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CORRESP
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CORRESP

 Richard Aftanas

 Partner

Hogan Lovells US LLP

 390 Madison Avenue

New York, NY 10017

 T +1 212 918 3267

F +1 212 918 3100

 raftanas@hoganlovells.com

www.hoganlovells.com

 April 13, 2023

 BY
EDGAR

 Ms. Cara Wood

 Division of Corporation
Finance

 Office of Trade & Services

 United States
Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:

Equifax do Brasil S.A.

Registration Statement on Form F-4

Filed March 6, 2023

File No. 333-270310

Equifax Inc.

Registration Statement on Form S-4

Filed March 6, 2023

File No. 333-270309

 Dear Ms. Wood:

Set forth below are the responses of Equifax do Brasil S.A. (“Equifax Brasil”) and Equifax Inc.
(“Equifax” and, together with Equifax Brasil, the “Registrants,” “we”, “us” or “our”) to comments received from the staff of the
Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”), by letters dated March 31, 2023, with respect to the Registration Statement on Form F-4 filed with the Commission by Equifax Brasil and the Registration Statement on Form S-4 filed with the Commission by Equifax, in each case filed on March 6, 2023
(collectively, the “Registration Statement”). In connection with this letter responding to the Staff’s comments, we hereby submit to the Commission Amendment No. 1 to the Registration Statement
(“Amendment No. 1”).

 Division of Corporation Finance

April 13, 2023

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 For the Staff’s convenience, each response below is prefaced by the Staff’s
corresponding comment in bold, italicized text. All references to page numbers and captions correspond to the page numbers and captions in Amendment No. 1. The changes reflected in the Amendment No. 1 include those made in response to the
Staff’s comments and other changes intended to update, clarify and render more complete the information set forth therein. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in Amendment No. 1.

 Registration Statement on Form F-4

Questions and Answers About the Transaction

If the Transaction is consummated, what will I receive?, page 1

1.
 We note that Boa Vista shareholders have multiple options with respect to the consideration that they
receive in connection with this transaction. Please revise to lay out in a tabular form, or other easily readable chart, an explanation of the Boa Vista shareholder options with respect to the consideration, withdrawal rights, and eventual put and
call options in connection with this transaction.

 Response:

In response to the Staff’s comment, the Registrant has revised the disclosure on pages 2, 3, 6 and 7 of Amendment
No. 1.

2.
 We note that any cash amounts payable upon the redemption will be adjusted downwards. Please estimate the
potential adjustments, if feasible, and provide examples under each redemption scenario that explains what shareholders would receive. If you are not able to estimate the potential adjustments, please explain why. In this light, we note that on page
89 you have estimated that as of September 30, 2022, claims against Boa Vista totaled approximately R$103.1 million.

Response:

We note the Staff’s comment. As described on pages 3, 57 and 58 of Amendment No. 1, the adjustments to the
consideration will be based on certain distributions of dividends, return of capital or interest on capital made by Boa Vista during the period between the signing of the Merger Agreement and the closing of the Transaction and losses reasonably
expected to be incurred with respect to legal proceedings that arise or relate to acts or facts occurring during this same period. As these amounts are not determinable prior to closing of the Transaction, it is not feasible to provide an estimate
of the potential adjustments. We note that the claims as of September 30, 2022 noted in the Staff’s comment relate to legal proceedings that arose prior to the execution of the Merger Agreement that were disclosed in the disclosure
schedules thereto and, as such, there would not be an adjustment with respect to any such claims.

 Division of Corporation Finance

April 13, 2023

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 What shareholder approvals are needed for the Transaction?, page 2

3.
 Here and in the “Required Vote” section on page 15, please revise to state the remaining
percentage of BV Common Shares required to vote at the BV Special Meeting to approve the transaction, which we note is approximately 10.11%.

Response:

In response to the Staff’s comment, the Registrants have revised the disclosure on pages 4 and 20 of Amendment No. 1.

 What percentage ownership will former Boa Vista shareholders hold in EFX and/or EFX Brasil ..., page 7

4.
 Please add a question and answer that addresses how the Consideration may be affected by fluctuations in
the Brazilian real/U.S. dollar exchange rate, as discussed in your risk factor on page 28 and in the Risks Relating to Brazil, starting on page 39.

Response:

In response to the Staff’s comment, the Registrants have revised the disclosure on page 7 of Amendment No. 1.

