June 25, 2019

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

       Re: Booking Holdings Inc.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Filed February 27, 2019
           File No. 001-36691

Dear Mr. Fogel:

      We have reviewed your filing 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 the comment, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2018

Note 2. Summary of Significant Accounting Policies
Segment Reporting, page 83

1.    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.
        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 Robyn Manuel, Staff Accountant, at 202-551-3823 or Bill
Thompson,
Branch Chief, at 202-551-3344 with any questions.
 Glenn Fogel
Booking Holdings Inc.
June 25, 2019
Page 2

FirstName LastNameGlenn Fogel        Sincerely,
Comapany NameBooking Holdings Inc.
                                     Division of Corporation Finance
June 25, 2019 Page 2                 Office of Consumer Products
FirstName LastName