SecProbe.io

December 22, 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 response letter  dated December 13, 2006 and have the
following additional comments.  In 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.

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 have read your response to prior comment 1 and note that the annual attrition of your customer relationshi ps ranged from 3% to 7%.  Please further clarify
whether your straight line amortiza tion methodology has fully captured the
attrition that has occurred in each asset group on a static pool basis.   For all periods presented, please qua ntify the amount of amorti zation expense that would

Mr. Joseph C. Hyde
Global Payments Inc.
December 22, 2006 Page 2
have been recognized had an accelerated method of amortization been applied and
advise us of the actual amor tization expense recognized.

Impairment of Long-Lived Assets, page 49
2. We have read your response to prio r comment 2 and note that your asset
groupings are organized according to geographic business due to certain
interdependencies that exist.  We believe that it would be pref erable to assess your
customer lists and merchant contracts for impairment on an individual basis.  If you continue to use the straight line met hod, then the assets should be tracked and
the impairment analysis should be perfor med at the individual customer-related
intangible asset level.  If management believes the implementation of this model
would be impractical, we would not obj ect to the adoption of an accelerated
method of amortization.  Please advise us.

*    *    *    *

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please submit a response letter on EDGAR that keys your responses to our comment s and provides any requested information.
Detailed response letters great ly facilitate our review.  Please understand that we may
have additional comments after review ing your responses to our comments.

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