Summary of the Transaction

 Risk Factors,
page 14

5.
 Please revise to provide a summary of the risk factors here. Please refer to Item 3 of Form F-4.

 Response:

In response to the Staff’s comment, the Registrants have revised the disclosure on pages 17 and 18 of Amendment
No. 1.

 Quorum for Installation, page 15

6.
 We note your statement that “[t]he BV Special Meeting will be installed on first call if 25% of the
issued and outstanding BV Common Shares are present, in person or by proxy.” Please revise to state whether quorum will be met by nature of the ownership of EFX Brasil and ACSP, which own approximately 40% of the issued and outstanding
shares.

 Response:

In response to the Staff’s comment, the Registrants have revised the disclosure on page 19 of Amendment No. 1.

 Division of Corporation Finance

April 13, 2023

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 Risk Factors

Security Breaches and other disruptions to information technology infrastructure .., page 28

7.
 To the extent that Boa Vista has experienced a material cybersecurity event, leak, or data breach, please
revise to state as much, quantify such impacts, and describe any other related consequences.

 Response:

 The Registrants have been advised by Boa Vista that it has not experienced any material cybersecurity event, leak, or data
breach.

 Boa Vista may not hold all intellectual property rights ..., page 30

8.
 Please disclose which Boa Vista material trademarks are currently being challenged
and if possible, describe the related quantitative impact on Boa Vista’s business.

Response:

In response to the Staff’s comment, the Registrants have revised the disclosure on page 34 of Amendment No. 1.
The Registrants do not believe the impact of these challenges is likely to be material both because Boa Vista believes it has meritorious defenses and the Registrants have other means to mitigate any potential impacts in the unlikely event that Boa
Vista is unable to prevail on the merits.

 Boa Vista may face difficulties in implementing EFX’s technology ..., page 32

9.
 To the extent material, please state the anticipated costs associated with implementing the EFX
technology transformation strategy.

 Response:

In response to the Staff’s comment, the Registrants have revised the disclosure on page 36 of Amendment No. 1 to
note that the anticipated costs of the EFX technology transformation strategy may be material to the results of operations and cash flows of Equifax Brasil. The Registrants do not believe any such costs will be material to Equifax. Equifax notes
that it has undertaken similar technology transformation strategy implementation efforts as it has integrated other acquisitions and, although based on this experience it believes that the costs may well be material to Equifax Brasil, given numerous
variables, including the time period over which the strategy will be implemented as well as the uncertain value of any offsetting benefits of the technology transformation strategy, it does not believe it is feasible to provide a meaningful estimate
of these costs.

 Division of Corporation Finance

April 13, 2023

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 Background of the Transaction, page 46

10.
 Please revise your disclosure throughout this section to provide greater detail as to the background of
the strategic options that you considered, the transaction, including the material issues discussed and key negotiated terms and agreements. The disclosure should provide shareholders with an understanding of how, when, and why the material terms of
your proposed transaction evolved and why this transaction is being recommended as opposed to any alternatives. In your revised disclosure, please ensure that you address the following:

•

 the material terms for any proposals and subsequent proposals and counter offers;

•

 at what point other strategic alternatives were eliminated from consideration;

•

 negotiation of the transaction documents and the parties involved;

•

 valuations, including the Valuation Report; and

•

 the consideration offered.

Response:

In response to the Staff’s comment, the Registrants have revised the disclosure on pages 50 and 51 of Amendment No. 1
to provide greater detail as to the background of the transaction.

 With respect to the Valuation Report, please see our
response to comment no. 24. Please also see our responses to comments nos. 12 and 13.

11.
 Please disclose all material details of the steps that occurred between early 2022 when EFX approached
ACSP about the potential take-private transaction and December 1, 2022, when the EFX board of directors were provided with an update on the material terms and conditions of the transaction, which it subsequently
approved on the same day.

 Response:

In response to the Staff’s comment, the Registrants have revised the disclosure on pages 50 and 51 of Amendment
No. 1.

12.
 Please elaborate on how the R$8.00 per share/aggregate purchase price of up to R$4.0
billion was determined and all consideration alternatives.

