SEC Comment Letter for EURONET WORLDWIDE, INC. (EEFT) (CIK 0001029199) (EEFT) — Sep 23, 2016
EURONET WORLDWIDE, INC. (EEFT) (CIK 0001029199)
Date: Sept. 23, 2016 · CIK: 0001029199 · Accession: 0000000000-16-094329
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Mail Stop 4720 September 23, 2016 Mr. Rick L. Weller Chief Financial Officer Euronet Worldwide, Inc. 3500 College Boulevard Leawood, Kansas 66211 Re: Euronet Worldwide, Inc. Form 8-K Filed April 27, 2016 Response Dated August 3, 2016 File No. 001 -31648 Dear Mr. Weller : We have reviewed your August 3, 2016 response to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and c ircumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our June 30, 2016 letter . Form 8 -K Filed on April 27, 2016 Exhibit 99.1 – Press Release 1. We have reviewed your response to our comment and believe it would be appropriate to use more descriptive titles to describe the non -GAAP financial measures, Adjusted Cash Earnings per Share and Adjuste d Cash Earnings, perhaps by eliminating the use of the word "cash" in the title. Please revise future filings accordingly. Rick L. Weller Euronet Worldwide, Inc. September 23, 2016 Page 2 You may contact Chris Harley at (202) 551 -3695 or me at (202) 551 -3291 if you have questions . Sincerely, /s/ H. Stephen Kim H. Stephen Kim Assistant Chief Accountant Office of Financial Services