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    Secure Financial Transactions — Any Time, Any Place

October 17, 2005

VIA EDGAR AND FACSIMILE

Mr. Donald Walker

Senior Assistant Chief Accountant

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Euronet Worldwide, Inc.

    Form 10-K for Fiscal Year Ended December 31, 2004

    File No. 001-31648

Dear Mr. Walker:

We have reviewed your comment letter dated September 27, 2005 regarding Euronet’s Form 10-K for the
year ended December 31, 2004. Please note that our response to you is within the 15 business days
we agreed to in a telephone conversation on Monday, October 3, 2005. Our responses to your
comments follow.

Commission Comment 1 relating to Note 3(n) — Summary of Significant Accounting Policies and
Practices, stock-based compensation, page 66:

Please tell us whether your options which have accelerated vesting are fixed or variable.

Company Response:

The options with accelerated vesting are accounted for as “fixed.” The disclosure in Note 3(n) to
our 2004 Consolidated Financial Statements relates to Time Accelerated Restricted Stock Award Plan
(TARSAP) grants. TARSAP grants are awards under which restricted common stock or options to
purchase common stock vest based on an employee’s completion of a requisite service period. The
grants also provide that the awards may vest prior to the end of the requisite service period if
certain performance criteria are achieved. The requisite service period of various grants is
consistent with awards having no acceleration features — such periods are generally five years, but
not more than seven years. The performance criteria are generally based on the achievement of
predetermined operating profit goals as approved by the Compensation Committee of the Board of
Directors. The performance criteria for vesting of grants are established with an objective of
creating an incentive to deliver performance results that are materially better than shareholder
return expectations. TARSAP grants are accounted for as “fixed awards” under the provisions of FASB
Interpretation No. 44, “Accounting for Certain Transactions Involving Stock Compensation (an
interpretation of Opinion No. 25).”

4601 College Boulevard, Suite 300 • Leawood, KS 66211 USA

Tel: +1-913-327-4200 • Fax: +1-913-327-1921

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In assessing the proper accounting for these awards, we considered whether the terms of the award
were within acceptable parameters of the following generally recognized guidelines:

    1)

    the fixed vesting schedule does not exceed ten years,

    2)

    the fixed vesting schedule does not substantially exceed vesting periods in other plans
of the company,

    3)

    the performance goals are not front-loaded and, in the absence of attaining those
goals, it is more likely than not that the employee will remain with the company to the end
of the plan term, and

    4)

    the term of an employment contract for the employee is not less than the vesting
period.

FASB Interpretation No. 44, paragraph 37, further clarifies the accounting treatment and states
that “If vesting is accelerated based on the occurrence of a specific event or condition in
accordance with the original terms of the award, a modification has not been made and, therefore,
no new measurement of compensation cost is required.”

After consideration of these factors, we concluded that these awards are required to be accounted
for as “fixed.”

Commission Comment 2 relating to Note 4 — Acquisitions, page 67:

You have made several acquisitions during 2003 and 2004 which involve the future release of common
stock subject to certain performance criteria. Please tell us for each of your acquisitions what
the performance criterion is and whether it is based on earnings, security prices or both.
Specifically address your acquisitions of Precept, EPS, CPI and AIM.

Company Response:

The purchase agreements for Precept, EPS, CPI and AIM included certain representations, warranties
and covenants related to the businesses acquired that are customary for transactions of these
types. These representations, warranties and covenants related to commitments, the occurrence or
non occurrence of certain contingencies, proper provision for tax liabilities, the outcome of legal
proceedings, etc. To provide a ready source of assets to cover indemnification obligations under
the acquisition agreements for a breach of these representations, warranties and covenants, we
required that an escrow be established that included a portion of the shares we issued as the
primary source of acquisition consideration. These shares were permitted to be released from the
escrow at the end of the survival period for claims based upon the representations, warranties and
covenants to the extent that a claim for indemnification for breach thereof had not been submitted
by us. Except as described below, the release of shares from escrow were not subject to the
performance of the acquired businesses, of the sellers or of the Euronet stock price.

Consistent with the discussion in Appendix B, paragraph 176(b) of SFAS No. 141, “Business
Combination,” we included the consideration placed in escrow for each of the acquisitions because
the only uncertainty relating to the security escrow was the identity of the payee, not the total
amount to be paid.

