER II MONTEVIDEO URUGUAY 11300 TEL +598 — 2927 — 2770 MARTIN DE LOS SANTOS EMAIL: martin.delossantos@mercadolibre.com May 23, 2025 Via EDGAR Correspondence United States Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services Attention: Mr. Scott Stringer and Mr. Adam Phippen Washington, D.C. 20549-4561 Re: MercadoLibre, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 Filed February 21, 2025 File No. 001-33647 Dear Mr. Stringer and Mr. Phippen: MercadoLibre, Inc., a Delaware corporation (the “Company,” “MercadoLibre,” “we” or “us”), responds below to the comment of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”), with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2024 (the “2024 Form 10-K”) filed on February 21, 2025 (File No. 001-33647), contained in your comment letter dated May 13, 2025 (the “Comment Letter”). For convenience of reference, the Staff comment contained in the Comment Letter is reprinted below in italics, numbered to correspond with the paragraph number assigned in the Comment Letter, and is followed by the response of the Company. Form 10-K for Fiscal Year Ended December 31, 2024 Consolidated Financial Statements Consolidated Statements of Cash Flows, page 83 1. We note consumers have access to credit lines for loans that can be used for a purchase on the Mercado Libre Marketplace. Please tell us how you classify cash receipts for loans from inventory sales reflected as "commerce product sales" in Note 10. Refer to ASC 230-10-45-16a. Response : MercadoLibre, Inc. offers its users (both merchants and consumers) an ecosystem of integrated e-commerce and digital financial services, mainly through Mercado Libre Marketplace and the Mercado Pago fintech platform (“Mercado Pago”). That is, Mercado Libre is not a purely commercial entity, but rather a hybrid entity that provides digital financial services beyond the e-commerce platform. The Company has two distinctive revenue streams in its business: commerce revenues and fintech revenues. Included in the Company’s fintech revenue stream is “Credit Revenues,” which includes “revenues from interest earned on loans and advances granted to merchants and consumers,” as mentioned in the Company’s 2024 Form 10-K, Part I, Item 1. Business (page 7). 1 The Company offers credit mostly to consumers and merchants who already form part of the Company’s user base. Facilitating credit is a key service overlay that enables the Company to provide incentives to use Mercado Pago as an end-to-end financial solution. The Company has two main classes of loans: a) For consumers, Mercado Pago offers personal loans to eligible users. For loans granted through Mercado Pago, the use of the funds is not pre-defined by the Company. The borrower has the option to elect how to use the funds among the following options: (i) to purchase products and services offered by third party sellers on the Mercado Libre Marketplace (“Marketplace 3P sales”), (ii) to purchase the Company’s own products on the Mercado Libre Marketplace (“Marketplace 1P sales”), (iii) to make an off-platform payment through the digital wallet (or withdraw it) or (iv) a combination of any of the above. b) For merchants, Mercado Pago provides loans to merchants who use the Mercado Libre ecosystem. The merchants normally use the funds for working capital needs or to expand their business. However, they can also use the funds in the same manner as consumer borrowers, as discussed above. As part of the Company’s oversight of the credit process, management monitors the transactions related to the lending solution and Marketplace 1P sales. Cash flows for loans used for Marketplace 3P sales or used to make off-platform payments through the digital wallet are appropriately included in investing activities in the Consolidated Statement of Cash Flows in accordance with ASC 230-10-45-12 and 45-13. All Marketplace 1P sales cash inflows are presented in Operating activities (net income) of the Consolidated Statement of Cash Flows, consistent with ASC 230-10-45-16a. However, the amount not collected from borrowers for the loans provided to them for Marketplace 1P sales is included in Changes in loans receivable, net in the investing activities of the Consolidated Statement of Cash Flows, instead of as an adjustment to operating activities. That is, the Company records a gross up of cash flow amounts in investing activities and operating activities, even though these amounts are non-cash transactions. Nonetheless, due to the immaterial amounts involved, the Company does not remove this non-cash activity from the Consolidated Statement of Cash Flows. For the year ending December 31, 2024, loans granted for Marketplace 1P sales at checkout were $61 million, which is less than 0.3% of total loan originations. As of December 31, 2024, $19 million of loans used for Marketplace 1P sales in 2024 were still outstanding, reflecting the non-cash gross up that should be removed from the Consolidated Statement of Cash Flows. In light of these considerations, the Company will continue to monitor the amounts related to loans granted for purchases of Marketplace 1P sales that are not collected as of period end and will adjust the Consolidated Statement of Cash Flows to remove the non-cash amounts, if and when they become material. *** If you have any questions or comments regarding the foregoing, please contact the Company’s Chief Accounting Officer, Marcelo Melamud at marcelo.melamud@mercadolibre.com. The Company looks forward to working with you on these matters. Sincerely, /s/ Martin de los Santos Name: Martin de los Santos Title: Chief Financial Officer cc: Jacobo Cohen Imach Martin de los Santos Marcelo Melamud 2

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 May 13, 2025

Mart n de los Santos
Executive Vice President and Chief Financial Officer
MercadoLibre, Inc.
WTC Free Zone
Dr. Luis Bonavita 1294, Of. 1733, Tower II
Montevideo, Uruguay, 11300

 Re: MercadoLibre, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
 File No. 001-33647
Dear Mart n de los Santos:

 We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 10-K for Fiscal Year Ended December 31, 2024
Consolidated Financial Statements
Consolidated Statements of Cash Flows, page 83

1. We note consumers have access to credit lines for loans that can be used
for a
 purchase on the Mercado Libre Marketplace. Please tell us how you
classify cash
 receipts for loans from inventory sales reflected as "commerce product
sales" in Note
 10. Refer to ASC 230-10-45-16a.
 May 13, 2025
Page 2

 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.

 Please contact Scott Stringer at 202-551-3272 or Adam Phippen at
202-551-3336 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
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United States securities and exchange commission logo
September 8, 2022
Pedro Arnt
Chief Financial Officer
MercadoLibre, Inc.
WTC Free Zone
Dr. Luis Bonavita 1294, Of. 1733, Tower II
Montevideo, Uruguay 11300
Re:MercadoLibre, Inc.
Form 10-K for Fiscal Year Ended December 31, 2021
Filed February 23, 2022
File No. 001-33647
Dear Mr. Arnt:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

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 MERCADOLIBRE, INC.

WTC FREE ZONE

 DR. LUIS BONAVITA
1294, OF. 1733 TOWER II

 MONTEVIDEO URUGUAY 11300

TEL +598 — 2927 — 2770

PEDRO ARNT

 EMAIL:
pedro@mercadolibre.com

 August 29, 2022

 Via
EDGAR Correspondence

 United States Securities and Exchange Commission

Division of Corporation Finance

 Office of Trade &
Services

Attention:
 Abe Friedman

Lyn Shenk

 Washington, D.C.
20549-4561

Re:
 MercadoLibre, Inc.

Form 10-K for Fiscal Year Ended December 31, 2021

Filed February 23, 2022

File No. 001-33647

Dear Abe Friedman and Lyn Shenk:

 MercadoLibre,
Inc., a Delaware corporation (the “Company,” “MercadoLibre,” “we” or “us”), responds below to the comment of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and
Exchange Commission (the “SEC”), with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2021 (the “2021 Form
10-K”) filed on February 23, 2022 (File No. 001-33647), contained in your comment letter dated August 15, 2022 (the “Comment Letter”).

 For convenience of reference, the Staff comment contained in the Comment Letter is reprinted below in italics, numbered to correspond
with the paragraph number assigned in the Comment Letter, and is followed by the response of the Company.

 Form
10-K for Fiscal Year Ended December 31, 2021

 Note 8. Segments, page 34

1.
 We note your response to comment 6. You state the CODM does not use information by products or services for
allocating resources and assessing performance of the segment. Please tell us if discrete financial information by products or services (or business lines) is provided to the CODM. Please also tell us whether there exist any “components of an
entity” (refer to ASC Master Glossary) other than the nine geographically-based operating segments you identified in your response. If so, please identify those for us.

 1

 Response: The CODM has access to financial information prepared by country and
by products or services. Discrete financial information by products or services is made available to the CODM. This discrete financial information is not made available regularly, since management does not prepare a fixed set of discrete financial
information for the CODM month-over-month. For example, depending on the trends in a certain period, management may elect to make available discrete financial information that is prepared ad-hoc for such
period only on a certain product or service and not others, which data is not necessarily shown again, or with the same breakdown or aggregation, in subsequent periods. This information by products and services is made available to show the
principal trends identified in the results of operations in each geographic segment.

 There are no company-wide components of an entity
other than the nine geographically-based operating segments identified in the Company’s response letter dated on July 25, 2022. The CODM does not use product/service or any other components, besides geographical, to allocate resources and
assess performance.

 ***

 If
you have any questions or comments regarding the foregoing, please contact the Company’s Chief Accounting Officer, Marcelo Melamud at marcelo.melamud@mercadolibre.com. The Company looks forward to working with you on these matters.

Sincerely,

 /s/ Pedro Arnt

Name:

Pedro Arnt

Title:

Chief Financial Officer

cc:
 Jacobo Cohen Imach

Pedro Arnt

 Marcelo Melamud

Federico Gómez Martínez

 2

United States securities and exchange commission logo
August 15, 2022
Pedro Arnt
Chief Financial Officer
MercadoLibre, Inc.
WTC Free Zone
Dr. Luis Bonavita 1294, Of. 1733, Tower II
Montevideo, Uruguay 11300
Re:MercadoLibre, Inc.
Form 10-K for Fiscal Year Ended December 31, 2021
Filed February 23, 2022
File No. 001-33647
Dear Mr. Arnt:
            We have reviewed your July 25, 2022 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 27, 2022 letter.
Form 10-K for Fiscal Year Ended December 31, 2021
Note 8. Segments, page 34
1.We note your response to comment 6.  You state the CODM does not use information by
products or services for allocating resources and assessing performance of the segment.
Please tell us if discrete financial information by products or services (or business lines) is
provided to the CODM.  Please also tell us whether there exist any "components of an
entity" (refer to ASC Master Glossary) other than the nine geographically-based operating
segments you identified in your response.  If so, please identify those for us.

 FirstName LastNamePedro Arnt
 Comapany NameMercadoLibre, Inc.
 August 15, 2022 Page 2
 FirstName LastName
Pedro Arnt
MercadoLibre, Inc.
August 15, 2022
Page 2
            You may contact Abe Friedman at 202-551-8298 or Lyn Shenk at 202-551-3380 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

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 MERCADOLIBRE, INC.

WTC FREE ZONE

 DR. LUIS BONAVITA
1294, OF. 1733 TOWER II

 MONTEVIDEO URUGUAY 11300

TEL +598 — 2927 — 2770

PEDRO ARNT

 EMAIL:
pedro@mercadolibre.com

 July 25, 2022

 Via EDGAR
Correspondence

 United States Securities and Exchange Commission

Division of Corporation Finance

 Office of Trade &
Services

 Attention: Mr. Abe Friedman

                 Ms. Lyn Shenk

Washington, D.C. 20549-4561

Re:
 MercadoLibre, Inc.

Form 10-K for Fiscal Year Ended December 31, 2021

Filed February 23, 2022

File No. 001-33647

Dear Mr. Friedman and Ms. Shenk:

 MercadoLibre, Inc.,
a Delaware corporation (the “Company,” “MercadoLibre,” “we” or “us”), responds below to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange
Commission (the “SEC”), with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2021 (the “2021 Form
10-K”) filed on February 23, 2022 (File No. 001-33647), contained in your comment letter dated June 27, 2022 (the “Comment Letter”).

 For convenience of reference, each Staff comment contained in the Comment Letter is reprinted below in italics, numbered to correspond with the paragraph
number assigned in the Comment Letter, and is followed by the corresponding response of the Company.

 1

 Form 10-K for Fiscal Year Ended December 31, 2021

 Consolidated Financial Statements, page 4

1.
 Please consider revising page numbering so that the financial statement page numbers are sequential to the
rest of the pages in the filing or use “F-” page numbering. Please also revise the formatting on the face of your financial statements to ensure the font size is easily readable.

 Response: The Company undertakes to revise page numbering in future filings so that the financial statement page numbers
are sequential to the rest of the pages in the filing. The Company will also revise the formatting on the face of its financial statements, starting with its interim condensed consolidated financial statements as of and for the six and three-month
periods ended June 30, 2022 (the “2Q2022 Interim Financial Statements”), to ensure the font size is easily readable.

 Notes to
Consolidated financial statements

 Note 2. Summary of significant accounting policies

Transfer of financial assets, page 12

2.
 Please define and describe the term credit cards coupon and tell us where in your footnotes these
transactions are disclosed.

 Response: The term “credit cards coupon” refers to credit card receivables
generated when a user’s payment is processed by the Company through its MercadoPago solution. The Company acknowledges that the translation could be more accurate so, beginning with the Company’s 2Q2022 Interim Financial Statements, it
will revise its disclosure to use the term credit card “receivables” instead of “coupons”. These credit card receivables are disclosed as an asset in the Credit Cards receivable and other means of payments, net line on the
balance sheet. Note 2 to the Company’s annual financial statements, on page 11, discloses the Company’s accounting policy applicable to credit card receivables. The Company discloses the effect of the transfer of these receivables on its
income statement, in the last sentence of the paragraph under the caption “Transfer of financial assets,” on page 12 of the Company’s annual financial statements, and will include that disclosure in its interim financial statements,
beginning with its 2Q2022 Interim Financial Statements.

 Allowances for doubtful accounts on loans receivable, accounts receivable and credit cards
receivable and other means of payment, page 12

3.
 We note that through Mercado Credito you operate a lending business. It appears that provisions for bad debt
expenses are classified as sales and marketing expense in your statements of income along with those from your non-lending operations. Please tell us what consideration you have given to classifying your
provision for credit losses for your Mercado Credito lending operations as a separate line item in your statements of income, rather than as an overhead-type expense in sales and marketing.

 2

 Response: The Company’s presentation of its statement of income uses a
“multi-step” format that includes subtotals such as “gross profit”, “income from operations” and “net income before income tax expense”. Provision for doubtful accounts is included in operating expenses since
credit losses are not expenses incurred to obtain revenue from customers. Note 18 to the Company’s financial statements, on page 55, discloses the Company’s credit loss expense in detail.

The Company has been classifying its operating expenses by function, computing the charge for the provision for doubtful accounts as one of those functions.
The Company will disclose the provision for doubtful accounts as a separate line item of its operating expenses in the statements of income beginning with its 2Q2022 Interim Financial Statements. The statements of income will be presented as
follows:

Six-month Periods
Ended
June 30,

Three-month Periods
Ended
June 30,

2022

2021

2022

2021

 Net service revenues

 Net product revenues

 Net revenues

 Cost of net revenues

 Gross profit

 Operating expenses:

 Product and technology development

 Sales and marketing

 Provision for doubtful accounts

 General and administrative

 Total operating expenses

 Income from operations

 Other income (expenses):

 Interest income and other financial gains

 Interest expense and other financial losses

 Foreign currency losses, net

 Net income before income tax expense

 Income tax expense

 Equity in earnings of unconsolidated entity

Net income

 3

 Provision for buyer protection program, page 14

4.
 Please revise to state that this provision is recognized in sales and marketing expense on your statements
of income.

 Response: The Company’s description of its accounting policy for Provision for buyer protection
program in future filings, including in the Notes to its 2Q2022 Interim Financial Statements, will state that the charge related to the provision for the buyer protection program is recognized in sales and marketing expense on the Company’s
statement of income.

 Revenue Recognition, page 16

5.
 Please revise to disclose disaggregated revenue and information to enable users of financial statements to
understand the relationship between the disclosure of disaggregated revenue and revenue information that is disclosed for each reportable segment and on the face of your statements of income. Refer to ASC 606-10-50-5 to 50-6 and 55-89 to 55-91. In this
regard, we note from your disclosures elsewhere that you generate revenue from, among others: Ecommerce intermediation and inventory sales (MercadoLibre Marketplace), digital payments (Mercado Pago), shipping (Mercado Envios), banner and classified
advertising (Mercado Ads and MercadoLibre Classifieds), web store services for sellers (Mercado Shop), loans to merchants (online and offline) and consumer credit (Mercado Credito), etc.

We also note information pertaining to various components of your revenue disclosed in investor calls and earnings
presentations such as:

•

 “the advertising business has been a consistent highlight in terms of growth and margin structure and has
almost doubled in revenues year over year” [5/5/22 earnings call]

•

 “if you look at take rates on the fintech business, it does show how we have been activating the pricing
levers to offset those increases in costs.” [5/5/22 earnings call]

•

 “the three main [credit] products, which are merchant loans online, merchant loans off-line and consumer credit. In each of the three countries, Argentina, Brazil and Mexico, all those nine segments are profitable.” [5/5/22 earnings call]

•

 “we had a strong year-over-year improvement in take rates over gross merchandise volume in the commerce
business” [2/22/22 earnings call]

•

 “Credit revenues reached almost $300 million during the fourth quarter alone, triple
the value of the previous year” [2/22/22 earnings call]

 In addition, we note that certain
of your revenue streams are subject to risk factors that could lead to changes in the nature, amount, timing, and uncertainty of revenues and cash flows. For example, you disclose:

•

 “the global payments industry is continuously changing and increasingly subject to regulatory supervision
and continued examination”

•

 “traditional banking and financial institutions still have significant influence over sectoral
regulators, which makes it harder to promote innovative payment solutions and policy changes to adapt regulation to an ever changing and fast growing innovative and disrupting industry.”

•

 “The expansion of our Mercado Pago and Mercado Envios business into new countries may also require a
close commercial relationship with one or more local banks or other intermediaries, which may prevent, delay or limit the introductions of our services in such countries.”

•

 “We are subject to regulation in Brazil, Argentina, Mexico, Chile, Peru and Uruguay, that require or
would require us to obtain licenses or regulatory authorizations to operate certain services provided by Mercado Pago and that would subject us to additional regulatory requirements.”

•

 “A number of jurisdictions where we operate have enacted legislation regulating shipping services. If we
fail to comply with shipping services laws or regulations, or if we engage in an unauthorized shipping business, we could be subject to liability, forced to cease doing business with residents of certain countries, or to change our business
practices or to become a postal entity”

•

 “The funding and growth of our Mercado Credito business is directly related to interest rates; a rise in
interest rates may negatively affect our Mercado Credito business and results of operations.”

 4

•

 “To achieve economies of scale, drive down shipping costs and eliminate friction for buyers and sellers,
we generally pay local carriers directly for their shipping costs, and then we decide how much of those costs we transfer to our customers. The decision to raise the shipping fees we charge to users may have a negative effect on Mercado
Envios’s shipping volume...”

 Response: The Company has been presenting disaggregated revenue
information showing revenues from Commerce and Fintech on a consolidated basis in Note to the Company´s financial statements and for each reporting segment that appears on page 51 of the Form 10-K. In
response to the Staff’s comment, beginning with its 2Q2022 Interim Financial Statements, the Company will disaggregate further as discussed below, to reflect changes in its business and to align the notes to the financial statements with
information that it has been providing to investors. The Company will also revise the note on Segments to include additional disaggregated revenue information by reporting segment.

As the Staff’s comment observes, the Company offers its users multiple services within an integrated ecosystem, and uses six principal brands to identify
those services for its users. For purposes of understanding the impact of economic factors, however, the revenues and cash flows from all these services fall into the two categories Commerce and Fintech for the following reasons:

•

 Commerce revenues are generated from a portfolio of services and products that are offered to all of the
Company’s users on a single integrated platform. The goal is to facilitate commercial transactions by enabling users to not only conduct sales and purchases digitally through the Marketplace, but also deliver products through the Company’s
shipping service, promote products through its advertising service, list products through its classified solution and set up, manage and promote digital stores through its store-front solution. Each of these services support and maximize the
Company’s core Marketplace commerce transactions.

 5

•

 Fintech revenues are offered to all of the Company’s users as a digital financial solution to the
transactions performed through its Marketplace or Off-Marketplace. Each user can access MercadoPago platform to its account and use MercadoPago as a digital payment method or to get a loan (through
MercadoCredito) using its same digital account or wallet from MercadoPago to receive the principal and pay the loan’s installments periodically. The goal of the fintech platform is to permit the users to manage their finances with a few clicks.

 The Company conducts its business in a dynamic context that evolves rapidly and has an impact on certain products or services that the
Company offers. For instance, since the beginning of the COVID-19 pandemic in 2020, the Company has observed that buyers have diversified their purchases across a wider range of verticals on its platform. This
generated a greater number of transactions and increases in overall purchase frequency showing growth in the Company’s Net revenues line in the statement of income.

In connection with the aforementioned business growth, as the Staff notes, the Company regularly provides materials and presentations to investors that
contain revenue data or operational information about one or more specific services or products. This information is provided to supplement investors’ understanding of the Company’s business and its performance, when a particular
development or impact is of interest for that purpose. For instance, the Company’s lending business has grown significantly in 2022 compared to 2021, leading us to highlight the evolution of its revenue stream. However, the Company believes
that these supplemental details about a particular product or service should not imply that the product or service should be disaggregated.

 Similarly,
the Staff notes that the Company’s risk factor disclosure identifies risks that could affect revenues from specific services in particular ways. The existence of these specific risks does not outweigh the common elements within Commerce
revenues and within Fintech revenues. For example, the Company’s business as a whole is subject to regulatory risk, and the Staff quotes several risk factors that identify specific regulatory risks for services within the Fintech category. The
Company believes this is consistent with its presentation of disaggregated revenues.

 To reflect its changing business, and to align its financial
statements’ disclosures with materials it has recently been providing to investors, the Company will expand the disclosure in Note 7 – Segments, beginning with the Company’s 2Q2022 Interim Financial Statements, to provide revenue
disaggregation in the following categories:

 6

Six months ended June 30,

Argentina

Brazil

Mexico

Other
Countries

Total

2022

2021

2022

2021

2022

2021

2022

2021

2022

2021

 Commerce services (a)

 Commerce products sales (b)

 Total commerce revenues

 Fintech services (c)

 Credit revenues (d)

 Fintech products sales (e)

 Total fintech revenues

 Total net revenues

Three months ended June 30,

Argentina

Brazil

Mexico

Other
Countries

Total

2022

2021

2022

2021

2022

2021

2022

2021

2022

2021

 Commerce services (a)

 Commerce products sales (b)

 Total commerce revenues

 Fintech services (c)

 Credit revenues (d)

 Fintech products sales (e)

 Total fintech revenues

 Total net revenues

(a)
 Includes final value fees paid by sellers derived from intermediation services and related shipping fees,
classified fees derived from classified advertising services and ad sales.

(b)
 Includes revenues from inventories sales and related shipping fees.

(c)
 Includes revenues from commissions the Company charges for transactions
off-platform derived from use of the Company’s payment solution, revenues as a result of offering installments for the payment to its Mercado Pago users, either when the Company finances

United States securities and exchange commission logo
June 27, 2022
Pedro Arnt
Chief Financial Officer
MercadoLibre, Inc.
WTC Free Zone
Dr. Luis Bonavita 1294, Of. 1733, Tower II
Montevideo, Uruguay 11300
Re:MercadoLibre, Inc.
Form 10-K for Fiscal Year Ended December 31, 2021
Filed February 23, 2022
File No. 001-33647
Dear Mr. Arnt:
            We have reviewed your filing 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 10-K for Fiscal Year Ended December 31, 2021
Consolidated Financial Statements, page 4
1.Please consider revising page numbering so that the financial statement page numbers are
sequential to the rest of the pages in the filing or use "F-" page numbering.  Please also
revise the formatting on the face of your financial statements to ensure the font size is
easily readable.
Notes to Consolidated Financial Statements
Note 2. Summary of significant accounting policies
Transfer of financial assets, page 12
2.Please define and describe the term credit cards coupon and tell us where in your
footnotes these transactions are disclosed.

