SecProbe.io

CORRESP
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April 21,
2008

Mr. Larry
Spirgel

Assistant
Director

United
States Securities and Exchange Commission

Division
of Corporation Finance

Mail
Stop 3720

100
F Street, N.E.

Washington,
D.C.  20549

RE:         Equifax Inc.

                                                Form 10-K for Fiscal Year Ended December 31, 2007

                                                Filed February 27, 2008

                                                File No. 001-06605

Dear
Mr. Spirgel:

This
letter sets forth our responses to comments received from the staff (the “Staff”)
of the Division of Corporation Finance of the United States Securities and
Exchange Commission (the “Commission”) in your letter to us dated March 24,
2008.

The
number of the responses and headings set forth below correspond to the numbered
comments and headings on the letter from the Staff.

Form 10-K for the Fiscal Year Ended December 31,
2007

Item 1.  Business, page 2

1.               In future filings, discuss
the nature and extent of your relationship with the third party data compilers
who provide information for your Direct Marketing Services and the over 1,600
organizations that provide payroll data for TALX services.

Response:  In future filings, we will
provide further information regarding the nature and extent of our
relationships with third party data compilers who provide information for our
Direct Marketing Services business and the organizations that provide payroll
data to our TALX segment, as follows (changes are highlighted in bold):

“Direct Marketing Services
(DMS)

Our
DMS products enable customers to target specifically defined market segments
and individuals based on individual consumer demographic characteristics;
design more effective and economically-efficient marketing campaigns;
facilitate improved direct mail response; and increase customer loyalty.  We offer this information in the form of a list
of consumers having specific attributes for ease of use by our customers.  These lists categorize consumers based on
meeting certain characteristics, interests or demographic attributes (e.g.,
those having recently acquired a new home).
Much of the information used in these products is
purchased or licensed from third parties under contracts which generally have
one to three year terms.  We compile the
remainder of the data that we use from public record sources and information
that is gathered from consumers directly through voluntary data

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submissions
to us, an example of which is product registration cards.  Since the purchased or licensed data is
obtained from public sources or other lists containing data that is generally
available from multiple sources, in the event that a termination of one or more
of these contracts occurs, we believe we could readily acquire the data from
other sources. The information in our DMS products is generally less regulated
and restricted than the credit information that we maintain.”

“TALX – The Work Number
(TWN) Services

We compile in our TWN
database payroll data obtained from over 1,600 companies, including over half
of the Fortune 500.  This data is
updated on a regular basis as employers transmit data electronically directly
to us each payroll period.  Employers
contract to provide this data to us for specified periods under the terms of
contracts which range from one to five year terms.  We use this data to provide employment and
income verifications to third-party verifiers; the fees we charge for these
services are generally per transaction.
After the expiration of the applicable contract, absent renewal by
mutual agreement of the parties, we generally do not have any further right to use
the employment data we obtained pursuant to the contract.  We have not experienced significant turnover
in the employer contributors to the TWN database because we generally do not
charge them to add their employment data to the database and the verification
service we offer relieves them of the administrative burden and expense of
responding to third party employment verification requests.”

North America Commercial Solutions, page 7

2.               In future filings, describe
your ownership and/or control of the Small Business Financial Exchange, Inc.
(SBFE) database.  We note the statement
on page 7 that you manage the database with the “owners” of the data.  We also note your statement on pages 10
and 11 that you own or “control” such data.
Please also discuss your ability to use such data when the agreement
terminates in 2012.

Response:  In future filings, we will
provide additional information regarding our ownership and/or control of the
Small Business Financial Exchange, Inc. (SBFE) database as follows
(changes are highlighted in bold):

“North
American Commercial Solutions

Our
Commercial Solutions products are derived from databases of credit, financial
and marketing information regarding businesses in the U.S. and Canada. The
business records included in the U.S. credit database have been developed
primarily as a part of the Small Business Financial Exchange, Inc., or
SBFE. SBFE members, which include a number of commercial
lending financial institutions, contribute their data to the member-owned SBFE
database which we exclusively manage.
Our contract with the SBFE to manage this database was renewed in 2007
and is scheduled to expire in 2012 unless renewed by mutual agreement of the
parties.  The information comprising the
database is generally not owned by us, and the participating organizations
could discontinue contributing information to the database or our management
contract may not be renewed; however, we believe that an event is unlikely
because contributors to the database use the aggregated information in the database
to conduct their business and we have a good working relationship with the SBFE
members as one of the original founders of this database.

Other
databases we have compiled include loan, credit card, public records and
leasing history data, as well as trade accounts receivable performance. In
2007, we further enhanced the depth of the database by adding Secretary of
State and SEC registration information. We also offer scoring and analytical
services, provided in an online format to customers obtaining a commercial
credit report, that provide additional information to help mitigate the credit
risk assumed by our customers. We also have a database which

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links
approximately 35 million commercial demographic data records from around the
world to build corporate family structures for enterprise visibility of
customers and suppliers.”

