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CORRESP
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Nuala M. King

SVP & Corporate Controller

1550 Peachtree St, N.W.

Atlanta, GA 30309

(404) 885-8440

Fax (404) 885-8087

nuala.king@equifax.com

January 27, 2014

VIA EDGAR

Mr. Larry Spirgel

Assistant Director

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Re: Equifax Inc.

    Form 10-K for the Fiscal Year Ended December 31, 2012

    Filed February 22, 2013

    Response dated November 6, 2013

    File No. 001-06605

Dear Mr. Spirgel:

This letter is being
submitted in response to the comments provided by the Staff of the Division of Corporation Finance (the “Staff”) of
the United States Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter dated
January 2, 2014 (the “Comment Letter”) with respect to the above-referenced Form 10-K for the Year Ended December
31, 2012 (the “Form 10-K”) and Form 10-Q for the Quarter Ended September 30, 2013 (the “Form 10-Q”), filed
by Equifax Inc. (“we,” “us,” “our,” “Equifax” or the “Company”) and
the Company’s responses to prior Staff comments referenced above.

For your convenience,
we have set forth each comment from the Comment Letter in bold typeface and have included the Company’s response below it.
The numbered paragraphs in this letter correspond to the numbered paragraphs of the Comment Letter.

Form 10-K for the Year Ended December 31, 2012

Goodwill and Other Intangible Assets, page 73

Indefinite-Lived Intangible Assets, page 74

    1

 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 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.

Response

In connection with our December 28, 2012 acquisition
of the credit services business assets and operations of Computer Sciences Corporation, Inc., a subsidiary of Computer Sciences
Corporation (the “CSC Acquisition”) Equifax recorded working capital and tangible net assets of $16 million, finite-lived
intangible assets of $518 million, contractual/territorial rights of $159 million and goodwill of $307 million. The contractual/territorial
rights were described in our historic SEC filings as “contractual/territorial rights representing the estimated fair value
of rights to operate in certain territories acquired through the purchase of independent credit reporting agencies in the U.S.
and Canada”.

As background to this discussion, Equifax entered
into an agreement with CSC in 1988, which along with several subsequent amendments (collectively the “Affiliation Agreement”)
established terms for the relationship between Equifax and CSC. Through the Affiliation Agreement, Equifax had conveyed to CSC
certain rights in what was defined as the CSC territory (i.e. specific postal zip codes in the United States). Specifically, Equifax
had granted CSC the right to use Equifax credit information to sell to third parties in the CSC territory using the Equifax trade
name as well as the right to use Equifax information technology systems and products. Equifax reacquired all rights granted by
the Affiliation Agreement as a part of the CSC acquisition and as a result Equifax has a reacquired right. The $159 million asset
which we initially incorrectly described in our 2012 Annual Report on Form 10-K as a contractual/territorial right was the right
reacquired from CSC. Notwithstanding its description in the financial statements, it was incorrectly valued using an indefinite
period. As we discuss in detail later in this response, we subsequently corrected our accounting and treated the reacquired right
as a definite-lived intangible asset both from a valuation perspective as well as its amortization period.

In December 2012, when we originally accounted for
the business combination, we considered the reacquired right to be indefinite in nature because of the ability of CSC to renew
the arrangement was effectively indefinite. The agreement contained an “evergreen” clause providing for automatic renewal
after the initial ten-year term for successive ten-year terms, indefinitely, unless CSC provided written notice to us of its election
to terminate by a specified period of time prior to the end of the applicable term. Equifax did not have the right (without cause)
to cancel or not renew the agreement or prohibit CSC from not renewing.