 FirstName LastNamePedro Arnt
 Comapany NameMercadoLibre, Inc.
 June 27, 2022 Page 2
 FirstName LastNamePedro Arnt
MercadoLibre, Inc.
June 27, 2022
Page 2
Allowances for doubtful accounts on loans receivable, accounts receivable and credit cards
receivable and other means of payment, page 12
3.We note that through Mercado Credito you operate a lending business.  It appears that
provisions for bad debt expenses are classified as sales and marketing expense in your
statements of income along with those from your non-lending operations.  Please tell us
what consideration you have given to classifying your provision for credit losses for your
Mercado Credito lending operations as a seprate line item in your statements of income,
rather than as an overhead-type expense in sales and marketing.
Provision for buyer protection program, page 14
4.Please revise to state that this provision is recognized in sales and marketing expense on
your statements of income.
Revenue recognition, page 16
5.Please revise to disclose disaggregated revenue and information to enable users of
financial statements to understand the relationship between the disclosure of
disaggregated revenue and revenue information that is disclosed for each reportable
segment and on the face of your statements of income.  Refer to ASC 606-10-50-5 to 50-6
and 55-89 to 55-91.  In this regard, we note from your disclosures elsewhere that you
generate revenue from, among others: Ecommerce intermediation and inventory sales
(MercadoLibre Marketplace), digital payments (Mercado Pago), shipping (Mercado
Envios), banner and classified advertising (Mercado Ads and MercadoLibre Classifieds),
web store services for sellers (Mercado Shop), loans to merchants (online and offline) and
consumer credit (Mercado Credito), etc.

We also note information pertaining to various components of your revenue disclosed in
investor calls and earnings presentations such as:
•"the advertising business has been a consistent highlight in terms of growth and
margin structure and has almost doubled in revenues year over year" [5/5/22 earnings
call]
•"if you look at take rates on the fintech business, it does show how we have been
activating the pricing levers to offset those increases in costs." [5/5/22 earnings call]
•"the three main [credit] products, which are merchant loans online, merchant loans
off-line and consumer credit. In each of the three countries, Argentina, Brazil and
Mexico, all those nine segments are profitable." [5/5/22 earnings call]
•"we had a strong year-over-year improvement in take rates over gross merchandise
volume in the commerce business" [2/22/22 earnings call]
•"Credit revenues reached almost $300 million during the fourth quarter alone, triple
the value of the previous year"  [2/22/22 earnings call]

In addition, we note that certain of your revenue streams are subject to risk factors that
could lead to changes in the nature, amount, timing, and uncertainty of revenues and cash

 FirstName LastNamePedro Arnt
 Comapany NameMercadoLibre, Inc.
 June 27, 2022 Page 3
 FirstName LastNamePedro Arnt
MercadoLibre, Inc.
June 27, 2022
Page 3
flows.  For example, you disclose:
•"the global payments industry is continuously changing and increasingly subject to
regulatory supervision and continued examination"
•"traditional banking and financial institutions still have significant influence over
sectoral regulators, which makes it harder to promote innovative payment solutions
and policy changes to adapt regulation to an ever changing and fast growing
innovative and disrupting industry."
•"The expansion of our Mercado Pago and Mercado Envios business into new
countries may also require a close commercial relationship with one or more local
banks or other intermediaries, which may prevent, delay or limit the introductions of
our services in such countries."
•"We are subject to regulation in Brazil, Argentina, Mexico, Chile, Peru and Uruguay,
that require or would require us to obtain licenses or regulatory authorizations to
operate certain services provided by Mercado Pago and that would subject us to
additional regulatory requirements."
•"A number of jurisdictions where we operate have enacted legislation regulating
shipping services. If we fail to comply with shipping services laws or regulations, or
if we engage in an unauthorized shipping business, we could be subject to liability,
forced to cease doing business with residents of certain countries, or to change our
business practices or to become a postal entity"
•"The funding and growth of our Mercado Credito business is directly related to
interest rates; a rise in interest rates may negatively affect our Mercado Credito
business and results of operations."
•"To achieve economies of scale, drive down shipping costs and eliminate friction for
buyers and sellers, we generally pay local carriers directly for their shipping costs,
and then we decide how much of those costs we transfer to our customers. The
decision to raise the shipping fees we charge to users may have a negative effect on
Mercado Envios’s shipping volume..."
Note 8. Segments, page 34
6.We note that you report segments by geography and that your operations span many
complimentary, but distinct product and service lines. We also note that your investor
presentations, such as your May 5, 2022 investor presentation and your institutional video
presentation on your website, appear to focus more on your different business lines than
on geography.  For example, your investor presentations have different, color-coded
sections for your primary business lines.  It also appears that your current segment
reporting by geography does not provide investors with much insight into your business
lines.  Please tell us, and revise to disclose, the factors used to identify your reportable
segments, including the basis of organization (for example, whether management has
chosen to organize the company around differences in products and services, geographic
areas, or a combination of factors and whether operating segments have been aggregated).
Please refer to ASC 280-10-50-21.  As part of your response, please also tell us how you
identified your operating segments based on the criteria provided in ASC 280-10-50-1

 FirstName LastNamePedro Arnt
 Comapany NameMercadoLibre, Inc.
 June 27, 2022 Page 4
 FirstName LastName
Pedro Arnt
MercadoLibre, Inc.
June 27, 2022
Page 4
through 50-9 and provide us with a list of these operating segments.  Please tell us how
you considered the aggregation criteria in ASC 280-10-50-11 and the quantitative
thresholds in ASC 280-10-50-12 in determining your reportable segments.  Please be
detailed in your response.
            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 Abe Friedman at 202-551-8298 or Lyn Shenk at 202-551-3380 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

Mail Stop 4561
July 5, 2017

Pedro Arnt
Chief Financial Officer
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2016
Filed February 24, 2017
File No. 001-33647

Dear Mr. Arnt :

We have completed our review of your filing.  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.

Sincerely,

 /s/ Stephen Krikorian

Stephen Krikorian
Accounting Branch Chief
Office of Information Technologies
and Services

CORRESP
1
filename1.htm

MERCADOLIBRE,
INC.

ARIAS 3751, 7TH FLOOR

BUENOS AIRES,
C1430CRG

ARGENTINA

TEL +5411 — 4640 — 8000

PEDRO
ARNT

DIRECT DIAL:
+5411 — 4640 — 8006

EMAIL: pedro@mercadolibre.com

June
28, 2017

Via
EDGAR Correspondence

Mr. Stephen
Krikorian

Accounting
Branch Chief

United States
Securities and Exchange Commission

Division of
Corporation Finance

Office of Information
Technologies and Services

100 F Street,
N.E.

Washington,
D.C. 20549-4561

    Re:
    MercadoLibre, Inc.

Form
10-K for Fiscal Year Ended December 31, 2016

Filed
February 24, 2017

File
No. 001-33647

Dear
Mr. Krikorian,

MercadoLibre,
Inc., a Delaware corporation (the “Company,” “MercadoLibre”, “we” or “us”), responds
below to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange
Commission (the “SEC”), with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31,
2016 (the “Form 10-K”) filed on February 24, 2017 (File No. 001-33647), contained in your comment letter
dated June 15, 2017 (the “Comment Letter”).

For
convenience of reference, each Staff comment contained in the Comment Letter is reprinted below in italics, numbered to correspond
with the paragraph number assigned in the Comment Letter and is followed by the corresponding response of the Company.

Form
10-K for Fiscal Year Ended December 31, 2016

Management’s
Discussion and Analysis of Financial Condition and Results of Operations

Description of line items

Sales and marketing expenses, page 46

 1. Please tell us whether your buyer protection program represents
a guarantee that should be accounted for under ASC 460-10. If this is the case, revise to provide the required disclosures pursuant
to ASC 460-10-50 in the footnotes to the financial statements.

Response: We advise the Staff
that we believe that our buyer protection program is effectively a guarantee and subject to the disclosure requirements under ASC
460-10-50.

This program provides protection on Marketplace
transactions that are processed through our online payment solution (“MercadoPago”), and as a result, the maximum potential
exposure is related to the volume of payments on our marketplace during the period for which
customer protection claims may be raised under existing user agreements. Based on historical losses to date, we do not believe
that the maximum potential exposure is representative of our actual potential exposure. We disclose our total volume of payments
on marketplace on page 40 of our Form 10-K for the fiscal year ended December 31, 2016.

We advise the Staff that we have assessed the
disclosure requirements under ASC 460-10-50 to be immaterial from both a qualitative and quantitative perspective as of December
31, 2016. Nevertheless, due to the expected increase in the buyer protection program in future periods, in future filings, beginning
with our Form 10-Q for the period ended June 30, 2017, we will include in the “Commitments and Contingencies” footnote
to the financial statements a description of the nature, the maximum potential exposure to, and the amount provisioned from, our
buyer protection program, as follows:

Example disclosure:

The Company provides consumers with a buyer
protection program (“BPP”) for all transactions completed through the Company’s online payment solution (“MercadoPago”).
This program is designed to protect buyers in the Marketplace from losses due primarily to fraud or counterparty non-performance.
The Company’s BPP provides protection to consumers by reimbursing them for the total value of the unfulfilled transaction,
if a purchased item does not arrive or does not match the seller’s description. The Company is entitled to recover from the
third-party carrier companies performing the shipping service certain amounts paid under the BPP. Furthermore, in some specific
circumstances (i.e. Black Friday, Hot Sale), the Company enters into insurance contracts with third party insurance companies in
order to cover contingencies that may arise from the BPP.

The maximum potential exposure under this program
is estimated to be the volume of payments on the Marketplace, for which claims may be made under the Company’s existing user
agreements. Based on historical losses to date, the Company does not believe that the maximum potential exposure is representative
of the actual potential exposure. The Company records a liability with respect to losses under this program when they are probable
and the amount can be reasonably estimated.

As of June 30, 2017, management's estimate
of the maximum potential exposure related to the Company’s buyer protection program is $[●], for which we recorded
an allowance as of that date of $[●].

Results of operations

Net revenues, page 56

 2. We reissue prior comment 2. Your response indicates that your
current disclosures allow investors to understand the material factors; however, it does not quantify the contribution of each
factor to the change. Please confirm that you will quantify the contribution of each factor when there is a material change in
your Non-Marketplace revenue. We refer you to Item 303 of Regulation S-K and Section III.D of SEC Release No. 33-6835.

Response:
We advise the Staff that in future filings, beginning with our Form 10-Q for the period ended June 30, 2017, we will quantify
the contribution of each significant factor to the extent there is a material change in our
Non-Marketplace revenue.

Consolidated financial statements

Notes to Consolidated financial statements

Note 7. Segments, page 32

 3. It remains unclear to us how payment related fees, which are
a significant revenue stream, are similar to other services that you consider to be ancillary. In this regard, we note that payment
related fees appear to be very different from shipping or advertising fees. Please provide separate quantification of payment related
fees in future filings.

Response: We
advise the Staff that in future filings, we will provide separate quantification of payment fees.

In response to the Staff’s
comment, below is how the disclosure would look in our Form 10-Q for the period ending June 30, 2017:

Example disclosure:

    Six-months Ended June 30,

    Three-months Ended June 30,

    Consolidated Net Revenues

    2017

    2016

    2017

    2016

    (In thousands)

    (In thousands)

    Marketplace

     $[●]

    $         207,375

     $[●]

    $         113,252

    Non-marketplace (*) (**)

    $[●]

    $         149,899

    $[●]

    $           86,392

    Total

    $[●]

    $         357,274

    $[●]

    $         199,644

(*) Includes mainly Payment Fees,
Ad Sales, Real Estate, Motors, Shipping Fees and other ancillary services.

(**) Includes $[●] and $87,186
of Payment Fees for the six-month periods ended June 30, 2017 and 2016, respectively; and $[●] and $50,570 for the three-month
periods ended June 30, 2017 and 2016, respectively.

If you have any questions or comments
regarding the foregoing, please contact our Chief Accounting Officer, Marcelo Melamud at +5411 4640 8053, marcelo.melamud@mercadolibre.com.
We look forward to working with you on these matters.

Sincerely,

 /s/ Pedro Arnt

Name: Pedro Arnt

Title: Executive Vice President and Chief Financial Officer

    cc:

        Jacobo Cohen Imach

        Pedro Arnt

        Marcelo Melamud

        Federico Gómez Martínez

Mail Stop 4561
June 15, 2017

Pedro Arnt
Chief Financial Officer
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2016
Filed February 24, 2017
File No. 001-33647

Dear Mr. Arnt:

We have reviewed your June 5 , 2017  response to our comment letter 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  comment s 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.
Unless we note otherwise, our references to prior comments are to comments in our May 22,
2017  letter.

Management’s Discussion and Analysis of Financial Condition and Results of Ope rations

Sales and marketing expenses, page 46

1. Please tell us whether your buyer protection program represents a guarantee that should
be accounted for under ASC 460 -10.  If this is the case, revise to provide the required
disclosures pursuant to ASC 460 -10-50 in the footnotes to the financial statements .

Results of operations

Net revenues, page 56

Pedro Arnt
MercadoLibre, Inc.
June 15, 2017
Page 2

 2. We reissue prior comment 2.  Your response indicates that your current disclosures allow
investors to understand the material factors; however, it does not quantify  the
contribution  of each factor to the change.  Please confirm that you will quantify the
contribution of each factor when there is a material change in your Non -Marketplace
revenue.  We refer you to Item 303 of Regulation S -K and Section III.D of  SEC Release
No. 33 -6835.

Notes to Consolidated Financial Statements

Note 7. Segments, page 32

3. It remains unclear to us  how payment related fees, which are a significant revenue
stream, are similar to other services that you consider to be  ancillary.  In this regard, we
note that payment related fee s appear to be very different from shipping or advertising
fees.  Please provide separate quantification of payment related fees in future filings.

You may contact Mengyao Lu, Staff Accountant, at (202) 551 -7271 , or Christine Dietz,
Assistant Chief Accountant, at (202) 551 -3408 , if you have questions regarding comments on the
financial statements and related matters.  If you require further assistance, do not hesitate to
contact me at (202) 551 -3488 .

Sincerely,

 /s/ Stephen Krikorian

Stephen Krikorian
Accounting Branch Chief
Office of Information Technologies
and Services

CORRESP
1
filename1.htm

CONFIDENTIAL TREATMENT REQUESTED
BY MERCADOLIBRE, INC.1

MERCADOLIBRE,
INC.

ARIAS 3751, 7TH FLOOR

BUENOS AIRES,
C1430CRG

ARGENTINA

TEL +5411 — 4640 — 8000

PEDRO
ARNT

DIRECT DIAL:
+5411 — 4640 — 8006

EMAIL: pedro@mercadolibre.com

June
5, 2017

Via
EDGAR Correspondence

Mr. Stephen
Krikorian

Accounting
Branch Chief

United States
Securities and Exchange Commission

Division of
Corporation Finance

Office of Information
Technologies and Services

100 F Street,
N.E.

Washington,
D.C. 20549-4561

    Re:
    MercadoLibre, Inc.

Form
10-K for Fiscal Year Ended December 31, 2016

Filed
February 24, 2017

File
No. 001-33647

Dear
Mr. Krikorian,

MercadoLibre,
Inc., a Delaware corporation (the “Company,” “MercadoLibre”, “we” or “us”), is
transmitting for filing the Company’s responses to the comments of the Staff of the Division of Corporation Finance (the
“Staff”) of the Securities and Exchange Commission (the “SEC”), with respect to the Company’s Annual
Report on Form 10-K for the fiscal year ended December 31, 2016 (the “Form 10-K”) filed on February 24, 2017 (File
No. 001-33647), contained in your comment letter dated May 22, 2017 (the “Comment Letter”).

For
convenience of reference, each Staff comment contained in the Comment Letter is reprinted below in italics, numbered to correspond
with the paragraph number assigned in the Comment Letter and is followed by the corresponding response of the Company. [1]

Form
10-K for Fiscal Year Ended December 31, 2016

Management’s
Discussion and Analysis of Financial Condition and Results of Operations

1
Note: Confidential treatment has been requested under Rule 83 (17 C.F.R. § 200.83) with respect to the information contained
within the [***] marking. Such portions have been omitted from this filing and have been filed separately with the Securities and
Exchange Commission.

Description of line items

Sales and marketing expenses, page 46

 1. Please explain your basis for including the charges related to the buyer protection program
in sales and marketing and refer to the authoritative guidance you relied upon when determining your classification.

Response: In response to the
Staff’s comment, we advise the Staff that our buyer protection program (“BPP”) is designed to protect buyers
in the Marketplace from losses due primarily to fraud or counterparty non-performance. In the case of an unfulfilled transaction,
our buyer protection program covers the total value of the unfulfilled transaction subject to some conditions detailed in its terms
of use. The program, therefore, provides confidence to both buyers and sellers regarding the fulfillment of the transaction, generating
retention and higher volume of transactions through our platform. We believe our BPP incentivizes potential buyers to make purchases
through our platform instead of through other means. Accordingly, we consider the BPP to be a marketing tool to incentive the use
of our ecosystem. Furthermore, charges related to the buyer protection program are not necessary costs incurred to generate revenues
or expenses directly related to providing the service that generates our revenues.

In addition, we advise the Staff that we rely
upon the guidance in Regulation S-X 210.5 -03 when determining the appropriate income statement classification for charges related
to the buyer protection program.

For the reasons described above, we advise
the Staff that we concluded that charges related to the buyer protection program should be accounted for as “Sales and marketing
expenses” in the income statement.

Results of operations

Net revenues, page 56

 2. You disclose that the increases in Non-Marketplace revenue in Brazil and Argentina during 2016
were mainly driven by the volumes of financing transactions, off-platform transactions, items shipped and ad sales. To the extent
material, please quantify the contribution of each of these factors in future filings. As part of your response, please explain
to us why you do not disclose the impact of the local currency devaluation on Non-Marketplace revenues. Refer to Item 303(a)(3)(iii)
of Regulation S-K and Section III.D of SEC Release No. 33-6835.

Response:
We advise the staff that we believe we have complied with the rules prescribed by Item 303(a)(3)(iii) of Regulation S-K
and Section III.D of SEC Release No. 33-6835 because our disclosures allow an investor to understand the material factors that
drive revenues within the Non-Marketplace category in each of our segments. Please also refer
to our response to Question 5. If a change in Non-Marketplace revenue is in the future materially driven by a change in just one
factor, we will quantify that contribution of that factor as a percentage of the total increase or decrease in future filings.

The increase in 2016 Non-Marketplace revenues
in Argentina and Brazil, was primarily driven by increases in the volume of payments and shipping transactions. In the case of
Argentina, the increase was partially offset by the local currency devaluation in that country. We advise the Staff that in future
filings, we will explain and quantify the impact of local currency devaluation on Non-Marketplace revenues to the extent material.

 3. You disclose on page 23 that your MercadoPago business has not obtained the requisite authorization
of the Brazilian Central Bank to carry out certain payment processing functions, which may have a material adverse effect on your
business and results of operations. Please tell us the amount of revenue earned from your MercardoPago business in Brazil during
each annual period presented and how you considered quantifying in your MD&A the potential adverse impact this uncertainty
may have on your operations. Refer to Item 303(a) of Regulation S-K and Sections III.B.3 and IV.B.1 of SEC Release No. 33-8350.

Response: We determine
what to disclose as a risk factor based on the probability of an event occurring, the potential magnitude of the effect of an event
on our business, or both. In the case of the required authorization of the Brazilian Central Bank to carry out certain payment
processing functions, we believe, although the effect on our business would be material if we were not to receive authorization,
the probability of non-authorization is low. Although we submitted our application in 2014 and it has not yet been approved, this
is consistent with information provided by the Central Bank of Brazil indicating that the vast majority of applications submitted
to date have not yet been processed. We are permitted to continue carrying out the payment processing functions subject to the
authorization until such authorization is received or denied. Further, we have not received any indication that our application
will not be authorized at some point. Accordingly, we do not believe Item 303(a) of Regulation S-K or Sections III.B.3 and IV.B.1
of SEC Release No. 33-8350, which require disclosure of known trends (i.e., based on a likelihood of occurrence) require at this
time disclosure or quantification of the potential adverse impact of non-authorization. However, we closely monitor the status
of this matter on a recurring basis and, to the extent we believe that the probability of non-authorization is no longer low, we
will disclose the potential adverse impact.

Consolidated financial statements

Notes to Consolidated financial statements

Note 2. Summary of significant accounting
policies

Revenue recognition, page 14

 4. Please describe for us the various offerings under MercadoPago and the respective revenue recognition
policy for each offering. Distinguish the fees earned for providing financing directly and any other fees earned before the credit
card receivables are sold

to third parties. Revise your
disclosure in future filings to provide a more comprehensive policy for financing revenues.

Response:
In response to the Staff’s comment, we advise the Staff that we earn revenues through MercadoPago from commissions we charge
sellers that use MercadoPago to process payments for transactions they consummate off-Marketplace. The commission charged is based
on a percentage of the payment amount processed through MercadoPago. Net revenues earned from these transactions are recognized
when the transaction is completed (i.e. when the payment is processed by the Company).

We also
earn revenues as a result of offering financing to our MercadoPago buyers. We offer buyers (in both on- and off-Marketplace transactions)
the option to pay in installments and charge fees corresponding to the amount financed. We recognize revenue from these activities
either when we finance directly or when we sell the corresponding financial assets to financial institutions. When we sell the
credit card receivables to financial institutions, financing revenues are accounted for net of financing cost at the time of transfer
of the financial assets. When we directly finance the transaction we recognize financing revenues ratably over the period of the
financing.

Finally,
we generate revenues from interests from merchant loans and advances extended under our MercadoCredito solution. Interest earned
on loans and advances granted to merchants is recognized over the period of the loan and is based on effective interest rates,
net of any required reserves.

We advise
the Staff that we will revise our disclosure in Note 2, section “Revenue Recognition” to the Company´s consolidated
financial statements in future 10K to provide a more comprehensive policy for MercadoPago financing revenues, as follows:

“Revenues
from commissions we charge to sellers for transactions off-platform derived from the use of the Company’s on-line payments
solution, are recognized once the transaction is considered completed, when the payment is processed by the Company. The Company
also earns revenues as a result of offering financing to its MercadoPago users, either when the Company finances the transactions
directly or when the Company sells the corresponding financial assets to financial institutions. When the Company finances
the transactions directly, it recognizes financing revenue ratably over the period of the financing. When the Company sells the
corresponding financial assets to financial institutions, financing revenues are accounted for net of financing costs at the time
of transfer of the financial assets.

Revenues
from interest earned on loans and advances granted to merchants are recognized over the period of the loan and is based on effective
interest rates, net of any required reserves.”

Note 7. Segments, page 32

 5. Please tell us how you considered disclosing revenue for each Non-Marketplace service or groups
of similar services pursuant to ASC 280-10-50-40. In your response, quantify the revenues from financing fees, off-platform payment
fees, shipping fees and advertising services during each annual period presented.

Response: We
advise the Staff that we offer our users an integrated ecosystem of services composed of multiple interrelated e-commerce services.
The most significant are the MercadoLibre Marketplace, the MercadoPago payments solutions, the MercadoEnvios shipping services,
the MercadoLibre advertising programs, the MercadoLibre Classifieds services and the MercadoShops online webstores solutions, as
further explained in our Form 10K as of December 31, 2016. Pursuant to ASC 280-10-50-40, we disclose revenues from these services
as either Marketplace or Non-Marketplace, taking into consideration that revenues from our core Marketplace solution are derived
directly from our gross merchandise volume (“GMV”) and all other services (which we classify as Non-Marketplace services)
are not directly tied to GMV. We believe aggregation of these Non-Marketplace services meets the requirements of ASC 280-10-50-40
because we consider them similar in nature for the following reasons:

 - Our Non-Marketplace services are ancillary to our Marketplace service
and are generally offered to our users as a unified set of services over a unique platform that serve the purpose of making Marketplace
transactions easier to carry out by buyers and sellers.

 - Non-Marketplace services are primarily designed to support and maximize
sales volumes on our core Marketplace. Consequently, our market strategy with respect to Non-Marketplace services is based
on a consideration of the impact of a Non-Marketplace service on the revenues of our ecosystem as a whole, rather than on the potential
revenues derived from a particular service.

