TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo December 7, 2022 Michael Miebach President and Chief Executive Officer Mastercard Inc. 2000 Purchase Street Purchase, NY 10577 Re: Mastercard Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 11, 2011 Response dated August 5, 2022 File No. 001-32877 Dear Michael Miebach: We have reviewed your August 5, 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 additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 25, 2022 letter. Form 10-K for the Fiscal Year Ended December 31, 2021 Notes to consolidated financial statements Note 3. Revenue, page 77 1. We have reviewed your response to our prior comment 1 in your letter dated July 8, 2022 and your response to our prior comment 2 in your letter dated August 5, 2022. We do not believe your disclosure of gross revenue by source with total rebates and incentives shown as a separate line, complies with the requirements of ASC 606. In this regard, we note that these categories are not revenue based on the recognition and measurement guidance in ASC Topic 606. Please revise your disclosure as appropriate. Michael Miebach Mastercard Inc. December 7, 2022 Page 2 You may contact Tony Watson at (202) 551-3318 or Suying Li at (202) 551-3335 if you have questions regarding comments on the financial statements and related matters. FirstName LastNameMichael Miebach Sincerely, Comapany NameMastercard Inc. Division of Corporation Finance December 7, 2022 Page 2 Office of Trade & Services FirstName LastName