SecProbe.io

February 28, 2007

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 February 9, 2007 and have the
following additional comment.  In our comment 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 responses to prior comments 1 and 2 and note that you intend to adopt an accelerated method of amortiz ation as of December 1, 2006 (the first
day of your third quarter of fiscal 2007) on a prospective basis for your significant
customer-related intangible assets.  Please provide us with the proposed

Mr. Joseph C. Hyde
Global Payments Inc.
February 28, 2007 Page 2
disclosure that you intend to include in your Form 10-Q for the quarter ended
February 28, 2007.  Your disclosure s hould describe the accelerated method you
have adopted and clarify that for you r three significant acquisitions that
comprised approximately 90% of the net book value of your assets, the straight-
line method approximated the amount of am ortization expense that would have
been recognized had the accelerated method been followed.  Please further
explain that for the remaining 10% of your customer-related intangible assets that you will continue to amortize under the st raight-line method, there has not been
and is not expected to be  a significant difference be tween amortization expense
under the accelerated and straight-line methods.

*    *    *    *

As appropriate, please respond to this comm ent 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 response to our comment and provides any requested information.
Detailed response letters great ly facilitate our review.  Please understand that we may
have additional comments after revi ewing your response to our comment.

You may contact Rachel Zablow, Sta ff Accountant at (202) 551-3428 or the
undersigned at (202) 551-3498 if you have questions.

      S i n c e r e l y ,

Linda van Doorn
Senior Assistant Chief Accountant