 - Virtually all of our Non-Marketplace services are distributed to
our marketplace users through a single on-line channel, and the majority of these are distributed as part of a purchase carried
out on our marketplace.

 - Our product development process is focused primarily on the enhancement
of our integrated platform to respond to a competitive user environment. Our product development strategy with respect to Non-Marketplace
services is based on a consideration of the impact of a Non-Marketplace service on the revenues of our ecosystem as a whole, rather
than on the potential revenues derived from a particular service.

The breakdown
of our consolidated net revenues of the requested Non-Marketplace Services categories for the years ended December 31, 2016,
2015 and 2014 can be quantified as follows (in thousands):

CONFIDENTIAL
TREATMENT REQUESTED BY MERCADOLIBRE, INC.2

    Revenues
    2016
    2015
    2014

    Payments related fees (*)
    ***
    ***
    ***

    Shipping fees
    ***
    ***
    ***

    Advertising fees
    ***
    ***
    ***

(*) Payments
related fees include fees arising from financing, off-platform and other payment services.

If you have any questions or comments
regarding the foregoing, please contact our Chief Accounting Officer, Marcelo Melamud at +5411 4640 8053, marcelo.melamud@mercadolibre.com.
We look forward working with you on these matters.

Sincerely,

/s/ Pedro Arnt

Name: Pedro Arnt

Title: Executive Vice President and Chief Financial Officer

    cc:

        Jacobo Cohen Imach

        Pedro Arnt

        Marcelo Melamud

        Federico Gómez Martínez

2
Note: Confidential treatment has been requested under Rule 83 (17 C.F.R.
§ 200.83) with respect to the information contained within the [***] marking. Such portions have been omitted from this filing
and have been filed separately with the Securities and Exchange Commission.

Mail Stop 4561
May 22, 2017

Pedro Arnt
Chief Financial Officer
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2016
Filed February 24, 2017
File No. 001-33647

Dear Mr. Arnt :

We have reviewed your filing  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 advi se 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.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Description of line items

Sales and marketing expenses, page 46

1. Please explain your basis for including the charges related to the buyer protection
program in sales an d marketing and refer to the authoritative guidance you relied upon
when determining your classification.

Pedro Arnt
MercadoLibre, Inc.
May 22, 2017
Page 2

 Results of operations

Net revenues, page 5 6

2. You disclose that the increases in Non -Marketplace revenue in Brazil and Argentina
during 2016 wer e mainly driven by the volumes of financing transactions, off -platform
transactions, items shipped and ad sales.  To the extent material, please quantify the
contribution of each of these factors in future filings.  As part of your response, please
explain  to us why you do not disclose the impact of the local currency devaluation on
Non-Marketplace revenues.  Refer to Item 303(a)(3)(iii) of Regulation S -K and Section
III.D of SEC Release No. 33 -6835.

3. You disclose on page 23 that your MercadoPago  business has not obtained the requisite
authorization of the Brazilian Central Bank to carry out certain payment processing
functions, which may have a material adverse effect on your business and results of
operations.  Please tell us the amount of reven ue earned from your MercardoPago
business in Brazil during each annual period presented  and how you considered
quantifying in your MD&A the potential adverse impact this uncertainty may have on
your operations.  Refer to Item 303(a) of Regulation S -K and S ections III.B.3 and IV.B.1
of SEC Release No. 33 -8350.

Consolidated Financial Statements

Notes to Consolidated Financial Statements

Note 2. Summary of significant accounting policies

Revenue recognition, page 14

4. Please describe for us the various off erings under MercadoPago and the respective
revenue recognition policy for each offering.  Distinguish the fees earned for providing
financing directly and any other fees earned before the credit card receivables are sold to
third parties.  Revise your dis closure in future filings to provide a more comprehensive
policy for financing revenues.

Note 7. Segments, page 32

5. Please tell us how you considered disclosing revenue for each Non -Marketplace service
or groups of similar services pursuant to ASC 280 -10-50-40.  In your response, quantify
the revenues from financing fees, off -platform payment fees, shipping fees and
advertising services during each annual period  presented .

Pedro Arnt
MercadoLibre, Inc.
May 22, 2017
Page 3

 We remind you that the company and its management are responsible for the accura cy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Mengyao Lu, Staff Accountant , at (202) 551 -7271 , or Christine Dietz,
Assistant Chief Accountant , at (202) 551 -3408 , if you have questions regarding comments on the
financial statements and related matters.  If you require further assistance, do not hesitate to
contact me at (202) 551 -3488 .

Sincerely,

 /s/ Stephen Krikorian

Stephen Krikorian
Accounting Branch Chief
Office of Information Technologies
and Services

September 23 , 2014

Via E -mail
Pedro Arnt
Chief Financial Officer
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc .
 Form 10 -K for the Fiscal Year Ended December 31, 201 3
 Filed March 3, 2014
 File No. 001 -33647

Dear Mr. Arnt :

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequ acy of the disclosure in the filing to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Stephen Krikorian

Stephen Krikorian
Accounting Branch Chief

cc:   Marcelo Melamud
 Chief Accounting Officer

CORRESP
1
filename1.htm

CORRESP

 MERCADOLIBRE, INC.

ARIAS 3751, 7TH FLOOR

BUENOS AIRES, C1430CRG

 ARGENTINA

 TEL +5411 — 4640 — 8000

PEDRO ARNT

 DIRECT DIAL: +5411 — 4640 — 8006

 EMAIL:
pedro@mercadolibre.com

 September 2, 2014

Mr. Stephen Krikorian

 Accounting Branch Chief

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549-4561

Re:
MercadoLibre, Inc.

 Form 10-K for Fiscal Year Ended December 31, 2013

Filed March 3, 2014

File No. 001-33647

 Dear
Mr. Krikorian:

 MercadoLibre, Inc., a Delaware corporation (the “Company,” “MercadoLibre”, “we” or “us”), is
transmitting for filing the Company’s responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”), with respect to the Company’s
Annual Report on Form 10-K for the fiscal year ended December 31, 2013 (the “Form 10-K”) filed on March 3, 2014 (File No. 001-33647), contained in your comment letter dated August 18, 2014 (the “Comment
Letter”).

 For convenience of reference, each Staff comment contained in the Comment Letter is reprinted below in italics, numbered to correspond
with the paragraph number assigned in the Comment Letter and is followed by the corresponding response of the Company.

 Form 10-K for Fiscal Year Ended December 31, 2013

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of operations

 Net revenues, page 59

1.
We note your response to prior comment 1. Please clarify how your disclosures on page 60 comply with the requirements of Item 303(a)(3)(iii) of Regulation S-K and Section III.D of SEC Release No. 33-6835.
In this regard, for each of your segments, you attribute increases in your marketplace revenues to increase in unit sales and growth in fees, without quantifying the amount that each source contributed to the change. While we note that your prices
are fixed percentages of the prices which the sellers post on your web site, and you have not changed such percentages significantly, the increase in your revenues as a result of increases in seller prices represents a source of change that should
be quantified, if material.

 Response:

We advise the Staff that we believe we have complied with the rules prescribed by Item 303(a)(3)(iii) of Regulation S-K and Section III.D of SEC Release
No. 33-6835 because our disclosures allow for an understanding of the material factors that drove revenue growth in each of our segments in 2013.

 In
response to the Staff’s inquiry regarding increases of marketplace revenue as a result of increases in prices, the Company advises the staff that, upon further review, it believes that the most insightful way to explain marketplace revenue
growth for each of its segments is through three principal drivers: growth in the volume transacted through our marketplace as measured in local currencies (“local currency volume”), and/or changes in prices charged to sellers, and/or
foreign exchange fluctuations.

 For each of our segments, for the year ended 2013 as compared to 2012, one or more, but not necessarily all, of these
three drivers have a material effect on marketplace revenue growth. The following paragraphs describe and quantify, if material, each of these growth drivers.

Specifically, marketplace revenue growth in Brazil of 14.9% during 2013 primarily reflects increased local currency volume of 18.2%.

Marketplace revenue growth in Mexico of 19.8% during 2013 primarily reflects increased local currency volume of 6.3% and a 9.2% increase in prices
charged to sellers that resulted from an increase in the fees for marketplace transactions charged to sellers.

 Marketplace revenues of our Venezuelan
segment increased 68.3% during 2013 mainly due to a 125.4% increase in local currency volume that was partially offset by a 16.8% devaluation of the local currency during the year, and a 12.7% decrease in the prices charged to sellers that
resulted from certain caps that we applied to our fees for marketplace transactions.

 Marketplace revenues of our Argentine segment increased 28.9% during
2013, mainly due to a 47.5% increase in local currency volume that was substantially offset by a 20.4% devaluation of the Argentine peso during the year.

The Company will continue to monitor the impact that the change in local currency volume, prices charged to sellers, and foreign currency fluctuations have on
the total change in marketplace revenues and will quantify these when their effect is material.

 Finally, for knowledge of the Staff, we advise that it’s inquiry regarding the impact of unit sales and of
the prices at which sellers post on our websites represent additional information that explain growth of local currency volume, which is only one of the drivers behind revenue growth. Notwithstanding, and in order to satisfy the Staff’s request
for further clarification, unit growth for the full year period 2013 represented 23.2% while average prices at which sellers post on our website during that year, as measured in US dollars increased by 4.0%.

The Company hereby acknowledges that:

•

the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•

Staff comments or changes to disclosure in response to Staff comments do not foreclose the SEC from taking any action with respect to the filing; and

•

the Company may not assert Staff’s comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.

If you have any questions or comments regarding the foregoing, please contact our Chief Accounting Officer, Marcelo Melamud at +5411 4640 8053,
marcelo.melamud@mercadolibre.com. We look forward working with you on these matters.

 Sincerely,

 /s/ Pedro Arnt

 Name: Pedro Arnt

 Title:
Executive Vice President and Chief Financial Officer

cc:
Jacobo Cohen Imach

 Pedro Arnt

Marcelo Melamud

August 18, 2014

Via E -mail
Pedro Arnt
Chief Financial Officer
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc .
 Form 10 -K for the Fiscal Year Ended December 31, 201 3
 Filed March 3, 2014
 File No. 001 -33647

Dear Mr. Arnt :

We have reviewed your letter dated July 18, 2014 in connection with the above -
referenced filing an d 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 letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have  additional comments .  Unless otherwise noted , where
prior comments are referred to they refer to our letter dated July 3, 2014 .

Form 10-K for the Fiscal Year Ended December 31, 2013

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of operations

Net revenues, page 59

1. We note your response to prior comment 1. Please clarify how your disclosures on page
60 comply with the requirements of Item 303(a)(3)(iii) of Regulation S -K and Section
III.D of SEC Release No. 33 -6835.  In this regard, for each of your segments, you
attribute increases in your marketplace revenues to increases in unit sales and growth in
fees, without quantifying the amount that each source contributed to the change. While

Mr. Pedro Arnt
Mercado Libre, Inc.
August 18, 2014
Page 2

 we note that your prices are fixed p ercentages of the prices which the sellers post on your
web site, and you have not changed such percentages significantly, the increase in your
revenues as a result of increases in seller prices represents a source of change that should
be quantified, if m aterial.
You may contact Laura Veator, Staff Accountant , at (202) 551 -3716, or Christine Davis,
Assistant Chief Accountant, at (202) 551 -3408, if you have questions regarding comments on the
financial statements and re lated matters. If you require further  assistance, do not hesitate to
contact me at (202) 551 -3488.

Sincerely,

 /s/ Patrick Gilmore for

Stephen Krikorian
Accounting Branch Chief

cc:   Marcelo Melamud
 Chief Accounting Officer

CORRESP
1
filename1.htm

CORRESP

 MERCADOLIBRE, INC.

ARIAS 3751, 7TH FLOOR

BUENOS AIRES, C1430CRG

 ARGENTINA

 TEL +5411 — 4640 — 8000

PEDRO ARNT

 DIRECT DIAL: +5411 — 4640 — 8006

 EMAIL:
pedro@mercadolibre.com

 July 18, 2014

Mr. Stephen Krikorian

 Accounting Branch Chief

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549-4561

Re:
MercadoLibre, Inc.

 Form 10-K for Fiscal Year Ended December 31, 2013

Filed March 3, 2014

Form 8-K

 Filed
May 16, 2014

 File No. 001-33647

Dear Mr. Krikorian,

 MercadoLibre, Inc., a Delaware
corporation (the “Company,” “MercadoLibre”, “we” or “us”), is transmitting for filing the Company’s responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of
the Securities and Exchange Commission (the “SEC”), with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2013 (the “Form 10-K”) filed on March 3, 2014 and to the
Company’s Form 8-K filed on May 16, 2014 (the “Form 8-K”) (File No. 001-33647), contained in your comment letter dated July 3, 2014 (the “Comment Letter”).

For convenience of reference, each Staff comment contained in the Comment Letter is reprinted below in italics, numbered to correspond with the paragraph
number assigned in the Comment Letter and is followed by the corresponding response of the Company.

 Form 10-K for Fiscal Year Ended December 31, 2013

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of operations

 Net revenues, page 59

1.
Tell us what consideration you gave to explain your increases in revenues by segment in the local currency, including quantifying the extent to which increases are due to changes in prices and changes in unit sales.
In this regard, we note that inflation has had a significant impact on several of your geographies. Further, to the extent that there are significant differences between the rate of inflation in these geographies and the rate of currency devaluation
against the U.S. dollar, in either your revenue or expenses, tell us what consideration you gave to disclosing this.

Response: In response to the Staff’s comment, we advise the Staff that we have considered that an explanation of revenues by segment in
local currency was unnecessary because we believed that the explanations provided for each segment for amounts in US dollars allowed for an understanding of the main variables affecting our business in the majority of our segments. We also wish to
advise the Staff that, in 2013, in the majority of our segments, with Venezuela as the exception, the effect on our revenues of any difference between inflation and devaluation of local currencies was not material.

In the specific case of Venezuela, the effect of the change in the exchange rate used to translate the financial statements in 2013 against 2012 had an
approximate effect of a 17% reduction on revenues, while average prices posted by sellers during 2013 -which we do not control- increased, presumably 56%, because of inflation in that country in 2013.

With respect to changes in prices of our services such as final value fees and payment fees, our prices are a fixed percentage on the prices which the sellers
post in our web site and we have not changed such percentages significantly in any of our most relevant reportable segments during 2013. Consequently, on page 60 of our Form 10-K we have disclosed in which of our main segments the total increase in
revenues was mainly caused by increases in unit volume. Such increases in quantities derived mainly from unit volume increases in: (a) “New paid listings” – which are the number of listings on which we have charged an optional
feature fee - (b) “Items sold” - which are the number of units sold through our platform in all segments - and (c) in the number of Financing and Off-platform Payments transactions in Brazil and Argentina.

Finally, we advise the Staff that in future filings, we will explain the potential impact of inflation on the local currency increase in net revenues in each
country to the extent that there are material differences between the rate of inflation in these geographies and the rate of currency devaluation against the U.S. dollar.

Quantitative and Qualitative Disclosures About Market Risk, page 73

2.
 We note your disclosures on page 106 regarding the controls and restrictions on the acquisition of foreign currencies in Argentina, and your
disclosure on page 145 regarding

the increase in the Argentinean peso exchange rate against the U.S. dollar during January 2014. Tell us what consideration you gave to disclosing summarized financial information and the net
monetary assets and liabilities held by your subsidiary in Argentina, as well as sensitivity information regarding potential impacts of changes in exchange rates.

Response: In response to the Staff’s comment, we advise the Staff that we considered that providing more detailed financial information or
additional sensitivity information was not necessary because: i) we had disclosed the effect of the subsequent devaluation on pages 50 and 145 of the 2013 Form 10-K, ii) in our view, controls and restrictions in Argentina were not so significant to
require additional disclosures, and iii) we estimated that, having the Peso/US dollar exchange rate increased in early 2014, our expectation was of more moderate movements in such exchange rate during the rest of the year.

Although certain authorizations are required by the Argentine Central Bank or Tax authorities, there is no legal ban on the acquisition of U.S. dollars for
dividend distribution and payment of imports. We have not requested authorization to purchase U.S. dollars for dividend distributions. In addition, we have been able to purchase U.S. dollars to make payments abroad in U.S. dollars as needed. Based
on current conditions, the Company does not expect the current exchange controls and restrictions to have a material adverse effect on its business plans in Argentina or on its overall business and financial condition.

In addition, the exchange rate between the U.S. dollar and Argentine Peso has not changed significantly since January 2014 to date.

For these reasons, we concluded that the disclosure of summarized financial information and the net monetary assets and liabilities held by our Argentine
subsidiary was unnecessary. We will continually re-assess the above situations and if those facts and circumstances or our expectations relating to such risks in Argentina change, we will provide summarized financial information and net monetary
assets and liabilities of our Argentina segment.

 In connection with the sensitivity analysis regarding potential impacts of changes in exchange rates in
Argentina specifically, we advise the Staff that in future filings we will include in our sensitivity analysis the effects on our Other Comprehensive Income of a local currency devaluation of 10% against the U.S. dollar related to the exposure of
our Argentine subsidiaries.

 Form 8-K filed May 16, 2014

3.
Your disclosure indicates that you are reviewing your long-lived assets, goodwill and intangible assets with indefinite useful life for impairment considering the lower U.S. dollar-equivalent cash flows now expected
from your Venezuelan business as well as considering their “current expected use in the new context”. Please explain what you mean by “current expected use in the new context” and explain how this impacts the recoverability of
your assets.

 Response: In May and October 2013, we acquired two office properties in Venezuela, a country with
high operational and financial growth rates for us during the last years. Our Net Revenues and Direct Contribution grew on average in U.S. dollars during the last 3 years by 59.5% and 72.0% annually, respectively. In that context, we intended to use
both office spaces to support the expected future growth of our operations in that country.

 However, during the last months, the prevailing political and
economic conditions in Venezuela have continued to deteriorate and new currency exchange regulations were issued, which have implied that our Venezuelan net revenues and the contribution of our Venezuelan operations to the overall business were and
will be significantly lower than under the prior conditions as described on pages 24, 25, 43 and 48 of the Form 10-K. Given this situation, management has re-assessed the expected business growth of our Venezuelan operations and has decided to
adopt greater flexibility on its Venezuelan operating model, limiting the property investments that will be dedicated to support our main operating activities in that country.

In this new context, the current intended use of both office spaces is to generate rental income and, eventually, consider opportunities for disposal of these
assets if real estate market conditions are favorable.

 Consequently, we are currently assessing these properties for impairment taking into consideration
undiscounted cash flows from future rental income and eventual disposition of the two office properties, instead of considering the use of these properties for our own business growth, as we did in prior quarters. The estimated impairment mentioned
in our Form 8-K corresponds to the write down of the carrying value of the abovementioned properties to their fair value. Those are the only assets which expected use changed in the new context and for which we currently estimate that the
recoverable amount would be affected. In our impairment test of other assets (including Goodwill and Intangible assets) of the reporting unit we take into account the office property balances as adjusted to their recoverable amounts and our
estimations of the future performance of our business in Venezuela as explained in the next paragraph.

 We believe that our underlying business in
Venezuela is competitively well-positioned and continues to show solid growth in terms of units sold despite the fact the economic conditions in the Venezuelan economy remain difficult. We believe that as these economic conditions start to improve
our business in Venezuela will benefit accordingly.

 The Company hereby acknowledges that:

•

the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•

Staff comments or changes to disclosure in response to Staff comments do not foreclose the SEC from taking any action with respect to the filing; and

•

the Company may not assert Staff’s comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.

 If you have any questions or comments regarding the foregoing, please contact our Chief Accounting Officer,
Marcelo Melamud at +5411 4640 8053, marcelo.melamud@mercadolibre.com. We look forward working with you on these matters.

Sincerely,

 /s/ Pedro Arnt

Name: Pedro Arnt

Title: Executive Vice President and Chief Financial Officer

cc:
Jacobo Cohen Imach

 Pedro Arnt

Marcelo Melamud

July 3, 2014

Via E -mail
Pedro Arnt
Chief Financial Officer
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc .
 Form 10 -K for the Fiscal Year Ended December 31, 201 3
 Filed March 3, 2014
 Form 8 -K
Filed May 16, 2014
File No. 001 -33647

Dear Mr. Arnt :

We have reviewed your filing s 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 th is letter within ten business days by amending your filing s, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe  an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing s and the information you provide in
response to these comment s, we may have  additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2013

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of operations

Net revenues, page 59

1. Tell us what consideration you gave to explaining your increases in revenues by segment
in the local cur rency, including quantifying the extent to which increases are due to
changes in prices and changes in unit sales. In this regard, we note that inflation has had a
significant impact on several of your geographies. Further, to the extent that there are

Mr. Pedro Arnt
Mercado Libre, Inc.
July 3, 2014
Page 2

 significant differences between the rate of inflation in these geographies and the rate of
currency devaluation against the U.S. dollar, in either your revenue or expenses, tell us
what consideration you gave to disclosing this.

Quantitative and Qualitative  Disclosures About Market Risk, page 73

2. We note your disclosures on page 106 regarding the controls and restrictions on the
acquisition of foreign currencies in Argentina, and your disclosure on page 145 regarding
the increase in the Argentinean peso exch ange rate against the U.S. dollar during January
2014. Tell us what consideration you gave to disclosing summarized financial
information and the net monetary assets and liabilities held by your subsidiary in
Argentina, as well as sensitivity information r egarding potential impacts of changes in
exchange rates.

Form 8-K filed May 16, 2014

3. Your disclosure indicates that you are reviewing your long -lived assets, goodwill and
intangible assets with indefinite useful life for impairment considering the lower  U.S.
dollar -equivalent cash flows now expected from your  Venezuelan business as well as
considering their “current expected use in the new context.”  Please explain what you
mean by “current expected use in the new context” and explain how this impact s the
recoverability of your assets.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the  federal securities laws of the United States.

Mr. Pedro Arnt
Mercado Libre, Inc.
July 3, 2014
Page 3

 You may contact Laura Veator, Staff Accountant , at (202) 551 -3716, or Christine Davis,
Assistant Chief Accountant, at (202) 551 -3408, if you have questions regarding comments on the
financial statements and  related matters. If you require further assistance, do not hesitate to
contact me at (202) 551 -3488.

Sincerely,

 /s/ Stephen Krikorian

Stephen Krikorian
Accounting Branch Chief

cc:   Marcelo Melamud
 Chief Accounting Officer

August 5, 2013

Via E -mail
Pedro Arnet
Executive VP & CFO
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc
 Form 10-K for Fiscal Year Ended December 31, 201 2
 Filed February 28, 201 3
File No. 001-33647

Dear Mr. Arnet :

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We urge all per sons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing  include s the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/  Kathleen Collins

Kathlee n Collins
Accounting Branch Chief

cc:   Marcelo Melamud
 Chief Accounting Officer

CORRESP
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Correspondence

 CONFIDENTIAL TREATMENT REQUESTED BY MERCADOLIBRE, INC.

MERCADOLIBRE, INC.

 ARIAS 3751,
7TH FLOOR

BUENOS AIRES, C1430CRG

 ARGENTINA

 TEL +5411 — 4640 — 8000

 PEDRO ARNT

DIRECT DIAL: +5411 — 4640 — 8006

 EMAIL: pedro@mercadolibre.com

 July 9, 2013

 Ms. Kathleen Collins

Accounting Branch Chief

 United States
Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549-4561

Re:
MercadoLibre, Inc.

Form 10-K for Fiscal Year Ended December 31, 2012

Filed February 28, 2013

File No. 001-33647

 Dear
Ms. Collins,

 MercadoLibre, Inc., a Delaware corporation (the “Company,” “MercadoLibre”,
“we” or “us”), is transmitting for filing the Company’s responses (this “Response”) to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange
Commission (the “SEC”), with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2012 (the “Form 10-K”) filed on February 28, 2013 (File No. 001-33647), contained in your
comment letter dated June 24, 2013 (the “Additional Comment Letter”) in response to our letter dated May 23, 2013 (the “Initial Response”), which we provided in response to your comment letter dated May 9, 2013
(the “Original Comment Letter”).

