SecProbe.io

November 29, 2006

Mail Stop 4561

Mr. Joseph C. Hyde
Chief Financial Officer
Global Payments Inc.
10 Glenlake Parkway, North Tower
Atlanta, GA 30328

Re: Global Payments Inc.
 Form 10-K for the y ear ended May 31, 2006
Filed August 4, 2006
Form 10-Q for the quarter  ended August 31, 2006
Filed October 6, 2006
 File No. 1-16111

Dear Mr. Hyde:

We have reviewed your filings and have the following comments.  We have
limited our review to only your financial stat ements and related disclosures and will
make no further review of your documents.  Where indicated, we think you should revise
your documents in response to these comment s.  If you disagree, we will consider your
explanation as to why our comment is inappl icable or a revision is unnecessary.  Please
be as detailed as necessary in your explanat ion.  In some of our comments, we ask you to
provide us with information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filings.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Joseph C. Hyde
Global Payments Inc.
November 29, 2006 Page 2
Form 10-K for the year ended May 31, 2006

Consolidated Financial Statements

Note 1 – Summary of Significan t Accounting Policies, page 45

Goodwill and Other Intangible Assets, page 49
1. We note that customer-related intangible assets are amortized using the straight-line method over their estimated useful lives  of 2 to 30 years.  Considering that
the benefits from the acquisition of custom er lists and merchant contracts tend to
dissipate more rapidly in th e earlier years due to attr ition, please tell us how you
concluded that the straight-line method of amortization is appropriate.  It appears
to us that an accelerated method of amor tization would be a more appropriate way
to allocate the cost of customer lists a nd merchant contracts to the periods that
will benefit from the relationship consiste nt with paragraph 12 of SFAS 142.

Impairment of Long-Lived Assets, page 49
2. Please tell us how you have  defined your asset groups in conducting impairment
tests under SFAS 144.  Specifically, addre ss whether customer-related intangible
assets, such as customer lists and merchant  contracts, are tested at the merchant
level or some higher level and provide us w ith your basis for that determination.

Form 10-Q for the quarter ended August 31, 2006

Item 4 – Controls and Procedures, page 29
3. Please advise us whether management c oncluded that the company’s disclosure
controls and procedures were “effect ive” in accordance with Item 307 of
Regulation S-K and revise your disclosure  in future filings to clarify.

*    *    *    *

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Pl ease furnish a cover letter that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Pleas e file your cover letter on EDGAR.  Please
understand that we may have additional comments after reviewing your responses to our comments.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings to be certain that the filings include all information required under the Securities Exchange Act of 1934 and that they have provided all information

Mr. Joseph C. Hyde
Global Payments Inc.
November 29, 2006 Page 3
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that

• the company is responsible for the adequacy  and accuracy of the disclosure in the
filings;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

You may contact Rachel Zablow, Sta ff Accountant at (202) 551-3428 or the
undersigned at (202) 551-3780 if you have questions.

      S i n c e r e l y ,

Linda van Doorn
Senior Assistant Chief Accountant