EXPEExpedia Group

We note that you disclose and discuss revenue by segment on page 49. Please revise your MD&A section to also discuss the changes in results of operations by segment. In this regard, you should discuss any significant changes in costs and profitability measure related to each segment, such as Adjusted EBITDA, which is disclosed in Note 19 to the financial statements as your primary operating metric for your segments,

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or operating income. See Item 303(A) of Regulation S-K.

The Company acknowledges the Staff's comment and in response, in future filings, beginning with our next Quarterly Report on Form 10-Q for the quarter ended June 30, 2017, we will include a table detailing Adjusted EBITDA, our primary operating metric, by segment as well as add discussion of the drivers of any significant changes in Adjusted EBITDA by segment. In addition, we will add additional disclosure including the definition and reconciliation to the most directly comparable GAAP financial measure of Adjusted EBITDA as required for the newly added non-GAAP information.

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Using our most recent quarterly results as an example, we have provided our sample disclosure for the quarter ended March 31, 2017 compared to 2016 as set forth on Attachment A to this letter.

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Please revise to include fair value measurement disclosures related to assets and liabilities measured at fair value on a non-recurring basis, such as the indefinite lived intangible assets that were impaired during 2016. See requirements in ASC 820-10-50-2.

The Company acknowledges the Staff’s comment and we have reviewed the disclosure requirements of ASC 820-10-50-2 in light of the comment. Upon our review, we respectfully believe that the Company's consolidated financial statements include the significant disclosure requirements related to assets measured at fair value on a non-recurring basis in the footnotes, albeit outside of the referenced Note 5 – Fair Value Measurements.

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For example, our disclosures of the indefinite lived intangible assets impairment on page F-26, in Note 7 – Goodwill and Intangible Assets, Net, includes the required measurement date disclosure and reason for the measurement and impairment. In addition, on page F-13, Note 2 – Significant Accounting Policies, our disclosure includes the valuation techniques for such assets. However, we acknowledge that the disclosure requirements relating to the level within the hierarchy of the fair value measurements (Level 3) and the fair value measurement at the measurement date ($76 million) were not included and that aggregating the information into one location would be helpful to the reader of the financial statements. In future filings, as applicable, we will revise our fair value measurement footnote disclosures to include the aggregate of any such non-recurring fair value measurements into the Fair Value Measurements footnote, and ensure completeness of the required disclosures, as requested by the Staff.

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Please revise to disclose your revenue by product or service in accordance with ASC 28010-50-40.

We acknowledge the Staff’s comment and have reviewed the requirements of ASC 280-10-50-40, which requires that revenues from external customers for each product or service or each group of similar products and services be reported separately unless it is impracticable to do so.

We note that, in our MD&A section on pages 40-41 of our Form 10-K for the fiscal year ended December 31, 2016, we disclose the percentage of total revenue for Hotel, HomeAway, Air and Advertising and Media.

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In addition, on page 50, we disclose revenue by business model components: Merchant, Agency, Advertising and Media and HomeAway. These categories also align with our discussion of revenue recognition in Note 2 – Significant Accounting Policies in our notes to consolidated financial statements. However, in response to the Staff’s comment, we have evaluated our entity-wide disclosures regarding revenue from similar products and services in our consolidated financial statements and will present disclosures in the segment footnote in the notes to consolidated financial statements in future filings, beginning with our next Annual Report on Form 10-K. Using our most recent annual results as an example, we have provided indicative disclosure below.

Revenue by groups of products and services are as follows:

Year ended December 31,

2016

2015

2014

($ in thousands)

Lodging(1)

$

6,020,668

4,638,481

4,046,632

Advertising and media

807,383

565,704

479,219

Air

777,696

566,123

468,225

Other(2)

1,167,817

902,009

769,409

Total revenue

8,773,564

6,672,317

5,763,485

(1) During the first quarter of 2017, we began disclosing lodging revenue, which includes both hotel accommodations as well as alternative accommodations primarily made through HomeAway.

(2) Other includes car rental, insurance, destination services, cruise and fee revenue related to our corporate travel business, among other revenue streams, none of which are individually material.

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We note that in the Financial Summary and Operating Metrics section on page 1, you present Adjusted EBITDA prior to operating and net loss as calculated in accordance with GAAP. To avoid giving undue prominence to this non GAAP measure, please revise to present the most directly comparable GAAP measure, presumably net income (loss), prior to the presentation of this non-GAAP measure.

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We also note that in your reconciliation of Adjusted EBITDA on page 21, you begin the reconciliation with the non-GAAP measure rather than the GAAP measure. Please revise to begin the reconciliation with the most directly comparable GAAP measure, net income (loss). See

We acknowledge the Staff's comment and in response the Company will revise the presentation in future filings, beginning with our next Form 8-K furnished to present second quarter of 2017 financial results, to reorder Adjusted EBITDA so it appears under operating and net income (loss) in our Financial Summary and Operating Metrics section and will also begin the reconciliation of the non-GAAP measure with the most directly comparable GAAP measure, net income (loss). Read in the reply ↗