 Because of the commercially sensitive nature of certain information contained in
this Response, this submission is accompanied by a request for confidential treatment for selected portions of this Response. The Company has filed a separate letter with the Office of Freedom of Information and Privacy Act (the “FOIA
Office”) in connection with the confidential treatment request, pursuant to Rule 83 of the SEC’s Rules on Information and Requests [17 C.F.R. § 200.83] (“Rule 83”). For the Staff’s reference, the Company has enclosed a
copy of its letter to the FOIA Office (the “Request”) with this copy of the correspondence marked to show the portions redacted from the version filed via EDGAR and for which the Company is requesting confidential treatment.

 M-001

 CONFIDENTIAL TREATMENT REQUESTED BY MERCADOLIBRE, INC.

 In accordance with Rule 83, the Company requests confidential treatment of (a) the
marked portions (the “Confidential Information”) of this Response and (b) the accompanying Request (collectively, the “Confidential Material”). Please promptly inform the undersigned of any request for disclosure of the
Confidential Material made pursuant to the Freedom of Information and Privacy Act or otherwise so that the undersigned may substantiate the foregoing request for confidential treatment in accordance with Rule 83.

In accordance with Rule 83, this Response has been clearly marked with the legend “Confidential Treatment Requested by MercadoLibre,
Inc.” and each page is marked for the record with the identifying numbers and code “M-001” through “M-006.”

 Pursuant to Rule 83, a copy of the Request (but not this Response) also is being delivered to the SEC’s FOIA Office.

 For convenience of reference, each Staff comment contained in the Additional Comment Letter is reprinted below in italics, numbered to correspond with the paragraph number assigned in your comment letter
and is followed by the corresponding response of the Company.

 Form 10-K for Fiscal Year Ended December 31, 2012

 Management’s Discussion and Analysis of Financial Condition and Results of Operations

Critical Accounting Policies and Estimates

 Foreign Currency Translation, page 49

1.
We note in your response to prior comment 1 you state that there is no legal prohibition in Venezuela in connection with dividend distributions. However, it appears
based on your response that the only means by which you are currently able to obtain U.S. dollars to make dividend distributions is through the CADIVI. Please clarify whether this is the case, and if so, tell us what consideration you gave to
disclosing this. In addition, we note that no dividends were declared by your Venezuelan subsidiary during fiscal 2012. Please explain why and to the extent this is due to potential delays in obtaining CADIVI approval in a timely manner, tell us
whether you considered addressing the impact this process may have on your liquidity. Lastly, please tell us what consideration you gave to disclosing the factors that you provide in your response regarding the reasons why you expect that the
current restrictions will not have a material adverse effect on your overall business plan in the long run.

Response: We confirm to the Staff that the only means in Venezuela by which we are currently able to obtain U.S. dollars to make dividend
distributions in that currency is through the CADIVI.

 M-002

 CONFIDENTIAL TREATMENT REQUESTED BY MERCADOLIBRE, INC.

We have been disclosing in our forms 10-K the existence of the CADIVI system since its inception and have been providing expanded detail about subsequent developments relating to exchange
regulations in Venezuela. We have also disclosed that during 2010 and 2011, the lack of the CADIVI’s approval did not restrict our ability to distribute dividends for fiscal years 2008, 2009 and 2010 by using existing cash balances held in the
U.S. bank accounts of our Venezuelan subsidiaries; and that no dividends were declared during the fiscal year ended December 31, 2012. Finally, we disclosed that the Venezuelan government maintains the restrictions with respect to obtaining
U.S. dollars for the purpose of dividend distributions.

 We advise the Staff that in future filings we will specifically
include language clarifying that, in Venezuela, the CADIVI system is the only means by which we are currently able to obtain U.S. dollars to make dividend distributions.

 We respectfully advise the Staff that we did not request approval of the CADIVI for the acquisition of U.S. dollars for dividend distributions, either during 2012 or during 2013 to date. Our current
strategy is to expand our operations in Venezuela through reinvesting our accumulated earnings in lieu of declaring dividend distributions. We, therefore, have been analyzing and investing in office property and customer reception centers aiming to
strengthen our leadership position in Venezuela. In that sense, we have invested approximately $20.6 million, or Bolivares Fuertes 130.0 million.

 We are of the opinion that, considering our overall liquidity as of December 31, 2012, the current restrictions on the distribution of dividends in Venezuela would not have a material adverse effect
on our consolidated liquidity, which as of December 31, 2012 amounted to $281.1 million. As disclosed in our Form 10-K, as of December 31, 2012, the cash and investments that our Venezuelan subsidiaries held in Bolivares Fuertes amounted
to approximately 15.5% of our consolidated cash and investments. Given the relatively small portion that such amount represents, we do not expect any material impact in the overall liquidity and business plans of MercadoLibre, Inc., or on our
dividend distribution plan during the next twelve months.

 Furthermore, we advise the Staff that in future filings we will
disclose the factors that we provided to the Staff in our prior response to the Original Comment Letter, regarding the reasons why we expect that the current restrictions will not have a material adverse effect on our overall business plan in the
long run.

2.
We note in your response to prior comment 2 you state that because of the manner in which foreign exchange regulations have been implemented by the Venezuelan
government as of the date of your Form 10-K for the year ended December 31, 2012, it did not imply the deconsolidation risk to be a material risk at the time of that filing. Please explain to us the specific factors that you considered as it
relates to deconsolidation risk and describe further the factors that were in place at December 31, 2011, which indicated deconsolidated was a significant risk at such time.

 M-003

 CONFIDENTIAL TREATMENT REQUESTED BY MERCADOLIBRE, INC.

 Response: In response to the Staff’s comment, we advise the Staff that in our 2010
and 2011 forms 10-K we disclosed that if volume restrictions on foreign exchange imposed by the government worsened significantly or new regulations were implemented which impacted our ability to settle transactions in foreign currencies, we could
be required to deconsolidate our Venezuelan operations for accounting purposes. In considering whether a material risk of deconsolidation existed at those times, we assessed the level of uncertainty that in our judgment we might face in the future,
including, among other factors, then current and expected regulations and economic situation, and whether volume restrictions on exchange activity were, and were expected to be, in our judgment, an “other-than-temporary lack of
exchangeability” of foreign currency, all of which could in the future trigger significant uncertainty about our ability to control our business in Venezuela. We considered for that assessment the guidance in ASC 810-10-15-10 and 830-20-30-2,
and the financial and operating situation of our investment in Venezuela at each of those years. Since the mere existence of exchange restrictions does not in and of itself create a presumption that an entity should deconsolidate its foreign
operations, we considered in our judgment our specific facts, circumstances and expectations as of each filing date.

 In
May 2010, the Venezuelan government had imposed additional foreign exchange controls under a newly implemented regulatory system, controlled by the Central Bank of Venezuela, and among other things, the new exchange rate system began to
prohibit trading of foreign currencies through the formerly allowed, parallel market and started to impose volume restrictions and passed new rulings with strict criminal and economic sanctions on the use of methods other than those officially
designated for the exchange of Venezuelan currency with other currencies. Considering that those new regulations would limit our Venezuelan subsidiaries’ access to U.S. dollars, that, at that time, we operated with certain suppliers which were
to be paid in foreign currencies and the possible effects on the general business environment in Venezuela, we concluded that in combination with potential other government regulations, the situation could worsen to an extent that might have implied
in the future an uncertainty so severe as to cast a significant doubt on our ability to control that foreign investment. Since the effect of such new regulations on the economy (which could in turn lead to further regulations) and specifically the
effect on our business and business plans can only be seen and monitored as time passes, during 2011 we monitored the situation and decided that the risk was still material.

 During 2012 we continued monitoring the above-mentioned effects and concluded that after a considerable period of time, the evolution of our business was positive (both in terms of growth and
profitability) and the effects of the Venezuelan macroeconomic situation and related regulations showed no material negative effect on our ability to control our business as we had foreseen in our plans. We were also able to take some actions, which
to a certain extent allowed us to reduce our foreign currency needs to manage our operations. All of the above led us to conclude that our expectation was of a reduced likelihood of future uncertainties that could lead to a loss of our ability to
control our subsidiary. Such assessment was aligned with our other disclosure in our Form 10-K that, despite the increasing restrictions on the ability of our Venezuelan subsidiaries to obtain U.S. dollars for the purpose of distributing dividends
to us or our other subsidiaries, we did not expect that the then current restrictions would have a material adverse effect on our business plans, in Venezuela or on our overall business, financial condition or results of operations.

 M-004

 CONFIDENTIAL TREATMENT REQUESTED BY MERCADOLIBRE, INC.

 Results of Operations

 Year Ended December 31, 2012 compared to year ended December 31, 2011, Page 61

3.
We note your response to prior comment 3 where you indicate that the various service categories that make up your revenue streams such as ad sales, real estate,
motors, off platform payment fees, and financing fees represent, on an individual basis, a small percentage of your net revenues. However, we note your disclosure on page 61 that non-marketplace revenues from financing and off-platform payments grew
37% in the year ended December 31, 2012 as compared to the same period in 2011, mainly as a consequence of a 36.2% increase in total payments volume paid using MercadoPago. Please clarify the dollar value of revenues generated from financing
and off-platform payment fees and tell us what consideration you gave to also separately disclosing these revenues considering you disclose other metrics relating to these revenue sources. Please also tell us what consideration you gave to including
this disclosure in your segment discussion.

 Response: In response to the Staff’s request, the dollar
amount of the revenues generated from financing and off-platform payment fees were as follows:

 Off-platform payment

 & Financing fees

2012

2011

Change from 2011
to 2012 ($)

Change from 2011
to 2012 (%)

 Off-platform payment fees

**

**

**

**

 Financing fees

**

**

**

**

 Total Off-platform payment & Financing fees

**

**

**

**

**
Confidential Treatment Requested

 Financing and off-platform payment fees were the revenue sources that have changed more significantly within our Non-Marketplace revenue stream during the reported years, as such we have included related
metrics to explain the reason of those changes. In the event that other revenue sources, within Non-Marketplace revenue stream, change significantly in the future, we will include the appropriate explanation for those changes in accordance with the
requirements of Item 303 of Regulation S-K.

 In addition, as mentioned in our Initial Response to the Staff’s
comment 6 of the Original Comment Letter, we advise the Staff that, in future fillings, we will disclose our revenues generated by Marketplace and Non-Marketplace Services for each of our geographic segments (similar to the format provided in our
Initial Response to the Staff’s comment 3 of the Original Comment Letter) and will expand our discussions relating to changes in those service categories and their impact on our net revenues for each of our geographic segments.

 M-005

 CONFIDENTIAL TREATMENT REQUESTED BY MERCADOLIBRE, INC.

 The discussion of Non-Marketplace Services will include its revenue sources, such as Ad Sales, Motors,
Real Estate, off-platform payment fees, financing fees, etc., to the extent there are material changes in such revenue sources.

Item 11. Executive Compensation (Incorporated by Reference from Definitive Proxy Statement Filed April 26, 2013)

Executive Compensation, page 21

4.
In the first two bullet points on page 27, you disclose certain company performance measures that are based on adjustments “as determined by the compensation
committee.” In future filings, please revise to disclose how the adjustments are calculated so that your disclosure complies with Instruction 5 to Item 402(b) of Regulation S-K.

Response: We acknowledge the Staff’s comment and we advise the Staff that the 2012 performance measures mentioned by the Staff have
not been affected by any adjustments. In future filings we will clarify the nature of adjustments determined by the compensation committee, if any.

 The Company hereby acknowledges that:

•

 the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•

 Staff comments or changes to disclosure in response to Staff comments do not foreclose the U.S. Securities and Exchange

June 24, 2013

Via E -mail
Pedro Arnet
Executive VP & CFO
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc
 Form 10-K for Fiscal Year Ended December 31, 201 2
 Filed February 28, 201 3
File No. 001-33647

Dear Mr. Arnet :

We have reviewed your letter dated May 23, 2013 in connection with the above -
referenced filing an d have the following comment s.  In our comment s, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response .  If you do not believe our comment s apply  to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comment s, we may have  additional comments.   Unless otherwise noted , where
prior comments are referred to they refer to our letter dated May 9 , 2013 .

Form 10 -K for Fiscal Year Ended December 31, 201 2

Management’s Discussion and Analysis of  Financial Condition and Results of Operations

Critical Accounting Policies and Estimates

Foreign Currency Translation, page 49

1. We note in your response to prior comment 1 you state that there is no legal prohibition
in Venezuela in connection with divi dend distributions.  However, it appears based on
your response that the only means by which you are currently able to obtain U.S. dollars
to make dividend distributions is through the CADIVI.  Please clarify whether this is the
case, and if so, tell us wh at consideration you gave to disclosing this. In addition, we note

Mr. Pedro Arnet
MercadoLibre, Inc.
June 24 , 2013
Page 2

 that no dividends were declared by your Venezuelan subsidiary during fiscal 2012.
Please explain why and to the extent this is due to potential delays in obtaining CADIVI
approval in a tim ely manner, tell us whether you considered addressing the impact this
process may have on your liquidity.  Lastly, please tell us what consideration you gave to
disclosing the factors that you provide in your response regarding the reasons why you
expect t hat the current restrictions will not have a material adverse effect on your overall
business plan in the long run.

2. We note in your response to prior comment 2 you state that because of the manner in
which foreign exchange regulations have been implemen ted by the Venezuelan
government as of the date of your Form 10 -K for the year ended December 31, 2012, it
did not imply the deconsolidation risk to be a material risk at the time of that filing.
Please explain to us the specific factors that you consider ed as it relates to
deconsolidation risk and describe further the factors that were in place at December 31,
2011, which indicated deconsolidated was a significant risk at such time.

Results of Operations

Year Ended December 31, 2012 compared to year e nded December 31, 2012 , Page 61

3. We note your response to prior comment 3 where you indicate that the various service
categories that make up your revenue streams such as ad sales, real estate, motors, off
platform payment fees, and financing fees represent, on an individual basis, a small
percen tage of your net revenues.  However, we note your disclosure on page 61 that non -
marketplace revenues from financing and off -platform payments grew 37% in the year
ended December 31, 2012 as compared to the same period in 2011, mainly as a
consequence of a  36.2% increase in total payments volume paid using MercadoPago.
Please clarify the dollar value of revenues generated from financing and off -platform
payment fees and tell us what consideration you gave to also separately disclosing these
revenues consid ering you disclose other metrics relating to these revenue sources.  Please
also tell us what consideration you gave to including this disclosure in your segment
discussion.

Item 11. Executive Compensation (Incorporated by Reference from Definitive Proxy Statement
Filed April 26, 2013)

Executive Compensation, page 21

4. In the first two bullet points on pag e 27, you disclose certain company performance
measures that are based on adjustments “as determined by the compensation
committee.”   In future filings, please revi se to disclose how the adjustments are
calculated so that your disclosure complies with Instruction 5 to Item 402(b) of
Regulation S -K.

Mr. Pedro Arnet
MercadoLibre, Inc.
June 24 , 2013
Page 3

You may contact Laura Veator , Staff Accountant , at (202) 551 -3716  if you have
questions regarding comments on the finan cial statements and re lated matters.  If you have any
other questions, please contact Gabriel Eckstein, Attorney -Advisor, at (202) 551 -3286 or Maryse
Mills -Apenteng, Special Counsel, at (202) 551 -3457.   If you require further assistance, do not
hesitate to  contact me at (202) 551 -3499.

Sincerely,

 /s/ Kathleen Collins

Kathleen Collins
Accounting Bra nch Chief

cc:   Marcelo Melamud
 Chief Accounting Officer

CORRESP
1
filename1.htm

CORRESP

 MERCADOLIBRE, INC.

ARIAS 3751, 7TH FLOOR

 BUENOS AIRES, C1430CRG

 ARGENTINA

TEL +5411 — 4640 — 8000

PEDRO ARNT

 DIRECT
DIAL: +5411 — 4640 — 8006

EMAIL: pedro@mercadolibre.com

May 23, 2013

 Ms. Kathleen Collins

 Accounting Branch Chief

 United
States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549-4561

Re:
MercadoLibre, Inc.

Form 10-K for Fiscal Year Ended December 31, 2012

Filed February 28, 2013

File No. 001-33647

 Dear
Ms. Collins,

 MercadoLibre, Inc., a Delaware corporation (the “Company,” “MercadoLibre”, “we” or
“us”), is transmitting for filing the Company’s responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”), with respect to the
Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2012 filed on February 28, 2013 (File No. 001-33647), contained in your comment letter dated May 9, 2013 (the “Comment Letter”).

 For convenience of reference, each Staff comment contained in the Comment Letter is reprinted below in italics, numbered to correspond with
the paragraph number assigned in your comment letter and is followed by the corresponding response of the Company.

 Form 10-K for Fiscal Year Ended December 31, 2012

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Critical Accounting Policies and Estimates

 Foreign Currency Translation, page 49

1.
We note that no dividends were declared by your Venezuelan subsidiaries during the year ended December 31, 2012. Tell us if you were restricted from making
distributions from these subsidiaries during 2012 as a result of the SITME regulations in place. Also, tell us whether you expect the elimination of the SITME on February 9, 2013 and the implementation of the SICAD on March 19, 2013 to
restrict your Venezuelan subsidiaries’ ability to make dividend distributions in the future. While we note your discussion of volume restrictions imposed by the SITME, it is unclear to what extent these restrictions impacted your ability to
make distributions. Please tell us what consideration you gave to disclosing these factors. Also, to the extent that you believe these restrictions will not have a material adverse effect on your overall business as you currently indicate on page
51, tell us your consideration to further enhance your disclosure to explain such conclusions.

 Response: In
response to the Staff’s comment, we respectfully advise the Staff that no legal prohibition exist in Venezuela, in connection with dividends distribution or with the remittance of dividends abroad and that the SITME regulations did not prevent
our Venezuelan subsidiaries from declaring and paying dividends in 2012. We further advise the Staff that the acquisition of U.S. dollars for dividends remittance abroad in foreign currency was not within the scope of SITME or the SICAD, but falls
within the scope of CADIVI, as disclosed on pages 25 and 77 to our Form 10-K for fiscal year ended December 31, 2012 filed on February 28, 2013 (Form 10-K). As discussed in our Form 10-K, SITME imposed limits to the foreign exchange
trading activity relating to the acquisition of U.S. dollars to import goods, services or capital inputs for entities domiciled in Venezuela.

Foreign currency exchange regulations have continued to be subject to changes by the Venezuelan government. In that regard, we have included additional
information about subsequent developments in our Form 10-Q as of March 31, 2013. We will continue assessing the effects of additional developments for further disclosure in our future filings.

In response to the Staff’s request, we advise the Staff that we continue to believe that the current restrictions to acquire U.S. dollars will not
have a material adverse effect on our overall business plan in the long run, considering that our Venezuelan operations are not dependent on third parties’ imported goods or services. Moreover, because our Venezuelan business has demonstrated
consistent growth that we believe is sustainable for the near future, our current plans contemplate continued reinvestment in our Venezuelan businesses with the proceeds of our business in that country.

Finally, given the current availability of cash from our various geographic segments, we do not expect that the current Venezuelan foreign exchange
situation will affect our ability to distribute cash dividends from MercadoLibre, Inc. to its stockholders as planned.

2.
We note the risk factor disclosure on page 27 of your December 31, 2011 Form 10-K where you state, if current volume restrictions on foreign exchange imposed by
the government worsen significantly or new regulations are implemented, which impact your ability to settle transactions at either the official rates or SITME rate, you could be required to deconsolidate your Venezuelan operations for accounting
purposes. Please tell us whether deconsolidation of your Venezuelan subsidiary is still a potential risk to the company and if so, tell us why you have not included a discussion of this risk in your current Form 10-K. Also, tell us what impact the
elimination of the SITME in February 2013 and the creation of the SICAD in March 2013 will have on the accounting for your Venezuelan operations. As part of your response, please tell us how your current inability to access the auction process by
which acquisition of foreign currencies will be made under the new system impacts the accounting for your Venezuelan operations.

 Response: We advise the staff that while we continue to believe that we are subject to the risk that “Local currencies used in the conduct of our business are subject to depreciation,
volatility and exchange controls.”, as we described in our Form 10-K, because of the manner in which foreign exchange regulations have been implemented by the Venezuelan government as of the date of our Form 10-K for the year ended
December 31, 2012, it did not imply the deconsolidation risk to be a material risk at the time of that filing. Accordingly, we determined that it was not necessary to include a risk factor to discuss the potential risk of deconsolidation.
Through the SITME mechanism, we have been able to obtain U.S. dollars for payments of intercompany services, and those restrictions have not altered our growth plans in Venezuela.

 In regards to the impact of the elimination of the SITME on the accounting of our Venezuelan operations, since exchange rate information resulting from auctions completed through the new mechanism SICAD
is not publicly available, there is only one official and legal exchange rate in Venezuela. That exchange rate was set at 6.3 Bolivares Fuertes per U.S. dollar on February 9, 2013 by the Venezuelan government. As a result, from that date, our
net monetary assets have been re-measured using the official exchange rate.

 Finally, we advise the Staff that we expect the government to
implement a mechanism that will allow us to obtain (either SICAD or any other mechanism implemented by the government) U.S. dollars for the payment of foreign services by our Venezuelan subsidiaries. If the corresponding government body begins to
make publicly available the exchange rate, resulting from SICAD or any other equivalent mechanism, and we are able to access that mechanism to obtain U.S. dollars for our operations, we will assess using those published exchange rates for
re-measurement purposes based on the actual facts and circumstances at that time.

 Results of Operations

 Year Ended December 31, 2012 compared to year ended December 31, 2012, Page 61

3.
We note your disclosure of the percentage increases in gross merchandise volume, financing and off-platform payments, and classified and add sales revenues. Please
tell us what consideration you gave to quantifying the dollar amount for each of these revenue streams and how changes in such amounts and the related metrics impacted your revenues. We refer you to Item 303(a)(3)(iii) of Regulation S-K and
Section III.D of SEC Release No. 33-6835.

 Response: In response to the Staff’s comment, we advise
that we considered the rules prescribed by Item 303(a)(3)(iii) of Regulation S-K and Section III.D of SEC Release No. 33-6835, when preparing our disclosures relating to material changes in our net revenues. In preparing this disclosure,
we considered those metrics that we believe are most relevant and necessary to allow readers to understand our financial condition, changes in financial condition and results of operations and have included those metrics in the “Management
Discussion and Analysis of Financial Condition and Results of Operations” section of our Form 10-K for the fiscal year ended December 31, 2012. We also advise the Staff that we have historically quantified gross merchandise volume on a
consolidated basis in our prior periodic reports. That said, we acknowledge the Staff’s comment and we advise that in future filings we will quantify the dollar amount of our Marketplace and Non-Marketplace Services revenues in the format set
forth below and will expand our discussions relating to changes in those service categories and their impact on our net revenues. We further advise the Staff that we believe disclosure of revenues for our Marketplace and Non-Marketplace Services is
the most appropriate format for providing this disclosure (as compared to providing quantitative disclosures for each individual service category that make up these revenue streams, such as Ad Sales, Real Estate, Motors, Off Platform Payment fees,
Financing Fees, etc.), as the categories are comprised generally of a number of service categories (or types of services) that are ancillary to our Marketplace Services and represent, on an individual-basis, a small percentage of the Company’s
net revenues.

 The breakdown of our consolidated net revenues by each of our Marketplace and Non-Marketplace Services categories for the years
ended December 31, 2012, 2011 and 2010 is as follows:

 Revenue streams

2012

2011

2010

 Marketplace

261,997,020

217,932,814

132,742,374

 Non-Marketplace Services (*)

111,604,474

80,998,811

83,973,339

 Total

373,601,494

298,931,625

216,715,713

(*)
 Includes Ad Sales,
Real Estate, Motors, Financing Fees, Off-platform Payment Fees, etc.

4.
We note your disclosure of growth in net revenues measured in local currencies. Please tell us what consideration you gave to also disclosing changes in expenses and
segment revenues measured in local currencies.

