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SEC Comment Letter for EURONET WORLDWIDE, INC. (EEFT) (CIK 0001029199) (EEFT) — Jan 9, 2012

EURONET WORLDWIDE, INC. (EEFT) (CIK 0001029199)
Date: Jan. 9, 2012 · CIK: 0001029199 · Accession: 0000000000-12-001161

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Reasoning

Referenced dates: December 13, 2011

Date
January 6, 2012
Author
Cecilia Blye
Form
UPLOAD
Company
EURONET WORLDWIDE, INC. (EEFT) (CIK 0001029199)

Letter

Re: Euronet Worldwide, Inc. Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 25, 2011 File No. 1-31648 Dear Mr. Brown:

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE

January 6, 2012 Via E-Mail Michael J. Brown Chairman and Chief Executive Officer Euronet Worldwide, Inc. 3500 College Boulevard Leawood, KS 66211

We refer you to our comment letter dated December 13, 2011 regarding business contacts with Iran, Syria and Sudan. We ha ve completed our review of this subject matter. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the co mpany may not assert staff co mments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

S i n c e r e l y ,

/s/ Cecilia Blye C e c i l i a B l y e , C h i e f Office of Global Security Risk cc: Todd Schiffman Assistant Director Division of Cor poration Finance

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
       DIVISION OF
CORPORATION FINANCE

January 6, 2012
Via E-Mail
Michael J. Brown
Chairman and Chief Executive Officer Euronet Worldwide, Inc. 3500 College Boulevard Leawood, KS 66211

 Re: Euronet Worldwide, Inc.
  Form 10-K for the Fiscal Year Ended December 31, 2010   Filed February 25, 2011   File No. 1-31648
Dear Mr. Brown:

We refer you to our comment letter dated December 13, 2011 regarding business
contacts with Iran, Syria and Sudan.  We ha ve completed our review of this subject
matter.  We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from  taking any action with respect to the
company or the filing and the co mpany may not assert staff co mments as a defense in any
proceeding initiated by the Commission or any person under the federal securities laws of
the United States.  We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the filing includes the
information the Securities Exchange Act of  1934 and all applicable rules require.

        S i n c e r e l y ,

        /s/ Cecilia Blye          C e c i l i a  B l y e ,  C h i e f          Office of Global Security Risk    cc:  Todd Schiffman   Assistant Director  Division of Cor poration Finance