May 5, 2025

Jamie Miller
Chief Financial Officer
PayPal Holdings, Inc.
2211 North First Street
San Jose, California 95131

       Re: PayPal Holdings, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2024
           Filed February 4, 2025
           File No. 001-36859
Dear Jamie Miller:

       We have reviewed your filing 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
Notes to Consolidated Financial Statements
Note 2 - Revenue
Disaggregation of Revenue, page 76

1.     We note you disaggregate revenue by geography, as required by the
entity-wide
       disclosures under ASC 280-10-50-41a, and by "revenue category,"
consisting of
       "transaction revenues" (91% of revenue for 2024) and "revenue from other
value
       added services" (9% of revenue for 2024). With respect to the disclosure
requirements
       of ASC 606-10-50-5, please tell us how you considered the guidance in
paragraphs
       ASC 606-10-55-89 through 55-91 in selecting the appropriate categories
to use to
       disaggregate revenue. In this regard, we note factors such as:

             various references to and disclosure focused on your two customer
types -
           consumers and merchants - in your filing;
             you have general managers for various lines of business, such as
"Consumer
           Group," "Large Enterprise," "Small Business & Financial Services,"
and "Global
 May 5, 2025
Page 2

           Markets" (per your February 2025 investor day presentations);
             you present total payment volume metrics to investors for various
products, such
           as "PayPal branded checkout," "PSP," and "Venmo" in your quarterly
earnings
           presentations; and
             your remittance business, Xoom, had stagnated and been on a
negative revenue
           trajectory, and various other comments about contributions from
various business
           lines to your growth (per your Q1 2024 earnings call).
Note 13 - Commitments and Contingencies
Protection Programs, page 110

2.     We note your reconciliation of the changes in the allowance for
transaction losses and
       negative customer balances, which you consider to be assurance-type
       warranties, includes reconciling items "provision," "realized losses,"
and "recoveries."
       Please revise your tabular reconciliation to include the reconciling
items specified by
       ASC 460-10-50-8c.
        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 Amy Geddes at 202-551-3304 or Lyn Shenk at 202-551-3380
if you
have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Trade &
Services
cc:   Brian Yamasaki