 Response: In response to the Staff’s comment, we advise that we have considered
disclosing such changes as noted in the comment but determined that by providing the year-over-year consolidated net revenue growth in local currencies, readers of our Form 10-K would have an understanding of the foreign currency effects on our net
revenues. However, we acknowledge the Staff’s comment and advise that in future filings we will disclose changes in segment revenues measured in local currencies. Finally, we consider that providing revenue growth in local currencies will be
sufficient information for readers of our Form 10-K to calculate expense growth measured in local currencies since they typically follow the same change pattern.

5.
Please tell us what consideration you gave to disclosing explanations for changes in your segment net revenues and direct costs. We refer you to Item 303(a) of
Regulation S-K and Section III.F.1 of SEC Release No. 33-6835.

 Response: In response to the Staff’s
comment, we advise that we considered the rules prescribed by Item 303(a) of Regulation S-K and Section III.F.1 of SEC Release No. 33-6835 when preparing disclosures relating to material changes in our segment net revenues and direct costs
and determined that the disclosures included in the “Management’s Discussion and Analysis of Financial Condition and Results of Operations” section of our Form 10-K provide the information that we believe is necessary to an
understanding of our financial condition, changes in our financial condition and results of operations. Particularly, it is our view that an explanation of material changes on a consolidated basis provides a reader with the most relevant information
regarding our business and provides the reader with an understanding of the business as a whole. However, we acknowledge the Staff’s comment, and considering that we are involved in a continuously evolving business, in future filings we will
provide additional information with respect to changes in our segment net revenues and direct costs.

6.
Also, please tell us why you do not include a discussion of your key metrics (i.e., gross merchandise volume, successful items sold and payment volume) and their
impact on the related geographic/segmental revenues. In your response, please address whether there are any material geographic differences or trends. See Item 303(a) of Regulation S-K, and for guidance, refer to Sections I.B and III.B of SEC
Release No. 33-8350.

 Response: In response to the Staff’s comment, we advise that we have
considered the rules prescribed by Item 303(a) of Regulation S-K, and for guidance, refer to Sections I.B and III.B of SEC Release No. 33-8350, when preparing disclosures relating to material changes to our net revenues. As discussed in
our response above to the Staff’s comment #5, it is our view that an explanation of material changes on a consolidated basis provides a reader with the most relevant information regarding our business and provides the reader with an
understanding of the business as a whole. However, we acknowledge the Staff’s comment, and considering that we are involved in a continuously evolving business, we advise the Staff that, in future fillings, we will quantify our revenues
generated by Marketplace and Non-Marketplace Services for each of our geographic segments (similar to the format provided in our response above to the Staff’s comment #3) and will expand our discussions relating to changes in those service
categories and their impact on our net revenues for each of our geographic segments. In addition, we advise the Staff that no significant changes or trends in key metrics occurred in relation to each of our geographic/segmental revenues that we
deemed necessary for further disclosure under Item 303(a).

 Liquidity and Capital Resources, page 72

7.
We note from your response to comment 4 in your March 29, 2011 letter and comment 2 in your July 13, 2012 letter that you would disclose the amount of cash
and investments held by foreign subsidiaries as well as the percentage of your consolidated cash and investments that are held outside the U.S. However, it does not appear that you have disclosed this information. Please advise.

 Response: In response to the Staff’s comment, we respectfully advise the Staff that although we included the
percentage of our consolidated cash and investments that are held outside the U.S. in Note 2 – Summary of significant accounting policies – Principles of consolidation, on page 10 to our consolidated financial statements for the year ended
December 31, 2012 included in our Form 10-K for fiscal year ended December 31, 2012, we have not included in our “Liquidity and Capital resources” section the amount of cash and investments held by foreign subsidiaries. We will
include cash and investments held by foreign subsidiaries as well as consolidated cash and investments that are held outside the U.S., in that section in future filings. Please, note that we have included such information in the “Liquidity and
Capital Resources” section of our Form 10-Q for the periods ended March 31, June 30 and September 30, 2012 and for the period ended March 31, 2013.

 We advise the Staff that as of December 31, 2012, cash and investments held by foreign subsidiaries amounted to $2

May 9, 2013

Via E -mail
Pedro Arnet
Executive VP & CFO
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc .
 Form 10-K for Fiscal Year Ended December 31, 201 2
 Filed February 28, 201 3
File No. 001-33647

Dear Mr. Arnet :

We have reviewed your filing and have the following comments.  Comments, if any,
related to disclosure in Part III of your Form 10 -K, will be provided under separate cover.  In our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your fil ing and the information you provide in
response to these comments, we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 201 2

Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of
Operation s

Critical Accounting Policies and Estimates

Foreign Currency Translation, page 49

1. We note that no dividends were declared by your Venezuelan subsidiaries during the year
ended December 31, 2012.  Tell us if you were restricted from making distributions  from
these subsidiaries during 2012 as a result of the SITME regulations in place.  Also, tell us
whether you expect the elimination of the SITME on February 9, 2013 and the

Pedro Arnet
MercadoLibre, Inc.
May 9, 2013
Page 2

 implementation of the SICAD on March 19, 2013 to restrict your Venezuelan
subsidi aries’ ability to make dividend distributions in the future.  While we note your
discussion of volume restrictions imposed by the SITME, it is unclear to what extent
these restrictions impacted your ability to make distributions .  Please tell us what
consi deration you gave to disclosing these factors.   Also, to the extent that you believe
these restrictions will not have a material adverse effect on your overall business as you
currently indicate on page 51, tell us your consideration to further enhance yo ur
disclosure to explain such conclusions.

2. We note the risk factor disclosure on page 27 of your December 31, 2011 Form 10 -K
where you state, if current volume restrictions on foreign exchange imposed by the
government worsen significantly or new regulations are implemented , which impact your
ability to settle transactions at either the official rates or SITME rate, you could be
required to deconsolidate your Venezuelan operations for accounting purposes.   Please
tell us whether  deconsolidation o f your Venezuelan subsidiary is still a potential risk to
the company and if so, tell us why you have not included a discussion of this risk in your
current Form 10 -K.  Also, tell us what impact the elimination of the SITME in February
2013  and the creatio n of the SICAD  in March 2013  will have on the accounting for your
Venezuelan operations.  As part of your response, please tell us how your current
inability to access the auction process by which acquisition of foreign currencies will be
made under the ne w system impacts the accounting for your Venezuelan operations.

Results of Operations

Year Ended December 31, 2012 compared t o year ended December 31, 2012, Page 61

3. We note your disclosure of the percentage increases in gross merchandise volume,
financing and off -platform payments, and classified and add sales  revenues . Please tell us
what consideration you gave to quantifying the dollar amount for each of  these re venue
streams and how changes in such amounts and the related metrics impacted your
revenues.  We refer you to Item 303(a)(3)(iii) of Regulation S -K and Section III.D of
SEC Release No. 33 -6835.

4. We note your disclosure of growth in net revenues measured in local currencies. Please
tell us what consideration you gave to also disclosing changes in expenses and segment
revenues measured in local currencies.

5. Please tell us what consideration you gave to disclosing explanations for changes in your
segment net revenues and direct costs. We refer you to Item 303(a) of Regulation S -K
and Sect ion III.F.1 of SEC Release No. 33 -6835.

6. Also, please tell us why you do not include a  discussion of your key metrics  (i.e., gross
merchandise volume, successful items sold and payment volume) and their impact on the

Pedro Arnet
MercadoLibre, Inc.
May 9, 2013
Page 3

 related geographic/segmental revenues.  In your response, please address whether there
are any material geographic differences or trends.  See Item 303(a) of Regulation S -K,
and for guidance, refer to Sections I.B and III.B of SEC Release No. 33 -8350.

Liqui dity and Capital Resources, page 72

7. We note from your response  to comment 4 in your March 29, 2011 letter and comment 2
in your July 13, 2012 letter that you would disclose  the amount of cash and investments
held by foreign subsidiaries as well as the per centage of your consolidated cash and
investments that are held outside the U.S.  However, it does not appear that you have
disclosed this information.   Please advise.

Item 10.  Directors, Executive Officers and Corporate Governance, page 80

8. You indica te that disclosure required by this Item is incorporated by reference from your
definitive proxy statement, but you have not clearly identified, by caption or otherwise,
the material incorporated by reference as required by Securities Exchange Act Rule 12b -
23(b).   In future filings, please ensure that the Part  III disclosure identifies by title the
section of your definitive proxy statement from which you are incorporating by reference
the required disclosure, or otherwise clearly identify the material inco rporated by
reference.   This comment also applies to Items 11 – 14 of Part III of your Form 10 -K.

Item 15.  Exhibits, Financial Statement Schedules

Notes to Consolidated Financial Statements

Note 7.  Segments

9. Tell us how you considered the guidance in ASC 280 -10-50-40 to include a breakdown
of revenues for each of your products and services (i.e., marketplace, online payment
solutions, advertising services and online stores).  In your response, pleas e provide us
with a breakdown of these  revenue  streams  for each period presented.

Note 8.  Fair Value Measurement of Assets and Liabilities, page 34

10. Please tell us what consideration you gave to disclosing the countries in which your
sovereign debt is invested and any risk factors associated with thes e countries.

Pedro Arnet
MercadoLibre, Inc.
May 9, 2013
Page 4

 Note 15.  Commitments and Contingencies, page 45

11. Please tell us the factors you considered in determining the risk of loss relating to the City
of Sao Paulo Tax Claims for the years 2005 through 2010 is remote.  In this regard, we
note that in 2007 the tax authorities ruled against the Brazilian subsidia ry and you made a
deposit in court of $5.1 million relating to the 2005 through 2007 claims.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the  Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures t hey have made.

 In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in  response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securit ies laws of the United States.

You may contact Laura Veator , Staff Accountant , at (202) 551 -3716  if you have
questions regarding comments on the financial statements and re lated matters.  If you have any
other questions, please contact Gabriel Eckstein, Attorney -Advisor, at (202) 551 -3286 or Maryse
Mills -Apenteng, Special Counsel, at (202) 551 -3457.   If you require further assistance, do not
hesitate to contact me at (202) 551 -3499.

Sincerely,

 /s/  Kathleen Collins

Kathleen Collins
Accounting Bra nch Chief

cc:   Marcel o Melamud
 Chief Accounting Officer

August 21, 2012

Via E -mail
Pedro Arnet
Executive VP & CFO
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc
 Form 10-K for Fiscal Year Ended December 31, 2011
 Filed February 28, 2012
File No. 001-33647

Dear Mr. Arnet :

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We u rge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing  include s the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/  Kathleen Colli ns

Kathleen Collins
Accounting Branch Chief

cc:   Jacobo Cohen Imach
 General Counsel

CORRESP
1
filename1.htm

CORRESPONDENCE

 MERCADOLIBRE, INC

ARIAS 3751, 7TH FLOOR

 BUENOS AIRES, C1430CRG

 ARGENTINA

TEL +5411
Ÿ 4640 Ÿ 8000

 PEDRO ARNT

DIRECT DIAL: +5411 Ÿ 4640 Ÿ 8006

EMAIL: pedro@mercadolibre.com

July 13, 2012

 Ms. Kathleen Collins

 Accounting Branch Chief

 United
States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549-4561

Re:
MercadoLibre, Inc.

Form 10-K for Fiscal Year Ended December 31, 2011

Filed February 28, 2012

Form 10-Q for Fiscal Quarter Ended March 31, 2012

Filed May 9, 2012

File No. 001-33647

 Dear Ms. Collins,

 MercadoLibre, Inc. a Delaware corporation (the “Company,” “MercadoLibre”, “we” or “us”), is
transmitting for filing the Company’s responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”), with respect to the Company’s
Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2011 filed on February 28, 2012 and its Form 10-Q for the Fiscal Quarter Ended March 31, 2012 filed on May 9, 2012 (File No. 001-33647), contained in your comment letter dated June
28, 2012 (the “Comment Letter”).

 For convenience of reference, each Staff comment contained in the Comment Letter is reprinted
below in italics, numbered to correspond with the paragraph number assigned in your comment letter and is followed by the corresponding response of the Company.

 Form 10-K for Fiscal Year Ended December 31, 2011

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Year ended December 31, 2011 compared to year ended December 31, 2010, page 56

1.
You state that the increase in cost of revenues from fiscal 2010 to fiscal 2011 was primarily attributable to the increase in collection fees associated with the
MercadoPago payment solution. Please explain further the nature of these “collection fees.” Also, tell us how collection fees may differ based on payment solutions, country, marketplace, etc.

Response: In response to the Staff’s comment, we advise the Staff that the “collection fees” relate to the fees that banks,
the credit card issuers and other means of payment charge us for processing payments pursuant to such means of payment. MercadoLibre offers to its users different options for making payments in the different countries in which it operates. Costs
depend on the specific country and the provider of the means of payment, and the costs charged by a specific provider generally do not differ whether they relate to our “on” or “off”-platform solutions. Most payment transactions
are carried out using means of payments where collection costs are agreed between the provider and the Company as a percentage of the amount of the payment, while fewer payment transactions are completed using a mean of payment that charges to us a
fixed amount per transaction in local currency instead of a percentage. With respect to those payment transactions that involve collection costs calculated as a percentage of the amount of the payment, collection fee charges vary depending on the
specific provider and has not changed significantly since the beginning of 2010. More specifically, most credit card fees range from 2% to 3%, while non-credit card fees range from 1.5% to 3% or are a fixed amount per transaction in local currency,
in those countries in which our volume of transaction is significant.

 The increase in the amount of cost of revenues generated by collection
fees in fiscal year 2011 relates to the increase in the total number and amount of transactions made using our payments platform which includes transaction costs derived mainly from credit cards. The main reasons for the increased use of our
payments platform are:

•

 The increase in the number of total transactions made in our marketplace which were settled through MercadoPago. Since mid-2010, we have made available
MercadoPago in Brazil at no added cost to our users. During 2011, we followed the same approach in Mexico and Venezuela. This resulted in a higher penetration and use of our payments platform in those countries.

•

 During 2011 there was an increased usage of MercadoPago off-platform payment in Argentina and Brazil. MercadoPago off-platform payment solution allows
users to utilize MercadoPago for payments on their own independent commerce websites, allowing for payments for transactions that occur outside of our platform. In mid-2010, the Company elected to make available off-platform transactions through
this new direct payments product to any website in Brazil that chose to adopt it. In 2011, the Company started processing off-platform transactions in Mexico and Venezuela.

 Liquidity and Capital Resources, page 66

2.
In your response to comment 4 in your March 29, 2011 letter you provided disclosures regarding the amount of cash and investments of foreign investments as well as
the percentage of your consolidated cash and investments that are held outside the U.S. and indicated that you would include this information in future filings. While we note that you included this information in your quarterly reports on Form 10-Q,
it appears that you have not included it in your annual report on Form 10-K. Please confirm that you will also include this information in your future Form 10-K filings.

 Response: In response to the Staff’s comment, we confirm the Staff that in our future Form 10-K filings we will include the amount of cash and investments of foreign subsidiaries as
well as the percentage of our consolidated cash and investments that are held outside the U.S. We hereby advise the Staff that as of December 31, 2011, cash and investments of foreign subsidiaries amounted to $151.4 million and approximately 45% of
our consolidated cash and investments were held outside the U.S.

3.
Please explain to us your billing and collection procedures for both your up-front and final value fees. In your response, tell us when you bill the sellers
for these services, what the typical payment terms are and how payments are received. For example, as it relates to the final value fees, tell us if the company retains a portion of the fee charged by the seller when processing the buyer’s
payment. Also, tell us whether the allowance for doubtful accounts relates primarily to receivables due from up-front service fees, final value fees or both.

 Response: In response to the Staff comment, we advise the Staff as follows regarding our billing and collection procedures:

 Users are billed once a month. As established in the “Terms of Use” accepted by our users when they agree to use our platform, we bill final value fees once the seller reports the transaction as
completed.

 With respect to up-front fees, once a seller publishes an item on MercadoLibre’s site, our billing system automatically
generates a charge to be billed to the seller in the next billing cycle.

 In both cases, the bill is due within 5 working days following the
date of the invoice. At the fifth day, if the invoice remains unpaid, an automatic process sends an email to the user to notify its unpaid balance. If the invoice remains unpaid on the tenth day following the date of the invoice, the user receives
an email notifying that they are not permitted to use our marketplace until the invoice is paid. If the invoice remains unpaid on the tenth day after this email notice is sent, an additional notification is sent to the user claiming for its unpaid
bills. After an invoice becomes thirty days past due, we send the receivable to a collection management agency in order to try to collect the unpaid amounts from the user.

 We can bill our customers for up-front and final value fees in a single invoice if the conditions for billing final value fees are met in the same month as for the up-front fee, otherwise we bill them in
separate invoices. Therefore, we can collect up-front and final value fees jointly, or separately, as the case may be.

 As established in our Terms of Use accepted by users, a marketplace user may settle the bill for services
provided by us through:

A.
Our payments platform:

a)
MercadoPago retains the final value fee charged to the seller when processing the buyer’s payment; or

b)
the user may settle the bill (up-front fee or final value fee) using their MercadoPago balances available in their accounts

B.
Direct bank transfer, credit cards or others local means of payments

 The allowance for doubtful accounts relates to receivables due from both up-front service fees and final value fees.

4.
Please provide us with an aging analysis of your receivable balances outstanding as of December 31, 2011 as compared to December 31, 2010, with explanations
for significant unreserved past due amounts. Further, to the extent there is a delay in the write-off of fully reserved receivables please explain the reason for this.

 Response: In response to the Staff’s comment, we provide the Staff with an aging analysis of our receivable balances outstanding as of December 31, 2011 and 2010, together with the
explanations for significant unreserved past due amounts, as well as the detail of fully reserved receivables not written-off as of December 31, 2011:

As of December 31, 2011 (in U.S. dollars)

Up to 10
days

11 – 30
days

31 – 45
days

> 45 days

Total

 Total receivables

17,465,707

2,478,880

2,028,182

10,793,815

32,766,584

 Allowance

(2,655,199
)

(1,622,480
)

(1,701,361
)

(9,972,457
)

(15,951,497
)

 Net balance

14,810,508

856,400

326,821

821,358

16,815,087

As of December 31, 2010 (in U.S. dollars)

Up to 10
days

11 - 30
days

31 - 45
days

> 45 days

Total

 Total receivables

13,894,285

2,054,130

1,705,870

6,524,456

24,178,741

 Allowance

(2,551,521
)

(1,349,679
)

(1,376,041
)

(6,283,327
)

(11,560,568
)

 Net balance

11,342,764

704,451

329,829

241,129

12,618,173

 The amount of past due balances greater than 45 days as of December 31, 2011 and 2010 corresponds mainly to
receivables from Advertising sales for which, due to the nature of this business, the allowance for doubtful accounts is estimated when the receivable is 90 days past due.

 As of December 31, 2011, there were past due balances over 180 days fully reserved from our Venezuelan and Colombian subsidiaries, amounting to approximately $ 3.8 million, which we plan to write-off
during 2012.

 Item 9A. Controls and Procedures, page 73

5.
We note that you conduct substantially all of your operations outside of the United States. In order to enhance our understanding of how you prepare your financial
statements and assess your internal control over financial reporting, we ask that you provide us with information that will help us answer the following questions.

•

 How do you evaluate and assess internal control over financial reporting?

In connection with your process to determine whether your internal control over financial reporting was effective, please describe
whether and how you considered controls to address financial reporting risks that are relevant to all locations where you have operations. If you have an internal audit function, please describe it and explain how, if at all, that function impacted
your evaluation of your internal control over financial reporting.

 Response: We confirm for the Staff that under Section
404 of the Sarbanes-Oxley Act of 2002 (the “Sarbanes-Oxley Act”), MercadoLibre’s management, with the participation of our principal executive and principal financial officers, assess and evaluate the effectiveness of its internal
control over financial reporting (“ICFR”) as of the end of each fiscal year end and each fiscal quarter reports on its assessment (in the case of a fiscal year-end review) or discloses any change that has materially affected, or is
reasonably likely to materially affect, the Company’s internal controls over financial reporting (in the case of a fiscal quarter review). In making its assessment, MercadoLibre’s management uses the criteria established by the Committee
of Sponsoring Organizations of the Treadway Commission (“COSO”) framework and the SEC’s guidance on management’s assessment of ICFR. These criteria cover the following five areas: control environment; risk assessment; control
activities; information and communication; and monitoring. MercadoLibre’s ICFR is designed to provide reasonable assurance regarding the reliability of its financial reporting and the preparation of financial statements in accordance with U.S.
GAAP.

 Our business model, technological platform, business processes and most relevant controls are substantially managed in a centralized
way. Our accounting and reporting processes are performed and managed centrally for all countries through an ERP system and controls that are based substantially in our headquarters in Argentina. So, due to those common processes and the
centralization of financial reporting process, risks are usually common to all countries. Our approach to the evaluation of internal controls over financial reporting takes advantage of such centralization.

 Control Environment: At an entity-wide control level, we have established the “tone at the
top” by demonstrating a commitment to character, integrity, and high ethical values through our attitudes and actions. We adopted a Code of Business Conduct and Ethics for all employees regarding acceptable business practices, conflicts of
interest, and expected standards of ethical behavior, which was approved by the board of directors. All new employees are required to sign an acknowledgement indicating that they have read and understand the Code of Business Conduct and Ethics. The
signed acknowledgement is maintained by our human resources department in the respective employee file. In addition, our Audit Committee understands and actively exercises oversight responsibility over our financial reporting and the internal
control over financial reporting process. The Audit Committee meets at least once each quarter. Meetings are held in advance of each earnings release and filing of the quarterly and annual reports with the SEC. We retained individuals competent in
financial reporting and related oversight roles and we maintained accounting policies and treatments conforming to U.S. GAAP. In addition, for anti-fraud purposes, we also established whistle blowing procedures, which include a hotline monitored by
the Head of Internal Audit and Audit Committee to receive any complaints regarding potential fraud activities. The Audit Committee will delegate either internal or external resources to investigate complaints, if necessary, and review the report on
the investigation results.

 Risk Assessment: Our management is in charge of specifying the financial reporting objectives with
sufficient clarity and criteria to enable the identification of risks to reliable financial reporting. Financial reporting objectives include preparing financial statements for external purposes that are fairly presented in conformity with U.S.
GAAP. We have procedures in place to ensure timely and proper identification of business risks relevant to financial reporting objectives, including the risks of material misstatement in significant accounts and related potential errors in the
financial statements. Regular executive staff meetings are held to discuss current developments, risks and other factors relevant to the Company. These meetings generally occur on a quarterly basis and include our Chief Executive Officer (the
“CEO”), Chief Financial Officer (the “CFO”), Chief Operational Officer (“COO”), Country Managers (“CMs”) and Heads of each business area”. We conduct an entity wide risk assessment at least every year and
assessment results are analyzed in risk matrices by the Internal Audit Department (“IAD”) who facilitates the assessment and discussions of its assessment with the Audit Committee. The risk evaluation is

June 28, 2012

Via E -mail
Pedro Arnet
Executive VP & CFO
MercadoLibre, Inc.
Arias 3751, 7th Floor
Buenos Aires, C1430CRG, Argentina

Re: MercadoLibre, Inc
 Form 10-K for Fiscal Year Ended  December 31, 2011
 Filed February 28, 2012
 Form 10 -Q for Fiscal Quarter  Ended March 31, 201 2
 Filed May 9, 2012
File No. 001-33647

Dear Mr. Arnet :

We have reviewed your filing s and have the following comments.  Please note that we
have limited our review to only your financial statements and related disclosures.  In some of our
comments , we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing s, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstanc es or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing s and the information you provide in
response to these comments, we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2011

Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Year ended December 31, 2011 compared to year ended December 31, 2010 , page 56

1. You state that the increase in cost of re venues from fiscal 2010 to fiscal 2011 was
primarily attributable to the increase in collection fees associated with the MercadoPago
payment solution.  Please explain further the nature of these “collection fees.”  Also, tell
us how collection fees may dif fer based on payment solutions, country, marketplace, etc.

