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                             June 28, 2022

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

                                                        Re: Booking Holdings
Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Filed February 23,
2022
                                                            Form 10-Q for the
Quarter Ended March 31, 2022
                                                            Filed May 4, 2022
                                                            File No. 001-36691

       Dear Mr. Fogel:

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

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

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

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Trends, page 39

   1.                                                   We note from your
disclosures that the impact of cancellation rates on your
                                                        accommodation room
nights has in the past and may in the future have a significant
                                                        impact on your
operations including room nights, revenues, marketing efficiency,
                                                        customer service costs
and expected credit losses. Please disaggregate, discuss and
                                                        analyze trends in your
cancellation rates in more detail. Refer to Item 303 of Regulation
                                                        S-K.
 Glenn Fogel
Booking Holdings Inc.
June 28, 2022
Page 2
Form 10-Q for the Quarter Ended March 31, 2022

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Trends, page 27

2.       We note your disclosure that you saw an immediate negative impact on
your room night
         trends, primarily in Europe after the news broke that Russia had
invaded Ukraine. You
         also disclose that you suspended the booking of travel services in
Russia and Belarus in
         early March which led to the loss of new bookings as well as
significantly elevated levels
         of cancellations of reservations from these countries. Please describe
the adverse impact
         of Russia   s invasion of Ukraine on your business and results of
operations. Discuss how
         management considered the invasion, higher oil prices, and inflation
in the development
         of your estimates for cancellations and sales incentives. Describe and
quantify for
         investors how the changes in these estimates impact your revenue. For
additional
         guidance, refer to the Division of Corporation Finance   s Sample
Letter to Companies
         Regarding Disclosures Pertaining to Russia   s Invasion of Ukraine and
Related Supply
         Chain Issues.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Sondra Snyder, Senior Staff Accountant at (202) 551-3332
or Robert
Babula, Senior Staff Accountant at (202) 551-3339 with any questions.



FirstName LastNameGlenn Fogel                                 Sincerely,
Comapany NameBooking Holdings Inc.
                                                              Division of
Corporation Finance
June 28, 2022 Page 2                                          Office of Energy
& Transportation
FirstName LastName