United States securities and exchange commission logo





                              May 6, 2021

       Andy Cring
       Chief Financial Officer
       eBay Inc.
       2025 Hamilton Avenue
       San Jose, CA 95125

                                                        Re: eBay Inc.
                                                            Form 10-K for the
Year Ended December 31, 2020
                                                            Filed February 4,
2021
                                                            Form 10-Q for the
Fiscal Quarter Ended March 31, 2021
                                                            Filed April 29,
2021
                                                            File No. 001-37713

       Dear Mr. Cring:

              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 the Year Ended December 31, 2020

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 36

   1.                                                   Please quantify here
and in your interim period reports each item cited as a variance factor
                                                        so that investors may
understand the magnitude and relative impact of each on your
                                                        results. For example,
we note several instances especially in regard to expenses, and in
                                                        particular "Interest
and Other, Net" for the first quarter of fiscal 2021, where this is the
                                                        case. Refer to section
501.04 of the Staff   s Codification of Financial Reporting Policies
                                                        for guidance.
 Andy Cring
FirstName
eBay Inc. LastNameAndy Cring
Comapany
May  6, 2021NameeBay Inc.
May 6,
Page 2 2021 Page 2
FirstName LastName
Net Transaction Revenues, page 37

2.       In addition to your definition of the metric "take rate," please
disclose what the metric
         represents, why it provides useful information to investors and how
you use it in
         managing or monitoring your performance. Refer to Commission Release
No. 33-10751
         for guidance.
Liquidity and Capital Resources
Cash Flows
Continuing Operating Activities, page 44

3.       Your disclosure here and in the latest Form 10-Q appears to emphasize
how cash provided
         by operating activities was derived for each period. Pursuant to Item
303(a) and (b) of
         Regulation S-K, your discussion should be an analysis of material
changes that impacted
         operating cash from period to period. Note that references to results,
noncash items, and
         working capital items may not provide a sufficient basis to understand
how operating cash
         actually was affected between periods. In this regard, your analysis
should discuss the
         reasons underlying variance factors cited. Refer to section IV.B and
B.1 of SEC Release
         No. 33-8350 for guidance, and section 501.04 of the Staff   s
Codification of Financial
         Reporting Releases regarding quantification of variance factors cited.
Please revise your
         disclosure as appropriate.
Form 10-Q for the Fiscal Quarter Ended March 31, 2021

Management's Discussion and Analysis of Financial Conditions and Results of
Operations
Net Revenues
Net Transactions Revenues , page 33

4.       You attribute the increase in net transaction revenue in the first
quarter of 2021 primarily
         due to an increase in GMV and take rate. Please tell us and disclose
the key drivers and
         underlying factors that caused this increase. Your earnings release
for this quarter
         mentions the impact of your revenue initiatives to scale management of
global payments
         which resulted in over 52% of global on-platform volume processed
through managed
         payments, increases in global sellers, and over 80% of the payments
migration completed
         in the U.S. that appear would be meaningful disclosure here. In
particular, explain to us
         and disclose as appropriate how the migration to managed payments on a
global basis
         correlated to the the significant positive GMV growth and net
transaction revenue
         growth. Refer to Items 303(c) and (b)(2)(i) through (iii) as
appropriate, of Regulation S-
         K.
 Andy Cring
FirstName
eBay Inc. LastNameAndy Cring
Comapany
May  6, 2021NameeBay Inc.
May 6,
Page 3 2021 Page 3
FirstName LastName
        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 Robert Shapiro at (202) 551-3273 or Doug Jones at (202)
551-3309 if
you have questions regarding comments on the financial statements and related
matters.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services
cc:      Marie Huber, General Counsel