    2

We did not appropriately consider the guidance in
ASC 805-20-25-14 which limited the life, and resulting value, of a reacquired right to the “remaining contractual term of
the related contract regardless of whether market participants would consider potential contractual renewals in determining its
fair value”, a concept that was not codified in GAAP until 20081. While
the Affiliation Agreement contained an “evergreen” renewal provision, the current term expired on August 1, 2018. The
valuation of the asset was modified to use a discounted cash flow model with cash flows through August 1, 2018 as compared to the
perpetual cash flows in the initial valuation. The modified valuation resulted in a value of $73 million being ascribed to the
rights that we reacquired in the business combination as compared to the $159 million we had valued the assets based upon an indefinite
life. The $86 million difference between the $159 million original value and the revised value of $73 was recorded to goodwill
as all other identifiable assets had already been appropriately valued.

 2. You state in your response that “Equifax 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 previously 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.

Response

Prior to the filing of our Quarterly Report on Form
10-Q for the period ended September 30, 2013, Equifax performed a detailed SAB 99 analysis. These factors were documented in a
memo, which we shared with our independent auditors. We presented a summary of this memo to the Audit Committee of our Board of
Directors prior to the filing of our September 30, 2013 Form 10-Q.

The analysis evaluated the impact of the corrected
valuation on key financial statement balances reported in our Annual Report on Form 10-K for the year ended December 31, 2012 and
our Quarterly Reports on Form 10-Q for the periods ended March 31, 2013 and June 30, 2013 and September 30, 2013. In addition,
we evaluated the financial measures used generally in the market to value our stock (EBITDA and Revenue) and concluded that because
none of the adjustments had any impact on these financial measures, we should focus our analysis on the impact of the error on
our financial statements. That analysis follows (dollar values in millions):

1 FAS 141(R) was required to be applied prospectively
to business combinations for which the acquisition date is on or after the beginning of the first annual reporting period beginning
on or after December 15, 2008

    3

Consolidated Balance Sheet
at December 31, 2012

    % of

    Reported

    Reported
    Adjustment
    Balance

    Goodwill
    $ 2,290.4
    $ 87.9
      3.8 %

    Indefinite-lived intangibles
      254.4
      (158.8 )
      62.4 %

    Purchased intangibles, net
      987.7
      70.9
      7.2 %

    Total assets
      4,511.1
      -

Consolidated Balance Sheet
at March 31, 2013

    % of

    Reported

    Reported
    Adjustment
    Balance

    Goodwill
    $ 2,253.5
      87.9
      3.8 %

    Indefinite-lived intangibles
      254.5
      (158.8 )
      62.4 %

    Purchased intangibles, net
      945.7
      67.6
      7.2 %

    Total assets
      4,387.2
      (3.3 )
      0.1 %

Consolidated Balance Sheet
at June 30, 2013

    % of

    Reported

    Reported
    Adjustment
    Balance

    Goodwill
    $ 2,248.3
      87.9
      3.8 %

    Indefinite-lived intangibles
      254.3
      (158.8 )
      62.5 %

    Purchased intangibles, net
      918.4
      64.3
      7.0 %

    Total assets
      4,373.6
      (6.6 )
      0.2 %

Consolidated Statement of
Operations for the three months ended March 31, 2013

    % of

    Reported

    Reported
    Adjustment
    Balance

    Depreciation and amortization
    $ 47.9
      3.3
      6.9 %

    Operating income
      149.0
      (3.3 )
      2.2 %

    Net income attributable to Equifax
      101.1
      (2.0 )
      2.0 %

Consolidated Statement of
Operations for the three months ended June 30, 2013

    % of

    Reported

    Reported
    Adjustment
    Balance

    Depreciation and amortization
    $ 44.1
      3.3
      7.5 %

    Operating income
      158.1
      (3.3 )
      2.0 %

    Net income attributable to Equifax
      90.5
      (2.0 )
      2.2 %

    4

Consolidated Statement of
Operations for the six months ended June 30, 2013

    % of

    Reported

    Reported
    Adjustment
    Balance

    Depreciation and amortization
    $ 92.0
      6.6
      7.2 %

    Operating income
      307.1
      (6.6 )
      2.1 %

    Net income attributable to Equifax
      191.6
      (4.0 )
      2.1 %

Consolidated Statement of
Operations for the three months ended September 30, 2013

