July 29, 2019

Glenn Fogel
Director, Chief Executive Officer and President
Booking Holdings Inc.
800 Connecticut Avenue
Norwalk, CT 06854

       Re: Booking Holdings Inc.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Filed February 27, 2019
           Response Dated July 23, 2019
           File No. 001-36691

Dear Mr. Fogel:

        We have reviewed your July 23, 2019 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.



Form 10-K for Fiscal Year Ended December 31, 2018

Summary of Significant Accounting Policies
Segment Reporting, page 83

1.    We have reviewed your response to our comment. Please provide additional
quantitative
      information in support of your assertion that the various operating
segments or brands
      have similar economic characteristics. For example, we understand that
Adjusted
      EBITDA is a profitability measure used by the CODM to assess the
performance of the
      brands, thus data regarding historical and estimated future Adjusted
EBITDA margin by
      brand should be provided. Please tell us what other profitability
measures are used by the
      CODM to assess the performance of the brands and provide similar
quantitative data with
      respect to these measures by brand. While we note your point that the
"take rate" for
      your "core online travel company brands" demonstrate similar long-term
financial
      performance, it is unclear whether "take rate" is a measure used by the
CODM to assess
 Glenn Fogel
Booking Holdings Inc.
July 29, 2019
Page 2
         operating segment performance. Moreover, we note this metric does not
apply to the
         KAYAK, OpenTable and Rentalcars.com brands/operating segments and you
have not
         provided any quantitative data in support of the economic similarity
of these brands to
         each other or your other core online travel company brands, but rather
you have pointed
         out the relative quantitative immateriality of these brands to
consolidated revenues and
         Adjusted EBITDA. If your position with respect to the aggregation of
these brands with
         your core online travel company brands is their quantitative
immateriality, please tell us
         your consideration of the guidance in ASC 280-10-50-13 and 50-15 with
respect to your
         segment presentation of these brands.
        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 Robyn Manuel, Staff Accountant, at 202-551-3823 or Bill
Thompson,
Branch Chief, at 202-551-3344 with any questions.



FirstName LastNameGlenn Fogel                                  Sincerely,
Comapany NameBooking Holdings Inc.
                                                               Division of
Corporation Finance
July 29, 2019 Page 2                                           Office of
Consumer Products
FirstName LastName