BKNGBooking Holdings

Please tell us in detail how you determined all of your operating segments or brands are properly aggregated into one reportable segment. Please be sure to address each of the aggregation criteria in ASC 280-10-50-11.

In accordance with your recent conversation with a representative of Booking Holdings Inc. (the “Company”), the Company will respond to your letter addressed to Glenn D. Fogel, Chief Executive Officer of the Company, dated June 25, 2019, relating to the Company’s Form 10-K for the year ended December 31, 2018, on or before July 24, 2019.

Best Regards,

/s/ Stephen Sonne

Stephen Sonne

Senior Vice President, Associate General Counsel and Corporate Secretary Read in the reply ↗

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

Rest of the question

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 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.

In accordance with your recent conversation with a representative of Booking Holdings Inc. (the “Company”), the Company will respond to your letter addressed to Glenn D. Fogel, Chief Executive Officer of the Company, dated July 29, 2019, relating to the Company’s Form 10-K for the year ended December 31, 2018, on or before September 6, 2019.

Best Regards,

/s/ Stephen Sonne

Stephen Sonne

Senior Vice President, Associate General Counsel and Corporate Secretary Read in the reply ↗