SecProbe.io

January 2, 2014

Via E-mail
Mr. Lee Adrean
Corporate Vice President &
Chief Financial Officer
Equifax Inc.
1550 Peachtree Street, N.W.
Atlanta, Georgia 30309

Re: Equifax Inc.
Form 10-K for the Fis cal Year Ended December 31, 2012
Filed February 22, 2013
Response dated November 6 , 2013
File No. 001 -06605

Dear Mr. Adrean :

 We have reviewed your response and have the following comment s.  Please provide us
with the requested information so we may better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information or by advising us when you will provide the requested response.   If you do not
believe our comment s appl y to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to our comment s, we may have
additional comments.

Form 10 -K for the Year Ended December 31 , 2012
Goodwill and Other Intangib le Assets, page 73
Indefinite -Lived Intangible Assets, page 74
1. We have reviewed your response to prior comment one.  You state in your response that
“(i)n connection with Equifax’s December 28, 2012 acquisition of certain credit services
business assets and operations of CSC Credit Services Inc. (the Acquisition), we initially
recorded an indefinite lived intangible asset disclosed as contractual/territorial rights
valued at $159 million.   We have now concluded that this asset represents a reacquired
right as defined in ASC 805 -20-25-14”.  We also note that in your December 31, 2012

Mr. Lee Adrean
Equifax Inc.
January 2, 2014
Page 2

 Form 10 -K you identified the purchase price as being final, except for certain items that
did not appear to relate to your acquired intangible assets.  In that regard, please:
 tell us the basis for initially determining that the intangible assets acquired were
contractual/territorial rights that were indefinite lived;
 explain, in detail, why you now believe that these intangible assets are reacquired
rights that have a finite  life; and
 explain, in detail, why the value of the intangible assets decreased from $159 million
to $73 million.  Specifically address the change in the term of the life and all other
factors that impacted the value.

2. You state in your response that “Equi fax has concluded that the adjustment to the
accounting for the business combination, and the related adjustments to amortization
expense, which should have been recorded at December 31, 2012 and in subsequent
periods, do not require restatement of previou sly issued financial statements.  The
conclusion is based on both the materiality of the adjustments as well as an evaluation of
all of the qualitative factors in Staff Accounting Bulletin 99”.  Please provide us with
your analysis under SAB 99 and tell us  what qualitative factors the company considered
in making the assessment that the misapplication of GAAP to a significant portion of the
$1 billion acquisition of CSC was not material.

3. Please tell us whether or not this misapplication of GAAP impacted t he company’s prior
assessment of Internal Controls over Financial Reporting and whether or not this resulted
in any changes in your internal controls.

4. Please explain why the remaining $96 million of indefinite -lived intangible assets are
now described as acquired operating agreements, and continue to be accounted for as
indefinite -lived intangible assets.  Please tell us how, in light of your ability to limit the
contractual term of the rights conveyed in the operating agreements, you determined that
the reacquisition of those rights have an indefinite term.  Include reference to
authoritative literature used as guidance.
You may contact Kenya Wright Gumbs, Staff Accountant, at (202) 551 -3373 or Robert
S. Littlepage Jr., Accountant Branch Chief, at (202) 551-3361, if you have questions regarding
comments on the financial statements and related matters.  Please contact me at (202) 551 -3810
with any other questions.

Sincerely,

/s/ Robert S. Littlepage Jr.  for

Larry Spirgel
Assistant Director