May 31, 2019 Michael Goss Chief Financial Officer Sotheby's 1334 York Avenue New York, New York, 10021 Re: Sotheby's Form 10-K for the Fiscal Year Ended December 31, 2018 Filed February 28, 2019 File No. 001-09750 Dear Mr. Goss: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2018 Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Measures, page 48 1. We note the non-GAAP measure Adjusted Expenses excludes agency direct costs, cost of inventory sales and cost of finance revenues. Please explain your basis for disclosing this measure and how it is useful to an investor. As part of your response, tell us how you determined that it is appropriate to disclose a non-GAAP measure of expenses that excludes all costs of revenue. Consolidated Income Statements, page 57 2. Please explain your basis for not including the total amount of SFS interest expense as cost of finance revenue in 2018. Although we note the changes in the credit facility in 2018, it is unclear why this would result in a change in the presentation of interest for the SFS business. Please advise. Michael Goss Sotheby's May 31, 2019 Page 2 Notes to Consolidated Financial Statements Note 3 - Segment Reporting, page 72 3. Please revise the table on page 73 to include SFS interest expense. In this regard, we refer you to the response to comment number 4 in your letter dated May 3, 2017. Refer to ASC 280-10-50-22(c). 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 Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Christine Dietz, Assistant Chief Accountant, at 202-551-3408 if you have any questions. Sincerely, FirstName LastNameMichael Goss Division of Corporation Finance Comapany NameSotheby's Office of Information Technologies May 31, 2019 Page 2 and Services FirstName LastName