Paragraph 176(b) states that “If the contingent consideration represents payment of amounts
withheld to insure against the existence of contingencies, neither the payment of the contingent
consideration nor the payment of a liability that results from the contingency with the funds
withheld affects the acquiring enterprise’s accounting for the business combination. The escrow is
a way of protecting the buyer against risk. The buyer has agreed to pay the amount either to the
seller or to a third-party claimant; and thus, the only uncertainty to the buyer is the identity of
the payee. The amount of the agreed upon consideration that is withheld would be recorded as part
of the purchase price in the original allocation. . . .”

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Additionally, the acquisitions of Precept and EPS included provisions for reductions in the
respective purchase prices if the 2004 earnings streams of these businesses decreased from
historical levels. The escrow discussed above, if not used for a breach of representations,
warranties and covenants, was available to cover any possible purchase price reduction
requirements. To determine the appropriate accounting for this contingent consideration, we
followed the guidance contained in paragraphs 25 through 28 of SFAS No. 141. This guidance
required that we assess the probability of the contingent consideration being paid and, if it is
considered “determinable beyond a reasonable doubt,” record the contingent consideration as a
component of the purchase price. In these two cases, we concluded that the amount of contingent
consideration (and the related performance criteria) was determinable beyond a reasonable doubt,
based on conclusions we reached upon completion of our pre-acquisition due diligence findings.
Moreover, within the reporting period, our conclusion used to determine the purchase price was
confirmed at the conclusion of 2004. There was no decline in the earnings stream of either Precept
or EPS after closing that required further evaluation.

In the case of AIM, in addition to the shares held in escrow as discussed above, 57,954 shares of
Euronet Common Stock issued to the sellers in September 2004, in settlement of the earn-out
arrangement of the original acquisition, were placed in escrow and will be released in December
2006. This release is subject to AIM’s installation of a defined number of transaction processing
terminals and future earnings performance of the acquired business. These additional shares were
valued at $1.1 million at the date of issuance. Upon issuance of these shares, we concluded beyond
a reasonable doubt that the terminal growth and earnings goals were achievable, given the
performance of the acquired business over the first twelve months of ownership since the September
2003 acquisition date. As we were highly confident in the achievement of the performance
objectives established for the relatively minor amount of the remaining escrow, we recorded the
full issuance of these shares as an adjustment to the purchase price of AIM during September 2004.

The agreement relating to the acquisition of CPI contained no provisions for reductions in the
purchase price based on earnings, but does provide for the issuance of additional shares if the
market price of Euronet Common Stock is below $22.66 on the date that shares are released from
escrow. Should we be required to issue additional shares as a result of this provision, in
accordance with SFAS No. 141, paragraph 30, we will not record any additional purchase price.
Paragraph 30 states that “The issuance of additional securities or distribution of other
consideration upon resolution of a contingency based on security prices shall not affect the cost
of the acquired entity. . . .”

See also our response to comment 3.

Commission Comment 3 relating to Note 4 — Acquisitions, page 67:

Please tell us whether the amounts of contingent consideration (shares of common stock) were
determinable at the date of acquisition. Specifically address your acquisitions of Precept, EPS,
CPI and AIM.

Company Response:

As stated in the response to comment 2 above, in the cases of Precept and EPS we viewed the
possible purchase price reductions as contingent consideration in accordance with paragraphs 25
through 28 of SFAS No. 141. However, at the acquisition date we determined beyond a reasonable
doubt that the historical earnings stream would continue through the remaining months of 2004 (the
measurement period). Accordingly, we recorded the full purchase price in the initial purchase
price allocation, including the issuance of any Euronet Common Stock, at date of acquisition. This
conclusion was confirmed at the end of the measurement period.

With respect to EPS and CPI, the purchase agreements included provisions whereby the sellers could
receive contingent payments based on the respective entity’s future earnings provided that each
respective entity

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exceeded pre-acquisition earnings levels. We viewed this differently than provisions which only
required earnings to not decrease. In each of these cases, we could not determine the amount of
the contingent payments beyond a reasonable doubt. Accordingly, as set forth in paragraphs 25
through 28 of SFAS No. 141, at the date of acquisition we did not record any additional
consideration related to contingent payments based on subsequent earnings. When the subsequent
earnings period was concluded, we recorded the value of the additional shares issued as additional
purchase price consideration based on the daily NASDAQ market closing price a few days before and
after the issuance of the shares.

