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                            September 19, 2023

       Adrianne Lee
       Chief Financial Officer
       Overstock.com, Inc.
       799 West Coliseum Way
       Midvale, UT 84047

                                                        Re: Overstock.com, Inc.
                                                            Form 10-K for the
fiscal year ended December 31, 2022
                                                            Filed February 24,
2023
                                                            File No. 000-49799

       Dear Adrianne Lee:

              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 filed February 24, 2023

       General

   1.                                                   We note that you
provided more expansive climate-related disclosure on your
                                                        website than you
provided in your SEC filings. Please advise us what consideration you
                                                        gave to providing the
same type of climate-related disclosure in your SEC filings as you
                                                        provided on your
website.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
       27

   2.                                                   We note your risk
factor on page 17 referencing the potential adoption of climate change
                                                        rules. To the extent
material, discuss the indirect consequences of climate-related
                                                        regulation or business
trends, such as the following:
                                                            decreased demand
for goods or services that produce significant greenhouse gas
                                                             emissions or are
related to carbon-based energy sources;
 Adrianne Lee
Overstock.com, Inc.
September 19, 2023
Page 2
             increased demand for goods that result in lower emissions than
competing products;
             increased competition to develop innovative new products that
result in lower
           emissions;
             increased demand for generation and transmission of energy from
alternative energy
           sources; and
             any anticipated reputational risks resulting from operations or
products that produce
           material greenhouse gas emissions.
3.    Discuss the physical effects of climate change on your operations and
results. This
      disclosure may include the following:
          severity of weather, such as floods, hurricanes, sea levels,
arability of farmland,
           extreme fires, and water availability and quality;
          quantification of material weather-related damages to your property
or operations;
          potential for indirect weather-related impacts that have affected or
may affect your
           major customers, suppliers or partners; and
          any weather-related impacts on the cost or availability of insurance.
      Your response should include quantitative information for each of the
periods for which
      financial statements are presented in your Form 10-K and explain whether
changes are
      expected in future periods.
4.    If material, please discuss any purchase or sale of carbon credits or
offsets and the effects
      on your business, financial condition, and results of operations. Ensure
you provide
      quantitative information with your response for each of the periods for
which financial
      statements are presented in your Form 10-K and for any future periods.
        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.

       Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or
Karina
Dorin, Attorney-Adviser, at (202) 551-3763 with any questions.



                                                             Sincerely,
FirstName LastNameAdrianne Lee
                                                             Division of
Corporation Finance
Comapany NameOverstock.com, Inc.
                                                             Office of Energy &
Transportation
September 19, 2023 Page 2
cc:       Todd Kaye
FirstName LastName