 Division of Corporation Finance

April 13, 2023

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 Response:

The Registrants acknowledge the Staff’s comment and advise the Staff that in determining the purchase price, Equifax
considered its valuation model (utilizing the discounted cash flow method), current and historical Boa Vista stock prices and historical trading trends, premium offered in precedent transactions, comparable companies valuations and precedent
transaction analysis, input from its advisors and other customary information. Given the different investor types in the Boa Vista shareholder base and their investment horizon, Equifax wanted to offer a range of alternatives that would meet the
investors’ needs, be deemed attractive to different types of investors and would be acceptable under Brazilian law, which included offering investors the option to take consideration in the form of publicly traded BDRs or equity in a Brazilian
company.

 EFX’s Reasons for the Transaction, page 47

13.
 We note the disclosure regarding the EFX board’s reasons for the transactions. Please revise to
state all material factors considered, both positive and negative. Additionally, please disclose whether the EFX board considered the consideration to be offered in connection with the transaction. If not, please state why the EFX board did not
consider the consideration and whether the EFX board continues to recommend the transaction. Finally, we note that the EFX board agreed to recommend the transaction on December 1, 2022, but negotiations with respect
to the transaction were ongoing throughout December 2022 and into February 2023, in connection with entry in to the Voting Agreement. Please revise to state whether the EFX board considered the events after
December 1, 2022 and if it continues to recommend the transaction.

Response:

In response to the Staff’s comment, the Registrants have revised the disclosure on pages 50 and 51 of Amendment
No. 1.

 With respect to the factors considered by the board of Equifax in approving the transaction, Equifax’s
decision to pursue the Transaction was based on an evaluation of its existing investment in Boa Vista and was, as such, a discussion as to whether now was the right time to consider expansion in Brazil. We note for the Staff that as Equifax is
materially larger than Boa Vista (as disclosed in its most recent Form 10-K, the aggregate market value of Equifax’s common stock held by non-affiliates as of
June 30, 2022 was approximately $22.4 billion, relative to a purchase price of approximately $596 million or less than 3% of Equifax’s then market capitalization), as noted in the disclosure on pages 50 and 52, from
Equifax’s perspective the board was not evaluating this Transaction as compared to other transactions it might pursue with other companies but rather the discussion focused solely on an evaluation of its investment in Boa Vista and options with
respect to such investment and its options to execute on its growth strategy in Brazil. In other words, there is no discussion of other strategic alternatives as the only decision from the perspective of Equifax was either to continue to hold its
existing investment in Boa Vista or to pursue the Transaction.

 Division of Corporation Finance

April 13, 2023

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 With respect to the timing of the approval by the board of Equifax, as
disclosed on page 51 of Amendment No. 1, in December 2022, the board of Equifax approved the Transaction and authorized management to make the offer to Boa Vista. Prior to such date, all discussions were solely between Equifax and ACSP.
Negotiations thereafter were the first set of negotiations between Boa Vista and Equifax and, as noted on page 51 of Amendment No. 1, there was no change in the material terms of the Transaction, including the price, from the terms authorized
by the board of Equifax in December 2022.

 We respectfully note that, with respect to the target’s shareholders, the
Registration Statement is expressly not a proxy statement and is not being used to solicit votes with respect to the BV Special Meeting or any other meeting of the shareholders of Boa Vista held in connection with the Transaction. The solicitation
of votes will be made by Boa Vista solely pursuant to information provided to its shareholders in a document prepared in accordance with the requirements of the Brazilian Corporations Law and the Brazilian Securities Commission (CVM). Similarly,
Equifax’s shareholders are not required to vote to approve the transaction and the sole shareholder of Equifax Brasil is Equifax. Accordingly, the Registration Statement does not include a recommendation of the Transaction but rather is
intended to provide an appropriate level of disclosure for Boa Vista shareholders to be able to evaluate an investment decision in either the Equifax Brasil common shares or the Equifax BDRs, should they elect one of those options in connection with
the Transaction.

 The Transaction

Accounting Treatment of the Transaction, page 48

14.
 We note the disclosure on page 83 that (i) EFX Brasil was established as
a vehicle for EFX’s business and investments in Brazil, (ii) EFX made its initial investment in Boa Vista through EFX Brasil in 2011, at which point the then-existing business and operations of EFX Brasil were
taken over by Boa Vista, (iii) since such time, EFX Brasil has not engaged in any significant business other than holding the indirect interest of EFX in Boa Vista, (iv) it has no
significant sources of income other than distributions from or gains or losses on its investment in Boa Vista. In view of the preceding, please explain to us your consideration and analysis in accounting for the transaction as a reverse acquisition
guided by either IFRS 3 or IFRS 2 as appropriate.

 Division of Corporation Finance

April 13, 2023

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