Technology
and Intellectual Property, page 10

3.               In future filings, identify
the duration of the Equifax trademark.
See Item 101(c) of Regulation S-K.
Also clarify the duration(s) of the licenses from Fair Isaac
Corporation and, if material, disclose any early termination provisions in such
licenses or your license from Seisint, Inc.

Response:  In future filings, we will clarify that,
depending upon the jurisdiction, our trademarks are valid as long as they are
in use and/or their registrations are properly maintained and they have not
been found to have become generic.
Registrations of trademarks can generally be renewed for additional ten
year terms indefinitely as long as the trademarks are in use.  Subject to our renewal rights, which we
intend to exercise, our  trademarks which use the
Equifax name currently have expiration dates ranging from August 4, 2008
to August 3, 2016.

Also,
as it relates to the licenses from Fair Isaac Corporation and Seisint, Inc.
we will provide additional disclosure by revising the existing disclosure as
follows:  “These licenses have ten-year
terms that began in 2002; may be
renewed on an annual basis thereafter;  and do not contain early termination provisions except for standard
provisions providing the right to terminate in the event of breach by other
party.”

Item
5.  Market for the Registrant’s Common
Equity…, page 26

4.               In future filings,
provide the disclosure graph required by Item 201(e) of Regulation S-K.

Response:  As permitted by Instruction 7 to Item 201(e),
we have provided our common stock cumulative total return and peer index stock performance
return disclosure graph on page 12 of our Annual Report to Shareholders
for the year ended December 31, 2007.

Consolidated
Financial Statements

2.  Acquisitions

Purchase
Price Allocation, page 72

5.               We note on page 72 that
you are amortizing the acquired customer relationships over a weighted average
useful life of 20.8 years.  In the prior
year, customer relationships had a weighted average useful life of 7.0
years.  Tell us your basis for the
weighted average useful life of 20.8 years.
Also, tell us your basis for the weighted average useful lives of 6.0
for the proprietary database.

Response:  The 2007
acquired customer relationships have a longer weighted average useful life than
2006 because of the specific differences in expected customer lives, which are
consistent with differences in actual customer attrition experience, of the
businesses acquired (i.e., TALX in 2007 and Austin Tetra in 2006).  The customer relationships acquired in the
TALX acquisition were based on existing customer relationships of both The Work
Number business, which have an expected useful life of 24 years, and Tax and
Talent Management business, which have an expected useful life of 11 years. The
weighted average useful life of the TALX customer relationships is 20.8 years.

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The
TALX customer relationship intangible assets represent the value expected to be
derived from the sale of information and services to existing TALX customers as
of the acquisition date as well as the future cash flows related to the new
records expected to be added to The Work Number database from existing employer
clients.  As described further in the
response to question number one above, existing employer clients contribute
their employment data to The Work Number database generally free of
charge.  Historically, there have been
very low attrition rates of employer clients due to the cost-effectiveness of
The Work Number services impact on an employer clients’ obligation to fulfill
income and employment verification for their employees. In order to determine
the fair value of the customer relationships, we calculated the net present
value of the future cash flows expected to be derived from customers using an
income approach, incorporating assumptions about customer attrition rates.  Our customer attrition rate assumptions were
based on historical customer attrition rates, which we believe to be
representative of future customer attrition rates and market conditions.  The customer relationship useful lives are
consistent with the period over which we expect our existing TALX customers to
purchase these services or provide employee records and therefore contribute
directly to our future cash flows.  The
expected lives of the customer relationships related to the TALX acquisition
are longer than those determined for our Austin-Tetra acquisition due in part
to the unique nature of The Work Number services and the strong market position
of TALX as the largest national provider of income and employment data
verification services.  Austin-Tetra, by
contrast, was our $35 million, 2006 acquisition which provides complementary
commercial data services and which competes in a market with several larger
competitors including Dun & Bradstreet.

The
proprietary database for The Work Number represents the value of the records
that existed in The Work Number database as of the TALX acquisition date.  We determined the fair value of the existing
records by calculating the net present value of future cash flows expected to
be derived from the sale of these records.
The proprietary database useful life of six years is consistent with the
historical purchasing patterns of TALX customers.

Additionally,
Equifax Inc. (the “Company”) acknowledges the following:

·                  The Company is responsible for the adequacy
and accuracy of the disclosure in the filing;

·                  Staff comments or changes to disclosure in
response to Staff comments do not foreclose the Commission from taking any
action with respect to the filing; and

·                  The Company may not assert Staff comments as a
defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

Please
contact the undersigned at (404) 885-8440 if you have any additional questions
regarding our responses to your inquiries as discussed above.

Sincerely,

  /s/
  Nuala M. King

  Nuala
  M. King

  Senior
  Vice President and

  Corporate
  Controller

cc:         Richard F. Smith, Chairman
and Chief Executive Officer

                        Lee Adrean,
Corporate Vice President and Chief Financial Officer

                        Kent E. Mast,
Corporate Vice President and Chief Legal Officer

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