Mr. Pedro Arnet
MercadoLibre, Inc.
June 28, 2012
Page 2

 Liquidity and Capital Resources, page 66

2. In your response to comment 4 in your March 29, 2011 letter you provided disclosures
regarding the amount of cash and investments of foreign investments as well as the
percentage of your consolidated cash and investments that are held outside the U.S. and
indicated that you would include this information in future filings.  While we note that
you included this information in your quarterly reports on Form 10-Q, it appears that you
have not included it in your annual report on Form 10 -K.  Please confirm that you will
also include this information in your future Form 10 -K filings.

3. Please explain to us your billing and collection procedures for both your up -front and
final value fees.  In your response, tell us when you bill the sellers for these services,
what the typical payment terms are and how payments are received.  For example, as it
relates to the final value fees, tell us if the company retains a port ion of the fee charged
by the seller when processing the buyer’s payment.  Also, tell us whether the allowance
for doubtful accounts relates primarily to receivables due from up -front service  fees, final
value fees or both.

4. Please provide us with an agin g analysis of your receivable balances outstanding as of
December 31, 2011 as compared to December 31, 2010, with explanations for significant
unreserved past due amounts. Further, to the exten t there is a delay in the write -off of
fully reserved receivabl es please explain the reason for this.

Item 9A .  Controls and Procedures, page 73

5. We note that you conduct substantially all of your operations outside of the United States.
In order to enhance our understanding of how you prepare your financial statements and
assess your internal control over financial reporting, we ask that you provi de us with
information that will help us answer the following questions.

 How do you evaluate and assess internal control over financial reporting?

In connection with your process to determine whether your internal control over
financial reporting was effective, please describe whether and how you considered
controls to address financial reporting risks that are relevant to all locations where
you have operations. If you have an internal audit function, please describe it and
explain how, if at all, tha t function impacted your evaluation of your internal control
over financial reporting.

 How do you maintain your books and records and prepare your financial statements?

If you maintain your books and records in accordance with U.S. GAAP, describe the
controls you maintain to ensure that the activities you conduct and the transactions

Mr. Pedro Arnet
MercadoLibre, Inc.
June 28, 2012
Page 3

 you consummate are recorded in accordance with U.S. GAAP. If you do not maintain
your books and records in accordance with U.S. GAAP, tell us what basis of
accounting you u se and describe the process you go through to convert your books
and records to U.S. GAAP for SEC reporting. Describe the controls you maintain to
ensure that you have made all necessary and appropriate adjustments in your
conversions and disclosures.

 What is the background of the people involved in your financial reporting?

We would like to understand more about the background of the people who are
primarily responsible for preparing and supervising the preparation of your financial
statements and eval uating the effectiveness of your internal control over financial
reporting and their knowledge of U.S. GAAP and SEC rules and regulations. Do not
identify people by name, but for each person, please tell us:

• what role he or she takes in preparing your fi nancial statements and evaluating the
effectiveness of your internal control;
• what relevant education and ongoing training he or she has had relating to U.S.
GAAP;
• the nature of his or her contractual or other relationship to you;
• whether he or she hold s and maintains any professional designations such as
Certified Public Accountant (U.S.) or Certified Management Accountant; and
• about his or her professional experience, including experience in preparing and/or
auditing financial statements prepared in a ccordance with U.S. GAAP and
evaluating effectiveness of internal control over financial reporting.

If you retain an accounting firm or other similar organization to prepare your
financial statements or evaluate your internal control over financial repor ting, please
tell us:

• the name and address of the accounting firm or organization;
• the qualifications of their employees who perform the services for your company;
• how and why they are qualified to prepare your financial statements or evaluate
your internal control over financial reporting;
• how many hours they spent last year performing these services for you; and
• the total amount of fees you paid to each accounting  firm or organization in
connection with the preparation of your financial statements and in connection
with the evaluation of internal control over financial reporting for the most recent
fiscal year end.

If you retain individuals who are not your emplo yees and are not employed by an
accounting firm or other similar organization to prepare your financial statements or

Mr. Pedro Arnet
MercadoLibre, Inc.
June 28, 2012
Page 4

 evaluate your internal control over financial reporting, do not provide us with their
names, but please tell us:

• why you believe they ar e qualified to prepare your financial statements or
evaluate your internal control over financial reporting;
• how many hours they spent last year performing these services for you; and
• the total amount of fees you paid to each individual in connection wit h the
preparation of your financial statements and in connection with the evaluation of
internal control over financial reporting for the most recent fiscal year end.

 Do you have an audit committee financial expert?

We note from the  disclosures on page  5 of your DEF14A  that you have identified an
individual who serves as your audit committee financial expert.  Please describe his
qualifications, including the extent of his knowledge of U.S. GAAP and internal control
over financial reporting.

Form 10 -Q for the Quarterly Period Ended March 31, 2012

Condensed Consolidated Statements of Changes in Shareholders’ Equity, page 6

6. It appears that you adopted the guidance in ASU 2011 -05 (as amended by ASU 2011 -20)
during the first quarter of fiscal 2012.  We further note that you continue to include the
individual components of other comprehens ive income in the statement of changes i n
shareholder’  equity . Please confirm for us that in future filings you will present one line
item representing the total other comprehensive income for each period in your statement
of stockholders’ equity consistent with the guidance in ASC 220 -10-45-14.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the c ompany and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from th e company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with resp ect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by

Mr. Pedro Arnet
MercadoLibre, Inc.
June 28, 2012
Page 5

 the Commission or any person under the federal securities laws of the United States.

You may contact Laura Veator , Staff Accountant , at (202) 55 1-3716  if you have
questions regarding comments on the financial statements and re lated matters.  Please contact me
at (202) 551 -3499  with any other questions.

Sincerely,

 /s/  Kathleen Collins

Kathleen Collins
Accounting Bra nch Chief

cc:   Jacobo Cohen Imach
 General Counsel

April 5, 2011
 Via E-Mail

Hernán Kazah Chief Financial Officer MercadoLibre, Inc. Arias 375, 7
th Floor
Buenos Aires, C1430CRG, Argentina
Re: MercadoLibre, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2010
Filed February 25, 2011 File No. 001-33647

Dear Mr. Kazah:
 We have completed our review of your Form 10-K and related filings and have no further
comments at this time on the specific issues raised.
Sincerely,  /s/  Kathleen Collins

Kathleen Collins Accounting Branch Chief

CORRESP
1
filename1.htm

Correspondence

MERCADO LIBRE, INC

ARIAS3751, 7TH FLOOR

BUENOS AIRES, C1430CRG

ARGENTINA

TEL 011• 5411 • 4640 • 8000

HERNAN KAZAH.

DIRECT DIAL: 011-5411-4640-8004

EMAIL: hernan@mercadolibre.com

March 29, 2011

VIA E- MAIL

Ms. Kathleen Collins

Accounting Branch Chief

United States Securities and Exchange Commission

Division of Corporation Finance

One Station Place

100 F Street, N.E.

Washington, D.C. 20549-4561

    Re:

    MercadoLibre, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2010

Filed February 25, 2011

File No. 001-33647

Dear Ms. Collins:

MercadoLibre, Inc. a Delaware corporation (the “Company,” “we” or “us”), is transmitting for filing
the Company’s responses to the comments of the Staff of the Division of Corporation Finance (the
“Staff”) of the Securities and Exchange Commission (the “SEC”), with respect to the Company’s
Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2010 filed on February 25, 2011
(File No. 001-33647), contained in your comment letter dated March 15, 2011.

For convenience of reference, each Staff comment contained in your March 15, 2011 comment letter is
reprinted below in italics, numbered to correspond with the paragraph number assigned in your
comment letter and is followed by the corresponding response of the Company.

Page 2

Form 10-K for the Fiscal Year Ended December 31, 2010

Item 1A. Risk Factors

“Political and economic conditions in Venezuela . . .”, page 26

    1.

    We note your disclosure on page 27 where you state that you requested U.S. dollars at the
official exchange rate for the first time for dividend distributions, which is pending
approval from the Venezuelan Commission of Foreign Exchange Administration. Please clarify and
quantify the restriction this pending approval has on the distribution of your net assets from
your Venezuelan operations to either the parent company or your shareholders, if any (see Rule
4-08(e) of Regulation S-X).

Response: We advise the Staff that during 2010 and previous years we were able to obtain
U.S. dollars using alternative mechanisms other than the Venezuelan Commission of Foreign Exchange
Administration (“CADIVI”). These dollars, obtained at a higher exchange rate than the one offered
by CADIVI, and held in balance at U.S. Bank accounts of our Venezuelan subsidiaries, were used for
dividend distributions from our Venezuelan subsidiary. As a result, during 2010, lack of CADIVI
approval did not restrict our ability to distribute the full amount of our retained earnings as
dividends related to fiscal years 2008 ($0.8 million), and 2009 ($1.8 million).

We also plan to distribute dividends related to earnings for fiscal year 2010, in the approximate
amount of $4.2 million, using existing cash balances held in the U.S. bank accounts of our
Venezuelan subsidiary and to reinvest the additional cash generated by our Venezuelan operations by purchasing
our own office space in that country. As disclosed on page 50 and F-19 of our filing, the alternative mechanisms
mentioned above are no longer available. The new mechanisms available as a result of the new rules
implemented by the Government of Venezuela in June of 2010 imply increased restrictions, which are discussed in our Form 10-K.

Net assets of our Venezuelan subsidiary amount to approximately 8% of our consolidated net assets,
and cash and investments of our Venezuelan subsidiary held in local currency in Venezuela amount
only to approximately 5% of our consolidated cash and investments.

As a result of the foregoing, we do not expect the current restrictions to have a
significant adverse effect on our business plans with regard to our investment in Venezuela.

Page 3

Beginning with our next quarterly Form 10-Q filing, we will include the description of the above
paragraphs and any new significant developments and their relative effect.

    2.

    In addition, given the risks presented by currency restrictions discussed, as well as concern
over whether the official rate is reflective of economic reality, tell us if you considered
providing summarized financial information for your Venezuelan operations, including sales,
total assets, liabilities and net assets as of the periods presented in either your MD&A or
liquidity discussion. In your response, please provide us with balance sheet information for
your Venezuelan operations as of December 31, 2010.

Response: We advise the Staff that we provided both the amount of net assets and net
revenues for Venezuelan operations. Specifically, on page 50 of our MD&A we provide our Venezuelan
net assets and on page 62 and 66 our net revenues appear as one of our operating segments.
Venezuelan net revenues also appear on page 77 under the caption “Foreign Currency Risk”. For the
2010 Form 10-K, we did not believe that providing more detailed information relating to our balance
sheet for our Venezuelan operations was relevant since, as of the end of fiscal year 2010, our
Venezuela operation’s net assets mainly consisted of monetary assets and liabilities relating to
the ordinary course of business, except for the goodwill balance which is already disclosed
segregated by geography in our financial statements. However, in future filings (beginning in the
first quarter of 2011), we will include the detail of total assets and total liabilities to
complement the information we already disclose for our Venezuelan operations as disclosed below.

The following table sets forth the Venezuelan Assets, Liabilities, Net Assets and Net Revenues for
the three years ended December 31, 2010.

    December 31,

    2010

    2009

    2008

    Venezuelan operations

    Net Revenues

    20,885,541

    27,331,095

    23,123,837

    Assets

    21,928,340

    15,471,344

    34,251,432

    Liabilities

    (8,212,581
    )

    (6,557,337
    )

    (12,366,560
    )

    Net Assets

    13,715,759

    8,914,007

    21,884,872

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of

Operations

Page 4

Critical Accounting Policies and Estimates

Accounting for Income Taxes, page 61

    3.

    Tell us your consideration to provide disclosures that explain in greater detail the impact
on your effective income tax rates and obligations of having proportionally higher earnings in
countries where you have lower statutory tax rates. In this regard, you should consider
explaining the relationship between the foreign and domestic effective tax rates in greater
detail as it appears as though separately discussing the foreign effective income tax rates
may be important information necessary to understanding your results of operations. To the
extent that one or two countries have had a more significant impact on your effective tax
rate, then tell us how you considered disclosing this information and including a discussion
regarding how potential changes in such countries’ operations may impact your results of
operations. Also, tell us if you have entered into any agreements with the Internal Revenue
Service with regard to certain foreign jurisdictions (e.g. advanced pricing agreements), and
if so tell us what consideration you have given to including a discussion of the material
terms of such agreements. We refer you to Item 303(a)(3)(i) of Regulation S-K and Section
III.B of SEC Release 34-48960.

Response: As disclosed on page 65 of our Form 10-K for the Fiscal Year Ended December 31,
2010, our effective income tax rate is defined as the provision for income taxes (net of charges
related to dividend distribution from foreign subsidiaries which are offset with domestic foreign
tax credits) as a percentage of pre-tax income. The effective income tax rate excludes the effects
of the deferred income tax and of the Mexican tax called “Impuesto Empresarial a Tasa Única”
(“IETU”).

The following table sets forth our effective income tax rate related to our main locations as of
December 31, 2010

    Argentina

    Brazil

    Mexico

    Venezuela

    Effective Income Tax rate

    18.2
    %

    31.9
    %

    33.9
    %

    41.9
    %

As disclosed on page F-21 of our 2010 Financial Statements, the Company’s Argentine subsidiary is a
beneficiary of a software development law granting it a relief of 60% of total income tax
determined in each year. Mainly for that reason, as of December 31, 2010, our Argentine operation’s
effective income tax rate of 18.2% is currently lower than the local statutory rate of 35%. If the
Company had not been granted the Argentine tax holiday, the Company would have pursued an alternative tax planning strategy and, therefore, the impact of not
having this particular benefit could result in a higher effective tax rate in Argentina, but not
necessarily in a 35% effective tax rate.

Page 5

As of December 31, 2010, our Brazilian effective income tax rate is lower than the local statutory
rate of 34% mainly because of the business reorganization generated as part of our tax planning
strategy, which permitted us to use tax loss carryforwards in that country.

As of December 31, 2010, our Mexican and Venezuelan effective income tax rates are higher than the
local statutory rate of 30% and 34%, respectively, mainly because of variations in both temporary
and permanent tax differences.

Our effective tax rate reflects the tax effect of significant operations outside the United States,
which are generally taxed at rates lower than the U.S. statutory rate of 35 percent, especially in
the case of Argentina, where we have significant operations with an effective tax rate of
approximately 18%. A future change in the mix of pretax income from these various tax jurisdictions
would impact the Company’s periodic effective tax rate.

In connection with the relationship between the foreign and domestic income tax rate, we do not
expect it to have a significant impact in the domestic effective income tax rate related to
dividend distributions from foreign subsidiaries since our strategy is to reinvest our cash surplus
in our international operations, and to distribute dividends when they can be offset with available
tax credits.

In future filings (beginning in the first quarter of 2011) we will include in our MD&A quantitative
disclosure related to the individual effective income tax rate of our main operations and the above
explanations relating to the countries that have a significant impact on our effective tax rate and
how potential changes in such countries’ operations may impact our results of operations.

We advise the Staff that we have not entered into any agreements with the Internal Revenue Service
with regard to certain foreign jurisdictions.

Page 6

Liquidity and Capital Resources, page 71

    4.

    You indicate on page F-48 that some of your non-U.S. subsidiaries’ undistributed earnings are
intended to be indefinitely reinvested in your international operations and potential
acquisitions related to those operations. Please clarify and disclose in future filings what
portion of the $45.6 million in total non-U.S. subsidiaries’ undistributed earnings are
considered to be indefinitely reinvested. If it is material to your operations, tell us your
consideration to disclose the amount of cash and investments that are currently held outside of
the U.S. and the impact of repatriating the undistributed earnings of foreign subsidiaries. We
refer you to Item 303(a)(1) of Regulation S-K and Section IV of SEC Release 34-48960.

Response: We estimate that the portion of undistributed earnings to be indefinitely
reinvested in our international operations and in potential acquisitions amounts to approximately
$19.5 million. In future filings we will disclose the undistributed earnings that we plan to
reinvest indefinitely in our business.

As of December 31, 2010, cash and investments of foreign subsidiaries amount to $114.5 million or
81.2% of our consolidated cash and investments and approximately 55% of consolidated cash and
investments are held outside the U.S., mostly in Brazil.

Our strategy is to reinvest our undistributed earnings of our foreign operations in those
operations and to distribute dividends when they can be offset with available tax credits.

In addition, we advise the Staff that we do not expect a material impact in any repatriation of
undistributed earnings of foreign subsidiaries on our operations since the taxable domestic gains
generated by any dividend distributions will be mostly offset with foreign tax credits that arise
from income tax paid in our foreign operations, which we are allowed to compute for domestic income
tax purposes.

We will disclose in future filings the above paragraphs.

Item 15. Exhibits and Financial Statement Schedules

Note 2. Summary of Significant Accounting Policies

Revenue Recognition, page F-16

    5.

    We note that you earn revenue from various fees, such as listing and optional fees (upfront
fees), final value fees, and on-line payment fees in certain instances. Please provide us with
and tell us how you considered disclosing your accounting policy for recognizing revenue for
multiple element arrangements pursuant to ASC 605-25-50.

Page 7

Response: We generate revenues for different services that we provide. When more than one
service is included in one single arrangement with the customer, we recognize revenue according to
multiple element arrangements accounting, distinguishing between each of the services provided and
allocating revenues based on their respective fair value. Those services are separately recognized
as revenue according to the criteria described for each type of services on page F-16. The most
common case of multiple element arrangement includes two services in a single agreement. Due to the
nature of our services and the short-term duration of these agreements (typically with term of up
to 2 months), the timing of delivery of both services generally coincides so the effect of such
segregation has not been significant. Considering that, from time to time, we may implement new
forms of arrangements with our customers, we will start including in our filing for the period
ended March 31, 2011 an explanation of our multiple element arrangement accounting.

Highly Inflationary status in Venezuela, page F-20

    6.

    We note that the Company accounted for its Venezuela operations as highly inflationary
beginning on January 1, 2010 in accordance with ASC 830-30-S99. Please tell us the
differences, if any, between the amounts reported for financial reporting purposes versus the
underlying U.S. dollar denominated values for each relevant line item while using the parallel
rates. Additionally, please tell us if such amounts were recognized through the income
statement or the cumulative translation adjustment and how you determined this classification
was appropriate. To the extent this information is material, tell us how you considered
disclosing it pursuant to the disclosure guidance in ASC 830-30-S99.

Response: We advise the Staff that, as described on page F-18 of our consolidated financial
statements, the assets, liabilities, income and expense accounts of our Venezuelan subsidiaries
were translated at the official rate of 2.15 “Bolívares Fuertes” per US dollar up to September 30,
2009.

Furthermore, U.S. dollar assets and liabilities maintained by the Venezuelan subsidiaries were
first re-measured into the functional currency “Bolívares Fuertes” at a parallel exchange rate, and
then translated into the reporting currency at the official exchange rate of 2.15 “Bolívares
Fuertes” per US Dollars.

As a result of using the official rate to translate U.S. dollar denominated values of the
Venezuelan subsidiaries through September 30, 2009, the increase in the value of assets was
recorded in the “Other non-current assets” line by crediting Other Comprehensive Income.

Page 8

As disclosed on page 49 of our Form 10-K for the Fiscal Year Ended

March 15, 2011
 Via E-Mail

Hernán Kazah Chief Financial Officer MercadoLibre, Inc. Arias 375, 7
th Floor
Buenos Aires, C1430CRG, Argentina
Re: MercadoLibre, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2010
Filed February 25, 2011 File No. 001-33647

Dear Mr. Kazah:
 We have reviewed your filing 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the Fiscal Year Ended December 31, 2010

 Item 1A. Risk Factors

 “Political and economic conditions in Venezuela . . .”, page 26

1. We note your disclosure on page 27 where you st ate that you requested U.S. dollars at the
official exchange rate for the first time for dividend distribut ions, which is pending
approval from the Venezuelan Commission of  Foreign Exchange Administration.  Please
clarify and quantify the restri ction this pending approval has on the distribution of your
net assets from your Venezuelan operations  to either the parent company or your
shareholders, if any (see Rule 4-08(e) of Regulation S-X).
2. In addition, given the risks presented by cu rrency restrictions di scussed, as well as
concern over whether the official rate is re flective of economic re ality, tell us if you

Hernán Kazah MercadoLibre, Inc. March 15, 2011
Page 2

 considered providing summarized financial in formation for your Venezuelan operations,
including sales, total assets, liabilities and net assets as of the periods  presented in either
your MD&A or liquidity discussion.  In your  response, please provi de us with balance
sheet information for your Venezuel an operations as of December 31, 2010.

Item 7.  Management’s Discussion and Analys is of Financial Condition and Results of
Operations
 Critical Accounting Policies and Estimates

 Accounting for Income Taxes, page 61

3. Tell us your consideratio n to provide disclosures that expl ain in greater detail the impact
on your effective income tax rates and ob ligations of having proportionally higher
earnings in countries where you have lower statut ory tax rates.  In this regard, you should
consider explaining the relati onship between the foreign and domestic effective tax rates
in greater detail as it appear s as though separately discussing  the foreign effective income
tax rates may be important information necessary to understanding your results of
operations.  To the extent that  one or two countries have ha d a more significant impact on
your effective tax rate, then tell us how you considered disclosing this information and
including a discussion regarding how potential changes in such countries’ operations may
impact your results of operations.  Also, tell us if you have entered into any agreements
with the Internal Revenue Se rvice with regard to certain  foreign jurisdictions (e.g.
advanced pricing agreements), and if so te ll us what considerat ion you have given to
including a discussion of the material terms of such agreements. We refer you to Item
303(a)(3)(i) of Regulation S-K and S ection III.B of SEC Release 34-48960.

Liquidity and Capital Resources, page 71
4. You indicate on page F-48 that some of your non-U.S. subsidiaries’ undistributed
earnings are intended to be indefinitely rei nvested in your international operations and
potential acquisitions related to  those operations.  Please clarify and disclose in future
filings what portion of the $45.6 million in to tal non-U.S. subsidiaries’ undistributed
earnings are considered to be i ndefinitely reinvested.  If it is  material to your operations,
tell us your consideration to  disclose the amount of cash and investments that are
currently held outside of the U.S. and th e impact of repatriating the undistributed
earnings of foreign subsidiaries. We refer you to Item 303(a)(1) of Regulation S-K and
Section IV of SEC Release 34-48960.

Hernán Kazah MercadoLibre, Inc. March 15, 2011
Page 3

 Item 15. Exhibits and Financial Statement Schedules

 Note 2. Summary of Significant Accounting Policies

 Revenue Recognition, page F-16

5. We note that you earn revenue from various fees, such as listing and optional fees
(upfront fees), final value fees, and on-lin e payment fees in certain instances.  Please
provide us with and tell us how you cons idered disclosing your accounting policy for
recognizing revenue for multiple element arrangements pursuant to ASC 605-25-50.

Highly Inflationary status in Venezuela, page F-20
6. We note that the Company accounted for its Ve nezuela operations as highly inflationary
beginning on January 1, 2010 in accordance wi th ASC 830-30-S99.  Please tell us the
differences, if any, between the amounts report ed for financial reporting purposes versus
the underlying U.S. dollar denominated values for each relevant line item while using the
parallel rates.  Additionally, please tell us  if such amounts were recognized through the
income statement or the cumulative translation adjustment and how you determined this classification was appropriate.  To the extent this information is material, tell us how you
considered disclosing it pursuant to th e disclosure guidance in ASC 830-30-S99.

Note 8. Fair Value Measurement of Assets and Liabilities, page F-40

7. For your available for sale securities with gr oss unrealized loss pos itions, please tell us
how you considered providing all of the disc losures required by AS C 320-10-50-6(b).