    % of

    Reported

    Reported
    Adjustment
    Balance

    Depreciation and amortization
    $ 51.8
      (6.6 )
      12.7 %

    Operating income
      150.0
      6.6
      4.4 %

    Net income attributable to Equifax
      83.5
      4.0
      4.8 %

We considered first the overall impact to income and
total assets in each of the periods and determined that the impact of the errors was not material. We then looked at the other
measures listed above and while some were larger by percentage, the overall impact was not considered to be material. Equifax considered
the 62% overstatement in indefinite lived intangibles on the balance sheet and concluded that users of the financial statements
would not view the indefinite-lived intangibles substantially differently than goodwill. Combining the indefinite lived intangibles
and goodwill, which are summarized above, results in an overstatement of 2.9% at each balance sheet date, which is not material.
Further, we did not have impairments in any periods and these adjustments would not have created an impairment to any of the intangible
assets.

As it related to the 2012 income statement, because
the acquisition occurred on December 28, 2012, the total income statement impact for three days of amortization expense in 2012
would have been approximately $100K, which we determined to be clearly inconsequential.

We also considered whether our SAB 99 analysis would
be materially affected by other unadjusted differences and concluded it would not. We believe it is appropriate and consistent
with the guidance on materiality that our analysis was performed on the impact of the adjustment to the financial statements taken
as a whole rather than evaluating the impact of the adjustment on the accounting for a discrete transaction.

Equifax’s qualitative assessment of the adjustment
included, but was not limited to, the following factors which include the assessment of Equifax management:

 • Whether the misstatement arises from an item capable of precise measurement or whether it arises from an estimate and, if so,
the degree of imprecision inherent in the estimate.

While the purchase price allocation includes a level
of estimation, the identification of the reacquired rights does not.

    5

 • Whether the misstatement masks a change in earnings or other trends.

Based on the materiality discussed above any adjustment
would not have a material impact on earnings or impact reported trends. In 2013, Equifax reported growth in earnings of 41.4%,
18.5% and 13.4% in the first, second and third quarters, respectively.

 • Whether the misstatement hides a failure to meet analysts' consensus expectations for the enterprise.

The analysts which cover Equifax set expectations on
“adjusted EPS” which excluded acquisition related amortization. Therefore, the analysts’ estimates would not
have been impacted by the adjustment.

 • Whether the misstatement changes a loss into income or vice versa.

No

 • Whether the misstatement concerns a segment or other portion of the registrant's business that has been identified as playing
a significant role in the registrant's operations or profitability.

The amortization expense impacts the US Consumer Information
Solutions segment of Equifax, the Company’s largest segment. The segment has historical quarterly margins over the last three
years in the range of 37-41% and generated in excess of $90M of operating profit in each of the first two quarters of 2013 which
would not have been materially impacted by the adjustments. The reported margin from all three quarters of 2013, along with the
margin as if the reacquired right was properly calculated in the initial purchase price allocation is as follows:

    Quarter Ended
    As Reported
    Revised

    March 31, 2013
      37.5 %
      36.2 %

    June 30, 2013
      40.2 %
      38.9 %

    September 30, 2013
      37.9 %
      40.4 %

Note as well that the impact of amortization expense
on margin is disclosed in the MD&A of the September 30, 2013 Form 10-Q.

 • Whether the misstatement affects the registrant's compliance with regulatory requirements.

No

 • Whether the misstatement affects the registrant's compliance with loan covenants or other contractual requirements.

No

    6

 • Whether the misstatement has the effect of increasing management's compensation — for example, by satisfying requirements
for the award of bonuses or other forms of incentive compensation.

No, acquisition related amortization expense does not
directly factor into any incentive compensation.

 • Whether the misstatement involves concealment of an unlawful transaction.

No

Based on the above, Equifax concluded that the error
was not material and no historical financial information needed to be restated.

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

Response

Equifax considered the following factors when evaluating
the deficiency in our internal controls over financial reporting at December 31, 2012 related to the recording of intangible assets
acquired in a business combination:

 • The recorded adjustment resulted i