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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

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
September 23, 2016
Author
/s/ H. Stephen Kim
Form
UPLOAD
Company
EURONET WORLDWIDE, INC. (EEFT) (CIK 0001029199)

Letter

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

Show Raw Text
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