The earn-out related to AIM was settled in September 2004 for 283,976 shares of Euronet Common
Stock, 110,114 of which were retained in escrow subject to seller representations, warranties and
covenants, and 57,954 of which were retained in escrow subject to AIM’s installation of a defined
number of transaction processing terminals and future earnings performance. See our response to
comment 2 above for further discussion of the AIM earn-out and escrow provisions.

In the case of Precept, the seller’s employment agreement called for an additional payment to be
made if the acquired business performed better than certain targets established at the date of
acquisition and the seller remained employed by Euronet. As set forth in paragraph 34 of SFAS No.
141, supplemented by EITF Issue No. 95-8, “Accounting for Contingent Consideration Paid to the
Shareholders of an Acquired Enterprise in a Purchase Business Combination,” contingent amounts
payable based on, among other things, factors such as continued employment or a bonus formula that
is based on a small percentage of profitability targets, rather than a multiple of such
profitability targets, should be accounted for as compensation expense. Based on an evaluation of
the factors contained in EITF Issue No. 95-8, we recorded the bonus payment as compensation expense
during the performance measurement period rather than accounting for it as additional purchase
price.

Commission Comment 4 relating to Note 4 — Acquisitions, page 67:

On page 67, you state that you have released a portion of the common shares from escrow in relation
to your purchase of Precept. However, this release did not occur until 2005. Please tell us how
you determined it to be appropriate to include the full consideration of common stock as part of
your initial purchase price allocation. It appears that such stock is contingent consideration
which should not be recorded until after the contingency has been resolved. Refer to paragraph 27
of FASB 141.

Company Response:

As stated in response to comment 2 above, at the acquisition date, we included all of the initially
issued shares of Euronet Common Stock in the initial purchase price determination for Precept
because the shares placed in escrow were placed there primarily to support the indemnification
obligations arising from an inaccuracy in the sellers’ representations, warranties and covenants.
Accordingly, the majority of escrow did not represent contingent purchase price, but was simply a
means of protecting us, the buyer, against risk. This treatment is in accordance with the
discussion in Appendix B, paragraph 176(b) of SFAS No. 141, and is consistent with the answer to
comment 2 above.

With regard to the provisions in the Precept agreement related to the possible return of a portion
of the initial purchase price, we concluded beyond a reasonable doubt that a purchase price
reduction would not be required as a result of the acquired entity’s failure to maintain the
historical earnings stream. As stated in a response to comment 2, this conclusion was based our
conclusions about this business following completion of our pre-acquisition due diligence findings.
We recognize paragraph 27 of SFAS No. 141 states that contingent consideration “usually” should be
recorded when the contingency is resolved. However, as stated earlier, we concluded beyond a
reasonable doubt that a purchase price reduction would not be required.

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Commission Comment 5 relating to Note 4 — Acquisitions, page 67:

Please tell us how you account for the earn-outs given in connection with your acquisitions of EPS,
CPI, Movilcarga, Transact and AIM. Specifically address the impact when completing the initial
purchase price allocation and the subsequent accounting for such earn-outs, as applicable. Please
cite authoritative guidance and explain the basis for your conclusions.

Company Response:

As discussed in response to comment 3 above, we account for earn-out obligations in accordance with
paragraphs 25 through 28 of SFAS No. 141, which requires the recording of additional purchase price
when the amount of contingent consideration becomes determinable beyond a reasonable doubt.
Therefore, in contrast to potential purchase price reductions related to the failure to maintain
pre-acquisition earnings streams discussed in comments 2 through 4, earn-out obligations which are
dependent on increasing the acquired entities’ future earnings streams are not included in the
initial purchase price determination because we cannot estimate the amount of such payments beyond
a reasonable doubt.

In the case of Transact, as of December 31, 2004, an earn-out payment of $39.1 million was recorded
as a current liability. This accrual was made because we had sufficient information prior to the
finalization of the year-end accounting to be certain as to the amounts related to the earn-out
payment. We completed the acquisition of Transact in November 2003 an