Note 14. Income Taxes, page F-46
8. Tell us how you considered disclosing the am ounts and expiration dates of operating loss
and tax credit carry-forward s for tax purposes pursua nt to ASC 740-10-50-3(a).
9. We also note that you reversed $4.6 million and $4.1 million of your deferred tax asset
valuation allowance in fiscal 2010 and 2009, re spectively.  Please describe in further
detail the tax planning strategies you implem ented during both of these years to more
efficiently use your accumulated tax loss carry -forward credits from acquired companies.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Hernán Kazah MercadoLibre, Inc. March 15, 2011
Page 4

  In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Melissa Feid er at (202) 551-3379 if you have questions regarding
comments on the financial statements and relate d matters.  Please contact me at (202) 551-3499
with any other questions.
Sincerely,  /s/  Kathleen Collins

Kathleen Collins Accounting Branch Chief

Mail Stop 4561
Via Fax (5411)  5352 8049
         J u n e  2 9 ,  2 0 0 9   Hernán Kazah Executive VP and Chie f Financial Officer
MercadoLibre, Inc. Tronador 4890, 8
th Floor
Buenos Aires, C1430DNN, Argentina
Re: MercadoLibre, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2008
Filed February 27, 2009
  Forms 8-K filed on February 24, 2009 and May 6, 2009
File No. 001-33647

Dear Mr. Kazah:
We have reviewed your response letter dated June 11, 2009 in connection with the
above-referenced filings and have the followi ng comments.  If indicated, we think you
should revise your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as deta iled as necessary in your expl anation.  In some of our
comments, we may ask you to provide us w ith supplemental information so we may
better understand your disclosure.  After re viewing this information, we may raise
additional comments.  Unless otherwise noted, where prior comments are referred to they
refer to our letter dated May 28, 2009.

Form 10-K for the Fiscal Year Ended December 31, 2008

 General

 1. We note that your counsel, on beha lf of the Company, provided the
acknowledgments we requested in our le tter dated May 28, 2009.  Please note that
the representations should come directly from the company.  In your next response, please provide the representa tions directly from the company.

Hernán Kazah
MercadoLibre, Inc.
June 29, 2009 Page 2  Note 2. Summary of Significant Accounting Polices

 Income and Asset Taxes, page F-17

 2. Your response to prior comment 7 i ndicates that you have not provided the
required disclosures because you would have  pursued an alternative tax planning
strategy had the tax holiday  not been in place.  Although we understand that you
may be able to implement these strategi es, the disclosures in SAB Topic 11.C are
required disclosures.  Please confirm that in future filings you will provide the disclosures required by SAB Topic 11.C.
 Note 17. Long Term Retention Plan, page F-50

 3. We note from your response to prior comment 10 that you do not believe
paragraphs A240(b)(2), (c)(2), and (d) of  SFAS 123(R) are applicable because the
Company did not grant options.  However, since the shares issued in connection with your long-term retention plan were not vested at their grant date, it appears that such paragraphs are applicable.  In  this regard, paragraphs A240(b), (c)(2),
and (d) make reference to share units and paragraph A240(b)(2) makes reference to shares of nonvested stock.  Therefore, tell us how you considered disclosing the information in these paragraphs or expl ain to us further why you do not believe
they are applicable.

* * * * * * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please  submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your response to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your response to our comments.
 You may contact Melissa Feider, St aff Accountant, at  (202) 551-3379, or
Christine Davis, Assistant Chief Accountant,  at (202) 551-3408 if you have any questions
regarding comments on the fina ncial statements and relate d matters.  Please address
questions regarding all other comments to Jan Woo, Staff Attorney, at (202) 551-3453 or
Katherine Wray, Staff Attorne y, at (202) 551-3483.  If you n eed further assistance, you
may contact me at (202) 551-3499.
       S i n c e r e l y ,          Kathleen Collins
Accounting Branch Chief

Mail Stop 4561
Via Fax (5411)  5352 8049
         July 23, 2009  Hernán Kazah Executive VP and Chie f Financial Officer
MercadoLibre, Inc. Tronador 4890, 8
th Floor
Buenos Aires, C1430DNN, Argentina
Re: MercadoLibre, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2008
Filed February 27, 2009
  Forms 8-K filed on February 24, 2009 and May 6, 2009
File No. 001-33647

Dear Mr. Kazah:
We have completed our review of your Fo rm 10-K and related filings and have no
further comments at this time on the specific issues raised.
       S i n c e r e l y ,          Kathleen Collins
Accounting Branch Chief

CORRESP
1
filename1.htm

Correspondence

    MERCADO LIBRE, INC

    TRONADOR 4890, 8TH FLOOR

    BUENOS AIRES, C1430DNN

    ARGENTINA

    TEL

    011• 5411 • 5352 • 8000

    FAX

    011• 5411 • 4545 • 4744 /

    011• 5411 • 5550 • 8719

    HERNAN KAZAH.

    DIRECT DIAL: 011-5411-5352-8004

    EMAIL: hernan@mercadolibre.com

July 14, 2009

VIA EDGAR AND FACSIMILE

Ms. Kathleen Collins

Accounting Branch Chief

United States Securities and Exchange Commission

Division of Corporation Finance

One Station Place

100 F Street, N.E.

Washington, D.C. 20549-4561

    Re:

    MercadoLibre, Inc.

    SEC Comment Letter for the Form 10-K for the Fiscal

    Year Ended December 31, 2008 filed on February 27, 2009

    Forms 8-K filed on February 24, 2009 and May 6, 2009

    File No. 001-33647

Dear Ms. Collins:

MercadoLibre, Inc. a Delaware corporation (the “Company,” “we” or “us”), is transmitting for filing
its responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of
the Securities and Exchange Commission (the “SEC”), with respect to the Company’s annual report on
Form 10-K for the Fiscal Year Ended December 31, 2008 filed on February 27, 2009 and current
reports on Form 8-K filed on February 24, 2009 and May 6, 2009 (File No. 001-33647), contained in
your comment letter dated June 29, 2009.

For convenience of reference, each Staff comment contained in your June 29, 2009 comment letter is
reprinted below in italics, numbered to correspond with the paragraph number assigned in your
comment letter and is followed by the corresponding response of the Company.

Ms. Collins

July 14, 2009

Page 2

Form 10-K for the Fiscal Year Ended December 31, 2008

General

    1.

    We note that your counsel, on behalf of the Company, provided the acknowledgments we
requested in our letter dated May 28, 2009. Please note that the representations should come
directly from the company. In your next response, please provide the representation directly
from the company.

Response: The Company hereby acknowledges that:

    •

    the Company is responsible for the adequacy and accuracy of the disclosure in the
filing;

    •

    staff comments or changes to disclosure in response to staff comments do not foreclose
the U.S. Securities and Exchange Commission (the “Commission”) from taking any action with
respect to the filing; and

    •

    the Company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Note 2. Summary of Significant Accounting Polices

Income and Asset Taxes, page F-17

    2.

    Your response to prior comment 7 indicates that you have not provided the required
disclosures because you would have pursued an alternative tax planning strategy had the tax
holiday not been in place. Although we understand that you may be able to implement these
strategies, the disclosures in SAB Topic 11.C are required disclosures. Please confirm that in
future filings you will provide the disclosures required by SAB Topic 11.C.

Response: In future filings, the Company will provide the disclosures required by SAB Topic
11.C.

Ms. Collins

July 14, 2009

Page 3

Note 17. Long Term Retention Plan, page F-50

    3.

    We note from your response to prior comment 10 that you do not believe paragraphs A240(b)(2),
(c)(2), and (d) of SFAS 123(R) are applicable because the Company did not grant options.
However, since the shares issued in connection with your long-term retention plan were not
vested at their grant date, it appears that such paragraphs are applicable. In this regard,
paragraphs A240(b), (c)(2), and (d) make reference to share units and paragraph A240(b)(2)
makes reference to shares of nonvested stock. Therefore, tell us how you considered disclosing
the information in these paragraphs or explain to us further why you do not believe they are
applicable.

Response: In response to the Staff comment, the following table shows the requirements of
the rule and our related response:

    Disclosure Requirement

    Company Response

    Paragraph A240 (b) (2): The number
and weighted-average grant-date fair
value (or calculated value for a
nonpublic entity that uses that
method or intrinsic value for awards
measured pursuant to paragraphs 24
and 25 of this Statement) of equity
instruments not specified in
paragraph A240(b)(1) (for example,
shares of non-vested stock), for
each of the following groups of
equity instruments: (a) those
non-vested at the beginning of the
year, (b) those non-vested at the
end of the year, and those (c)
granted, (d) vested, or (e)
forfeited during the year.

    As disclosed in note 17 to
our Financial Statements
included in our Form 10-K
for the Fiscal Year Ended
December 31, 2008, the
company has granted 21,591
shares under the long-term
retention plan as of
December 31, 2008. The
grant-date fair market
value was $36.8 for each
share. All equity
instruments were granted
during 2008 and were
non-vested at the end of
the year. There were no
vested or forfeited equity
instruments related to the
Long term retention plan
during the year ended
December 31, 2008. We
considered all granted
shares as non-vested
because, as described in
note 17, it is required
that the employee stays in
the Company at the payment
date.

In future filings we will
include the above mentioned
information to meet the
disclosure requirements of
paragraph A240 (b) (2).

Ms. Collins

July 14, 2009

Page 4

    Disclosure Requirement

    Company Response

    Paragraph A240 (c) (2): The total
intrinsic value of options exercised
(or share units converted),
share-based liabilities paid, and
the total fair value of shares
vested during the year.

    According to FAS 123(R),
paragraph E1, the intrinsic
value of a non-vested share
may be described as an
option on that share with
an exercise price of zero.
Thus, the fair value of a
share is the same as the
intrinsic value of that
share. In note 13 to our
Financial Statements
included in our Form 10-K
for the Fiscal Year Ended
December 31, 2008, we
included the fair value of
our shares. In future
filings, we will disclose
the fair value of our
shares in our Long Term
Retention Plan note to our
Financial Statements. (See
the aggregate intrinsic
value table included at the
end of this letter for more
detail)

    Paragraph A240 (d): For fully vested
share options (or share units) and
share options expected to vest at
the date of the latest statement of
financial position:

(1) The number, weighted-average
exercise price (or conversion
ratio), aggregate intrinsic value
(except for nonpublic entities), and
weighted average remaining
contractual term of options (or
share units) outstanding.

(2) The number, weighted-average
exercise price (or conversion
ratio), aggregate intrinsic value
(except for nonpublic entities), and
weighted average remaining
contractual term of options (or
share units) currently
exercisable (or convertible).

    As of December 31, 2008,
the Company did not have
any fully vested share as
disclosed in the response
to Paragraph A240 (b) (2).

As of December 31, 2008,
the remaining contractual
term of shares granted was
3.25 years (remaining
vesting period). The
aggregate intrinsic value
has been included in the
response to the disclosure
requirements of paragraph A240 (b) (2) above.

In future filings we will
include the above mentioned
information to meet the
disclosure requirements of
paragraph A240 (d).

The following table discloses the aggregate intrinsic value as of December 31, 2008 and March 31,
2009:

Ms. Collins

July 14, 2009

Page 5

    March 31,

    December 31,

    2009

    2008

    Number of shares granted

    21,591

    21,591

    Closing price of share

    18.55

    16.41

    Weighted average exercise price

    —

    —

    Intrinsic value

    18.55

    16.41

    Aggregate intrinsic value

    400,513

    354,308

If you have any questions or comments regarding the foregoing, please contact our General Counsel,
Jacobo Cohen Imach at 011 5411 5352 8030, jcimach@mercadolibre.com. We look forward to working
with you on these matters.

Sincerely,

/s/ Hernán Kazah

Hernán Kazah

    cc:

    Christine Davis

    Melissa Feider

Edward W. Elmore Jr.

    Jacobo Cohen Imach

    Jan Woo

    Katherine Wray

CORRESP
1
filename1.htm

Correspondence

    MERCADO LIBRE, INC

TRONADOR 4890, 8TH FLOOR

BUENOS AIRES, C1430DNN

ARGENTINA

    TEL

    011• 5411 • 5352 • 8000

    FAX

    011• 5411 • 4545 • 4744 /

    011• 5411 • 5550 • 8719

    HERNAN KAZAH.

DIRECT DIAL: 011-5411-5352-8004

EMAIL:  hernan@mercadolibre.com

July 8, 2009

VIA EDGAR AND FACSIMILE

Ms. Kathleen Collins

Accounting Branch Chief

United States Securities and Exchange Commission

Division of Corporation Finance

One Station Place

100 F Street, N.E.

Washington, D.C. 20549-4561

    Re:

    MercadoLibre, Inc.

    SEC Comment Letter for the Form 10-K for the Fiscal

    Year Ended December 31, 2008 filed on February 27, 2009

    Forms 8-K filed on February 24, 2009 and May 6, 2009

    File No. 001-33647

Dear Ms. Collins:

MercadoLibre, Inc. a Delaware corporation (the “Company,” “we” or “us”), is transmitting for filing
its responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of
the Securities and Exchange Commission (the “SEC”), with respect to the Company’s annual report on
Form 10-K for the Fiscal Year Ended December 31, 2008 filed on February 27, 2009 and current
reports on Form 8-K filed on February 24, 2009 and May 6, 2009 (File No. 001-33647), contained in
your comment letter dated June 29, 2009.

For convenience of reference, each Staff comment contained in your June 29, 2009 comment letter is
reprinted below in italics, numbered to correspond with the paragraph number assigned in your
comment letter and is followed by the corresponding response of the Company.

Ms. Collins

July 8, 2009

Page 2

Form 10-K for the Fiscal Year Ended December 31, 2008

General

    1.

    We note that your counsel, on behalf of the Company, provided the acknowledgments we
requested in our letter dated May 28, 2009. Please note that the representations should come
directly from the company. In your next response, please provide the representation directly
from the company.

Response: As requested, we are providing the representation directly from the company and
will continue to do so in the future.

Note 2. Summary of Significant Accounting Polices

Income and Asset Taxes, page F-17

    2.

    Your response to prior comment 7 indicates that you have not provided the required
disclosures because you would have pursued an alternative tax planning strategy had the tax
holiday not been in place. Although we understand that you may be able to implement these
strategies, the disclosures in SAB Topic 11.C are required disclosures. Please confirm that in
future filings you will provide the disclosures required by SAB Topic 11.C.

Response: In future filings, the Company will provide the disclosures required by SAB Topic
11.C.

Note 17. Long Term Retention Plan, page F-50

    3.

    We note from your response to prior comment 10 that you do not believe paragraphs A240(b)(2),
(c)(2), and (d) of SFAS 123(R) are applicable because the Company did not grant options.
However, since the shares issued in connection with your long-term retention plan were not
vested at their grant date, it appears that such paragraphs are applicable. In this regard,
paragraphs A240(b), (c)(2), and (d) make reference to share units and paragraph A240(b)(2) makes reference to shares of nonvested stock. Therefore, tell us how you
considered disclosing the information in these paragraphs or explain to us further why you
do not believe they are applicable.

Ms. Collins

July 8, 2009

Page 3

Response: In response to the Staff comment, the following table shows the requirements of
the rule and our related response:

    Disclosure Requirement

    Company Response

    Paragraph A240 (b) (2): The number
and weighted-average grant-date fair
value (or calculated value for a
nonpublic entity that uses that
method or intrinsic value for awards
measured pursuant to paragraphs 24
and 25 of this Statement) of equity
instruments not specified in
paragraph A240(b)(1) (for example,
shares of non-vested stock), for
each of the following groups of
equity instruments: (a) those
non-vested at the beginning of the
year, (b) those non-vested at the
end of the year, and those (c)
granted, (d) vested, or (e)
forfeited during the year.

    As disclosed in note 17 to
our Financial Statements
included in our Form 10-K
for the Fiscal Year Ended
December 31, 2008, the
company has granted 21,591
shares under the long-term
retention plan as of
December 31, 2008. The
grant-date fair market
value was $36.8 for each
share. All equity
instruments were granted
during 2008 and were
non-vested at the end of
the year. There were no
vested or forfeited equity
instruments related to the
Long term retention plan
during the year ended
December 31, 2008. We
considered all granted
shares as non-vested
because, as described in
note 17, it is required
that the employee stays in
the Company at the payment
date.

In future filings we will
include the above mentioned
information to meet the disclosure
requirements of paragraph
A240 (b) (2).

    Paragraph A240 (c) (2): The total
intrinsic value of options exercised
(or share units converted),
share-based liabilities paid, and
the total fair value of shares
vested during the year.

    According to FAS 123(R),
paragraph E1, the intrinsic
value of a non-vested share
may be described as an
option on that share with
an exercise price of zero.
Thus, the fair value of a
share is the same as the
intrinsic value of that
share. In note 13 to our
Financial Statements
included in our Form 10-K
for the Fiscal Year Ended
December 31, 2008, we
included the fair value of
our shares. In future
filings, we will disclose
the fair value of our
shares in our Long Term
Retention Plan note to our
Financial Statements. (See
the aggregate intrinsic
value table included at the
end of this letter for more
detail)

Ms. Collins

July 8, 2009

Page 4

    Disclosure Requirement

    Company Response

    Paragraph A240 (d): For fully vested
share options (or share units) and
share options expected to vest at
the date of the latest statement of
financial position:

(1) The
number, weighted-average
exercise price (or conversion
ratio), aggregate intrinsic value
(except for nonpublic entities), and
weighted average remaining
contractual term of options (or
share units) outstanding.

(2) The
number, weighted-average
exercise price (or conversion
ratio), aggregate intrinsic value
(except for nonpublic entities), and
weighted average remaining
contractual term of options (or
share units) currently
exercisable (or convertible).

    As of December 31, 2008,
the Company did not have
any fully vested share as
disclosed in the response
to Paragraph A240 (b) (2).

As of December 31, 2008,
the remaining contractual
term of shares granted was
3.25 years (remaining
vesting period). The aggregate intrinsic
value has been included in the response
to the disclosure requirements of paragraph
A240 (b) (2) above.

In future filings we will include the above
mentioned information to meet the disclosure
requirements of paragraph A240 (d).

The following table discloses the aggregate intrinsic value as of December 31, 2008 and March 31,
2009:

Ms. Collins

July 8, 2009

Page 5

    March 31,

    December 31,

    2009

    2008

    Number of shares granted

    21,591

    21,591

    Closing price of share

    18.55

    16.41

    Weighted average exercise price

    —

    —

    Intrinsic value

    18.55

    16.41

    Aggregate intrinsic value

    400,513

    354,308

If you have any questions or comments regarding the foregoing, please contact our General Counsel,
Jacobo Cohen Imach at 011 5411 5352 8030, jcimach@mercadolibre.com. We look forward to working
with you on these matters.

Sincerely,

/s/ Hernán Kazah

Hernán Kazah

    cc:

    Christine Davis

Melissa Feider

    Edward W. Elmore Jr.

    Jacobo Cohen Imach

Jan Woo

    Katherine Wray

CORRESP
1
filename1.htm

Correspondence

    HUNTON & WILLIAMS LLP

    RIVERFRONT PLAZA, EAST TOWER

    951 EAST BYRD STREET

    RICHMOND, VIRGINIA 23219-4074

    TEL 804 • 788 • 8200

    FAX 804 • 788 • 8218

    EDWARD W. ELMORE, JR.

    DIRECT DIAL: 804-788-7336

    EMAIL: telmore@hunton.com

    FILE NO: 59490.000009

June 11, 2009

VIA EDGAR AND FACSIMILE

Ms. Kathleen Collins

Accounting Branch Chief

United States Securities and Exchange Commission

Division of Corporation Finance

One Station Place

100 F Street, N.E.

Washington, D.C. 20549-4561

    Re:

    MercadoLibre, Inc.

Initial SEC Comment Letter for the Form 10-K for the Fiscal

Year Ended December 31, 2008 filed on February 27, 2009

Forms 8-K filed on February 24, 2009 and May 6, 2009

File No. 001-33647

Dear Ms. Collins:

As counsel to MercadoLibre, Inc. a Delaware corporation (the “Company,” “we” or “us”), we are
transmitting for filing the Company’s responses to the comments of the Staff of the Division of
Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”), with
respect to the Company’s annual report on Form 10-K for the Fiscal Year Ended December 31, 2008
filed on February 27, 2009 and current reports on Form 8-K filed on February 24, 2009 and May 6,
2009 (File No. 001-33647), contained in your comment letter dated May 28, 2009.

For convenience of reference, each Staff comment contained in your May 28, 2009 comment letter is
reprinted below in italics, numbered to correspond with the paragraph number assigned in your
comment letter and is followed by the corresponding response of the Company.

Form 10-K for the Fiscal Year Ended December 31, 2008

Item 7A. Quantitative and Qualitative Disclosures About Market Risk, page 60

Ms. Collins

June 11, 2009

Page 2

    1.

    You disclose that the company is exposed to several market risks but you do not appear to
have provided the quantitative disclosure required by Item 305(a) of Regulation S-K for these
risks, other than the sensitivity analysis for interest rate risk. Please advise.

Response: Although we provided a detailed discussion of each of our market risks, in
future filings, we will also provide sensitivity analysis disclosures with respect to foreign
currency exchange rate risks and equity price risk, if applicable. The foreign currency
exchange risk will include the impact on Revenues, Expenses, Net Income and Shareholders’ Equity
for a +/-10% fluctuation on all the foreign currencies to which we are exposed. Currently, our credit
risk does not depend on market conditions. For that reason, credit
risk will be eliminated from Item 7A. in future filings until we
have credit risk that depends on market conditions.

Item 9A. Controls and Procedures

Changes in Internal Control Over Financial Reporting, page 62

    2.

    We note your disclosure that “[e]xcept as described above,” there were no changes in your
internal controls over financial reporting. In your response letter, please confirm, if
correct, that there were changes in your internal control over financial reporting that
occurred during your fourth quarter ended December 31, 2008, that have materially affected, or
are reasonably likely to materially affect, your internal control over financial reporting;
or advise. In addition, in future filings please avoid qualifying your disclosure in this
manner, and instead provide an unqualified statement as to whether or not there were changes
in your internal control over financial reporting that occurred during the most recent quarter
that have materially affected, or are reasonably likely to materially affect, your internal
control over financial reporting. We note in this regard that your Form 10-Q for the quarter
ended March 31, 2009, states in an unqualified manner that there were no changes in internal
control over financial reporting during the quarter.

Response: The Company was first required to file an annual report on internal control over
financial reporting and the related attestation report pursuant to Item 308(a) and (b) of
Regulation S-K as of December 31, 2008. Given the pendency of those processes during the period
prior to that date, we believed disclosure of our upgrades was appropriate. With the completion of
our initial audit of internal controls, this transition period will no longer be an issue and we
will provide an unqualified statement, as we did in our Form 10-Q for the quarter ended March 31,
2009.

Ms. Collins

June 11, 2009

Page 3

We also advise the Staff that there were no changes in our internal controls over financial
reporting during the fourth quarter ended December 31, 2008 that have materially affected, or are
likely to materially affect, our internal control over financial reporting as defined in Exchange
Act Rule 13a-15 (f).

Item 11. Executive Compensation

Compensation Discussion and Analysis, page 14 (Incorporated by Reference to Definitive Proxy
Statement Filed April 29, 2009)

    3.

    You state that the annual incentive bonuses and the 2008 Long-Term Retention Bonus Plan
amounts for the named executive officers were, in part, based on the attainment of certain
individual goals. Please expand your disclosure to provide additional detail regarding the
individual performance objectives used to determine bonus awards for each of your named
executive officers, to the extent such information is material to an understanding of your
compensation policies and decisions. See Item 402(b)(2)(vii) of Regulation S-K.

Response: We advise the Staff that we disclose on page 16 of the Company’s Definitive Proxy
Statement filed on April 29, 2009 (the “Proxy Statement”) that individual performance objectives
accounted for 5% of the annual incentive bonus and 2008 long-term retention bonus in the case of
Mr. Galperin, based on a qualitative survey of his individual performance prepared by the Company’s
Board of Directors. As also disclosed on page 16 of the Proxy
Statement, in the cases of Messrs. Gimenez, Kazah, Szekasy and Tolda, their individual performance element accounted for 15% of their
annual incentive bonuses and 2008 long-term retention bonuses. These individual performance reviews
are based on a report of the individual executive’s performance prepared by his supervisor based on
criteria specific to his job responsibilities (10%), together with a 360 degree qualitative survey
of the individual’s performance prepared by his supervisor, colleagues and direct reports (5%). We
further disclose on page 16 that these job specific criteria related to qualitative financial and
operational goals of the office. We believe that this summary provides all of the material
information that is necessary for an understanding of this element of our compensation policies and
decisions.

