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,
                                                            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
       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.
 Pedro Arnt
FirstName  LastNamePedro Arnt
MercadoLibre,  Inc.
August 15, NameMercadoLibre,
           2022               Inc.
Page 2 15, 2022 Page 2
FirstName LastName
       You may contact Abe Friedman at 202-551-8298 or Lyn Shenk at
202-551-3380 with
any questions.


                                                      Division of Corporation
                                                      Office of Trade &