Ms. Collins

June 11, 2009

Page 4

Item 15. Exhibits and Financial Statement Schedules

Exhibits, page 66

    4.

    Please tell us why you have not filed the 2008 Long Term Retention Plan as an exhibit to your
Form 10-K pursuant to Item 601 (b)(10)(iii) of Regulation S-K.

Response: We advise the Staff that we will file the 2008 Long Term Retention Plan as an
exhibit to our next filing with the SEC pursuant to the Exchange Act.

Note 2. Summary of Significant Accounting Polices

Transfer of Financial Assets, page F-13

    5.

    We note that during fiscal 2008 the Company sold its funds receivable to financial
institutions and accounted for these transactions as “true sales” in accordance with SFAS140.
Please tell us the amount of gains or losses on such sales, if any, for each period presented,
including your most recent interim period ended March 31, 2009. If material, tell us how you
considered disclosing such amounts pursuant to paragraph 17(h)(2) of SFAS 140. Also, tel1 us
how you considered providing the disclosures required by paragraph 17(h)(4) of SFAS 140.

Response: We advise the Staff that the following table shows the amount of losses
recognized by the Company during each quarter of fiscal year 2008 and the most recent interim
period ended March 31, 2009 in connection to the sale of financial assets, which are included in
each corresponding quarter in the “interest expense and other financial charges” line of our
Consolidated Statement of Income.

    Interest expense

    Quarter

    in US$

    Q1 2008

    922,849.69

    Q2 2008

    813,212.34

    Q3 2008

    829,013.95

    Q4 2008

    4,573,326.14

    Q1 2009

    2,041,211.66

Ms. Collins

June 11, 2009

Page 5

We respectfully advise the Staff that we believe the disclosures required by paragraph 17 (h) (2)
and (4) of SFAS 140 are not applicable to us as our receivables were sold and not securitized.

Revenue Recognition, page F-15

    6.

    We note your disclosure on page 40 where you state that the financial charge for transactions
where you finance extended payment terms internally is recognized over the life of the
installment financing. Please describe the nature and length of extended payment terms offered
to your customers in further detail. Additionally, tell us how these payment terms impact the
Company’s assessment of the timing of revenue recognition (i.e. whether collection reasonably
assured) and how you considered disclosing such information pursuant to Question 1 of SAB
Topic 13.B. In this regard, we also note that the allowance for doubtful accounts was 69% and
67% of gross receivables for fiscal 2008 and 2007, respectively.

Response: We advise the Staff that through our Payments business (MercadoPago), we provide
buyers up to 18-month financing. This financing is made through credit card companies. We inform
the Staff that this financing does not impact the timing of revenue recognition as all the criteria
for considering that revenue is realized or realizable and earned or met. In particular we consider
that collectability is reasonably assured because collection is
granted through credit cards. Please note that credit card
companies assume uncollectability risk except charge-backs.

We
advise the Staff that when the Company finances the extended payment terms, interest income is
recognized over the financing term.

Also, as mentioned on page 53 of our Form 10-K, during the fourth quarter of 2008 we sold all our
credit card receivables and, as such, we will not compute revenue over the financing term as a
result of these sales of credit card receivables. Our current
treasury policy is to continue selling credit card receivables and we will not
finance these transactions with our own resources. We will disclose the corresponding revenue
recognition accounting policy for these types of transactions in future filings in the event we
decide to finance these operations ourselves without selling credit card receivables immediately.

We respectfully advise the Staff that the allowance for doubtful accounts referred in your comment
is related to our marketplace business and does not derive from our MercadoPago (payments)
business. The high percentages of allowance for doubtful accounts in relation to gross receivables
are a consequence of a delay in the write off of the portfolio. We
inform the Staff that beginning in Q2 2009, we will write off all accounts receivables with an aging over
180 days.

Ms. Collins

June 11, 2009

Page 6

Income and Asset Taxes, page F-17

    7.

    We note that your Argentine subsidiary is a beneficiary of a 60% relief of total income taxes
for ten years. Tell us the aggregate dollar per share effect on earnings for all periods
presented and, if material, how you considered disclosing this information pursuant to SAB
Topic 11C. Additionally, tell us how you considered specifying the termination date of this
tax holiday.

Response: We advise the Staff that we will specify the termination date of the tax holiday
in future filings. We respectfully advise the Staff that if the Company
had not been granted this Argentine tax holiday, the Company would have pursued an alternative tax
planning strategy and, therefore, disclosure of the impact of this particular tax benefit would be
misleading to investors. If and
when the Company pursues an alternative strategy, we will evaluate
the appropriateness of disclosing any risks or uncertainties of that
strategy.

Confidential
treatment requested by MercadoLibre.

Reference number: MELI 001.

[***]

Ms. Collins

June 11, 2009

Page 7

Note 6. Business Combinations, Goodwill and Intangible Assets

a) Classified Media Group, Inc., page F-26

    8.

    Please provide us with an analysis of how you determined that the acquired trademarks from
your acquisition of Classified Media Group, Inc. have an indefinite useful life. In your
response, please tell us why you believe that no legal, regulatory, contractual, competitive,
economic, expected use or other factors could limit the useful life of these intangible assets
pursuant to paragraph 11 of SFAS 142.

Response: In response to the Staff’s comment, we inform the Staff that the following
factors mentioned in paragraph 11 of SFAS 142 were evaluated to define the acquired trademarks as
an indefinite useful life intangible asset.

    a.

    The expected use of the asset by the entity: TuCarro is one of the most
well-known online brands in Venezuela and Colombia and is the leading trademark in the car
and real estate online classifieds in these countries, with no close competitor. As a
result, we intend to use this trademark indefinitely.

Ms. Collins

June 11, 2009

Page 8

    b.

    The expected useful life of another asset or a group of assets to which the useful
life of the intangible asset may relate: The useful life of the trademark is not
related to another asset.

    c.

    Any legal, regulatory, or contractual provisions that may limit the useful
life: We are not aware of any legal, regulatory or contractual limitation on the
trademark’s useful life other than routine renewals.

    d.

    The entity’s own historical experience in renewing or extending similar
arrangements (consistent with the intended use of the asset by the entity), regardless of
whether those arrangements have explicit renewal or extension provisions. In the absence of
that experience, the entity shall consider the assumptions that market participants would
use about renewal or extension (consistent with the highest and best use of the asset by
market participants), adjusted for entity-specific factors in this paragraph: The
Company does not have historical experience in renewing or extending similar arrangements.
In addition, in the markets where TuCarro trademark operates, there are no other
significant participants.

    e.

    The effects of obsolescence, demand, competition, and other economic factors (such
as the stability of the industry, known technological advances, legislative action that
results in an uncertain or changing regulatory environment, and expected changes in
distribution channels): As described above, in the markets where the TuCarro trademark
operates, there is no significant competition. We expect to continuously invest in
technological advances to address a growing demand and update our business under the
TuCarro trademark instead of creating a new trademark.

    f.

    The level of maintenance expenditures required to obtain the expected future cash
flows from the asset (for example, a material level of required maintenance in relation to
the carrying amount of the asset may suggest a very limited useful life): Given current
and estimated future business margins and its economies of scale, we will continue to
invest in this trademark at an accelerated pace to maintain an updated and
positive-cash-flow business structure.

Ms. Collins

June 11, 2009

Page 9

b) DeRemate Operations, page F-28

    9.

    We note on page F-28 that the Company acquired certain URLs, domain names, trademarks,
databases and intellectual property rights that are used or useful in connection with the online pl

Mail Stop 4561
Via Fax (5411)  5352 8049
        May 28, 2009  Hernán Kazah Executive VP and Chie f Financial Officer
MercadoLibre, Inc. Tronador 4890, 8
th Floor
Buenos Aires, C1430DNN, Argentina
Re: MercadoLibre, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2008
Filed February 27, 2009
  Forms 8-K filed on February 24, 2009 and May 6, 2009
File No. 001-33647

Dear Mr. Kazah:
We have reviewed the above-referenced f ilings and have the following comments.
If indicated, we think you should revise your document in response to these comments.
If you disagree, we will consider your explanation as to why our comment is inapplicable
or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.
 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Form 10-K for the Fiscal Year Ended December 31, 2008

 Item 7A. Quantitative and Qualitative Disclosures About Market Risk, page 60

 1. You disclose that the company is exposed to several market risks but you do not appear to have provided the quantitative disclosure required by Item 305(a) of
Regulation S-K for these risks, other than the sensitivity analysis for interest rate
risk.  Please advise.

Hernán Kazah
MercadoLibre, Inc.
May 28, 2009 Page 2   Item 9A. Controls and Procedures

Changes in Internal Control Over Financial Reporting, page 62

2. We note your disclosure that “[e]xcept as described above,” there were no
changes in your internal controls over fi nancial reporting.  In your response letter,
please confirm, if correct, that there were changes in your internal control over
financial reporting that occurred duri ng your fourth quarter ended December 31,
2008, that have materially affected, or are reasonably likely to materially affect,
your internal control over financial reportin g; or advise.  In addition, in future
filings please avoid qualifying your disclosu re in this manner, and instead provide
an unqualified statement as to whether or not there were change s in your internal
control over financial reporting that occu rred during the most recent quarter that
have materially affected, or are reasonably likely to  materially affect, your
internal control over financ ial reporting.  We note in th is regard that your Form
10-Q for the quarter ended March 31, 2009, states in an unqualified manner that there were no changes in internal control over financial reporting during the
quarter.
 Item 11. Executive Compensation

 Compensation Discussion and Analysis, pa ge 14 (Incorporated by Reference to
Definitive Proxy Statement Filed April 29, 2009)

3. You state that the annual incentive b onuses and the 2008 Long-Term Retention
Bonus Plan amounts for the named executiv e officers were, in part, based on the
attainment of certain individual goals.  Please expand your disclosure to provide
additional detail regarding the individual performance objectives used to
determine bonus awards for each of your named executive officers, to the extent such information is material to an un derstanding of your compensation policies
and decisions.  See Item 402(b)(2)(vii) of Regulation S-K.

Item 15. Exhibits and Financial Statement Schedules

Exhibits, page 66
 4. Please tell us why you have not filed the 2008 Long Term Retention Plan as an exhibit to your Form 10-K pursuant to Item 601(b)(10)(iii) of Regulation S-K.

Hernán Kazah
MercadoLibre, Inc.
May 28, 2009 Page 3  Note 2. Summary of Significant Accounting Polices

 Transfer of Financial Assets, page F-13

 5. We note that during fiscal 2008 the Company sold its funds receivable to financial
institutions and accounted for these transact ions as “true sales”  in accordance with
SFAS 140.  Please tell us the amount of gain s or losses on such sales, if any, for
each period presented, including your most recent interim period ended March 31, 2009.  If material, tell us how you consider ed disclosing such amounts pursuant to
paragraph 17(h)(2) of SFAS 140.  Also, te ll us how you considered providing the
disclosures required by para graph 17(h)(4) of SFAS 140.
 Revenue Recognition, page F-15

 6. We note your disclosure on page 40 where you state that the financial charge for
transactions where you finance extended payment terms intern ally is recognized
over the life of the installment financing.  Please describe the nature and length of
extended payment terms offered to your cust omers in further detail.  Additionally,
tell us how these payment terms impact the Company’s assessment of the timing of revenue recognition (i.e. whether co llection reasonably assured) and how you
considered disclosing such informati on pursuant to Question 1 of SAB Topic
13.B.  In this regard, we also note th at the allowance for doubtful accounts was
69% and 67% of gross receivables for fiscal 2008 and 2007, respectively.
 Income and Asset Taxes, page F-17

 7. We note that your Argentine subsidiary is a beneficiary of a 60% relief of total
income taxes for ten years.  Tell us the aggregate dollar per share effect on earnings for all periods presented and, if  material, how you considered disclosing
this information pursuant to SAB Topic 11C.  Additionally, tell us how you considered specifying the terminatio n date of this tax holiday.
 Note 6. Business Combinations, Goodwill and Intangible Assets

 a) Classified Media Group, Inc., page F-26

 8. Please provide us with an analysis of how you determined that the acquired trademarks from your acquisition of Cl assified Media Group, Inc. have an
indefinite useful life.  In your respon se, please tell us why you believe that no
legal, regulatory, contractual, competitive, economic, expected use or other factors could limit the useful life of these intangible assets pursuant to paragraph
11 of SFAS 142.

Hernán Kazah
MercadoLibre, Inc.
May 28, 2009 Page 4  b) DeRemate Operations, page F-28

 9. We note on page F-28 that the Company acquired certain URLs, domain names,
trademarks, databases and intellectual prope rty rights that are used or useful in
connection with the online platforms of the acquired entities.  However, based on
your disclosures on page F-30, it appears that  you only assigned value to customer
lists and non-compete agreements.  Tell us  how you considered assigning value to
the other acquired identifiable intangible a ssets pursuant to paragraph 39 of SFAS
141.  In this regard, we note that tradem arks, internet domain names, databases,
and patented or unpatented technology are ex amples of intangible assets that meet
the criteria for recognition as an asse t apart from goodwill pursuant to paragraph
A14 of SFAS 141.
 Note 17. Long Term Retention Plan, page F-50

 10. Your disclosures indicate that you issued  shares under your long-term retention
plan.  Tell us how you considered the disclosure requirements of paragraph
A240(f) of SFAS 123(R), as you do not appear to disclose such information in either Note 13 or Note 17.
 Forms 8-K filed on February 24, 2009 and May 6, 2009

 11. We note your disclosure of non-GAAP EBITDA.  Please tell us how you
considered Questions 14 and 15 of our Fr equently Asked Questions Regarding the
Use of Non-GAAP Financial Measures.  In this regard, we note that your
EBITDA measure is calculated differently than that described as EBITDA in SEC
Release No. 33-8176.  We also note that  you have reconciled this measure to
income from operations rather than net income.
 12. Please explain why there was no income tax adjustment for compensation costs related to acquisitions re corded in fiscal 2008.

* * * * * * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please  submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your response to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your response to our comments.

Hernán Kazah
MercadoLibre, Inc. May 28, 2009 Page 5
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 You may contact Melissa Feider, St aff Accountant, at  (202) 551-3379, or
Christine Davis, Assistant Chief Accountant,  at (202) 551-3408 if you have any questions
regarding comments on the fina ncial statements and relate d matters.  Please address
questions regarding all other comments to Jan Woo, Staff Attorney, at (202) 551-3453 or
Katherine Wray, Staff Attorne y, at (202) 551-3483.  If you n eed further assistance, you
may contact me at (202) 551-3499.
       S i n c e r e l y ,           Kathleen Collins
Accounting Branch Chief

CORRESP
1
filename1.htm

Accereration Request

 August 7, 2007

 VIA
EDGAR AND FACSIMILE

 Ms. Cicely LaMothe

 Accounting Branch Chief

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549-7010

Re:
MercadoLibre, Inc.

 Registration Statement on
Form S-1

 File No. 333-142880

 Dear Ms. LaMothe:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, MercadoLibre, Inc. (the “Company”) hereby
requests acceleration of effectiveness of the above-captioned Registration Statement to 1:00 p.m. Eastern time on August 9, 2007, or as soon thereafter as practicable.

 In connection with this request for effectiveness, the Company acknowledges the following:

(i)
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to
the filing;

(ii)
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

(iii)
the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Very truly yours,

 MERCADOLIBRE, INC.

By:

/s/ Marcos Galperin

 Name: Marcos Galperin

 Title: President and Chief
Executive Officer

cc:
S. Todd Crider, Esq.

 Edward W. Elmore, Jr., Esq.

 John F. Haley, Esq.

 Nicolás Szekasy

 Rachel Zablow

J.P. MORGAN SECURITIES INC.

MERRILL LYNCH, PIERCE, FENNER

277 Park Avenue

& SMITH INCORPORATED

New York, New York 10172

4 World Financial Center

New York, New York 10080

 August 7, 2007

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C. 20549

Re:

MercadoLibre, Inc. (the “Company”)

Common Stock

Registration Statement on Form S-1 (File No. 333-142880)

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned hereby join in the request of the Company that the effective date of the Registration Statement be accelerated so that the Registration Statement may become
effective by 1:00 p.m. (New York City time) on August 9, 2007 or as soon thereafter as practicable.

 The following information with respect to the
distribution of the preliminary prospectus dated July 27, 2007 (the “Preliminary Prospectus”) is furnished pursuant to Rule 460 of the Rules and Regulations of the Commission under the Securities Act of 1933, as amended, in connection
with the request for acceleration of the effective date of the Registration Statement.

 The number of Preliminary Prospectuses distributed between
July 27, 2007 and August 7, 2007 is as follows:

 No. of Preliminary Prospectuses

 To Prospective Underwriters

8,420

 To Institutions and Individuals

4,551

 To Others

110

 Total

13,081

 Very truly yours,

 J.P. MORGAN SECURITIES INC.

 For itself and on behalf of the several Underwriters listed in the Underwriting Agreement.

 By

 /s/ Daniel Darahem

 Daniel Darahem

 Authorized Signatory

 MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED

 For itself and on behalf of the several Underwriters listed in the Underwriting Agreement.

 By

 /s/ Daniel Gonzalez

 Daniel Gonzalez

 Authorized Signatory

July 27, 2007

Mail Stop 4561

Marcos Galperin
Chief Executive Officer
Mercadolibre, Inc.
Tronador 4890, 8th Floor
Buenos Aires, C1430DNN
Argentina

Re: Mercadolibre, Inc.
Amendment 2 to Registration Statement on Form S-1
Filed July 23, 2007
File No. 333-142880

Dear Mr. Galperin:

 We have reviewed your filing and have the following comments.  We have
limited our review to only your financial statements and related disclosures and will make no further review of your document.  Where indicated, we think you should revise
your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may raise additional comments.

 Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

Marcos Galperin
Mercadolibre, Inc.
July 27, 2007 Page 2

Critical Accounting Policies and Estimates, page 47

Stock Based Compensation, page 50

1. We have read the disclosures provided in response to prior comment 2.  In relation to your discussion of the factors affecting your October 2006 estimate of the fair value of your common stock, please quantify all discounts taken.

* * * *

As appropriate, please amend your registration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all information required under the Securities Act of 1933 and that they have provided all information investors require for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

We will consider a written request for acceleration of the effective date of the
registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in the above registration statement.  We will act on the request and, pursuant to delegated authority, grant acceleration of the effective date.

We direct your attention to Rules 460 and 461 regarding requesting acceleration
of a registration statement.  Please allow adequate time after the filing of any amendment for further review before submitting a request for acceleration.  Please provide this request at least two business days in advance of the requested effective date.

You may contact Rachel Zablow, Staff Accountant at (202) 551-3428 or the
undersigned at (202) 551-3413 if you have questions.

Marcos Galperin
Mercadolibre, Inc.
July 27, 2007 Page 3

      S i n c e r e l y ,

Cicely LaMothe
Accounting Branch Chief

cc: Edward W. Elmore, Jr. ( via facsimile )
Hunton & Williams LLP

July 19, 2007

Mail Stop 4561

Marcos Galperin
Chief Executive Officer
Mercadolibre, Inc.
Tronador 4890, 8th Floor
Buenos Aires, C1430DNN
Argentina

Re: Mercadolibre, Inc.
Amendment 1 to Registration Statement on Form S-1
Filed July 13, 2007
File No. 333-142880

Dear Mr. Galperin:

 We have reviewed your filing and have the following comments.  We have
limited our review to only your financial statements and related disclosures and will make no further review of your document.  Where indicated, we think you should revise
your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may raise additional comments.

 Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Capitalization, page 36

1. Please tell us your factual basis for including the issuance of shares upon the exercise of warrants at the completion of your offering in your capitalization table.  In this regard, please clarify what commitment is in place by the warrant holders to exercise these instruments at the completion of the offering.

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

Marcos Galperin
Mercadolibre, Inc.
July 19, 2007 Page 2

2. We have reviewed the information supplementally provided to us in your response to comment 4.  Please expand your MD&A to include a discussion of the assumptions and methodologies used in determining fair value for the issuances disclosed to us.  In addition, please provide a robust discussion explaining the factors and assumptions made to support the significant increase in the fair value of your common stock of $9.64 in October 2006 to the initial public offering price of $17.00.  Lastly, please disclose that your valuations were prepared internally and why management chose not to obtain a contemporaneous valuation by an unrelated valuation specialist.

3. We also note your representation that given the limited number of grants, you believe any difference in compensation expense would not be material for 2006.  Please clarify if this also applies to the quarter ended March 31, 2007.  Lastly, quantify for us how you determined these amounts would be immaterial.

Note 2 – Change in Accounting Principle, page F-35

4. As previously requested in our prior comment 3, please disclose the assumptions made in determining the value attributed to your warrant liability for each period.

* * * *

As appropriate, please amend your registration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all information required under the Securities Act of 1933 and that they have provided all information investors require for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

We will consider a written request for acceleration of the effective date of the
registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in the above registration statement.  We will act on the request and,

Marcos Galperin
Mercadolibre, Inc.
July 19, 2007 Page 3
pursuant to delegated authority, grant acceleration of the effective date.

We direct your attention to Rules 460 and 461 regarding requesting acceleration
of a registration statement.  Please allow adequate time after the filing of any amendment for further review before submitting a request for acceleration.  Please provide this request at least two business days in advance of the requested effective date.

You may contact Rachel Zablow, Staff Accountant at (202) 551-3428 or the
undersigned at (202) 551-3413 if you have questions.

      S i n c e r e l y ,

Cicely LaMothe
Accounting Branch Chief

cc: Edward W. Elmore, Jr. ( via facsimile )
Hunton & Williams LLP

June 7, 2007

Mail Stop 4561

Marcos Galperin
Chief Executive Officer
Mercadolibre, Inc.
Tronador 4890, 8th Floor
Buenos Aires, C1430DNN
Argentina

Re: Mercadolibre, Inc.
Registration Statement on Form S-1
Filed May 11, 2007
File No. 333-142880

Dear Mr. Galperin:

 We have reviewed your filing and have the following comments.  We have
limited our review to only your financial statements and related disclosures and will make no further review of your document.  Where indicated, we think you should revise
your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may raise additional comments.

 Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Marcos Galperin
Mercadolibre, Inc.
June 7, 2007 Page 2
Form S-1

General

1. Please update your financial statements pursuant to Rule 3-12 of Regulation S-X.

Dilution, page 36

2. Please provide us with your basis for including your deferred tax assets in the calculation of net tangible book value.

Financial Statements

Note 2 – Summary of Significant Accounting Policies

Change in Accounting Principle, page F-15

3. Advise us and disclose how you determined the fair value of your preferred stock warrants for each period and the assumptions made in determining that value.

Note 11 – Stock Option Plan, page F-33

4. For equity instruments granted during the 12 months prior to the date of the most recent balance sheet included in the registration statement, supplementally provide the following information:
• For each grant date, disclose the number of options or shares granted, the exercise price, the fair value of the common stock, and the intrinsic value, if any, per option;
• Upon determining a price range, advise us how the fair value of your common stock in these transactions compares to the IPO price.

* * * *

As appropriate, please amend your registration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all information required under

Marcos Galperin
Mercadolibre, Inc.
June 7, 2007 Page 3
the Securities Act of 1933 and that they have provided all information investors require for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that:

‚ should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

‚ the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

‚ the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.

We will consider a written request for acceleration of the effective date of the
registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in the above registration statement.  We will act on the request and, pursuant to delegated authority, grant acceleration of the effective date.

We direct your attention to Rules 460 and 461 regarding requesting acceleration
of a registration statement.  Please allow adequate time after the filing of any amendment for further review before submitting a request for acceleration.  Please provide this request at least two business days in advance of the requested effective date.

Marcos Galperin
Mercadolibre, Inc.
June 7, 2007 Page 4
You may contact Rachel Zablow, Staff Accountant at (202) 551-3428 or the
undersigned at (202) 551-3413 if you have questions.

      S i n c e r e l y ,

Cicely LaMothe
Accounting Branch Chief

cc: Edward W. Elmore, Jr. ( via facsimile )
Hunton & Williams LLP