SecProbe.io

Mail Stop 3561
 November 21, 2008
Paul R. Garcia Chairman, President and Chief Executive Officer  Global Payments Inc. 10 Glenlake Parkway, North Tower Atlanta, Georgia  30328-3473
Re:  Global Payments Inc.
Form 10-K for the fiscal year ended May 31, 2008 Filed July 30, 2008 File No. 001-16111
 Dear Mr. Garcia:
 We have reviewed your filing and have the following comments.  You should comply
with the comments in all future filings, as appl icable.  Please confirm in writing that you will do
so, and also explain to us in sufficient detail for an understa nding of the disclosure how you
intend to comply by providing us with your prop osed revisions.  If you disagree, we will
consider your explanation as to why our comments are inapplicable or a revision is unnecessary.
Please be as detailed as necessa ry in your explanation.  After re viewing this information, we may
raise additional comments.               Please understand that the purpos e of our review process is to assist you in your
compliance with the applicable disclosure requir ements 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 any other aspect of our review.  Feel free to call
us at the telephone numbers listed  at the end of this letter.
 Annual Report on Form 10-K for Fis cal Year Ended February 2, 2008

 Item 1—Business

 General

1. To the extent material to an understandi ng of your business taken as a whole, please
disclose the extent to which the business of each  segment is or may be seasonal.  In this
regard, we note your disclosure in the last  full paragraph on page 42 under the heading
“Management’s Discussion and Analysis of Financial Condition and Results of
Operations—Credit Facilities” that the terms of your Canadi an Credit Facility allow you

Paul R. Garcia
Global Payments Inc.
November 21, 2008 Page 2
“to expand the size of the uncommitted fac ility to $50 million Canadian dollars during
the peak holiday season….”  See Item 101(c)(1)(v) of Regulation S-K.
2. Please confirm that in future filings you will disclose financial information about long-lived assets in your geographic areas in your  Business section.  Alternatively, please
confirm that in future filings you will provide  in your Business section a cross-reference
to this disclosure in the no tes to your financial statements.  See Items 101(d)(1)(ii) and
101(d)(2) of  Regulation S-K.
 Item 7—Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 28
 Commitments and Contractual Obligations, page 44

3. Please revise to include estimated interest payments on outstanding long-term debt
obligations.  Because the table is aimed at  increasing transparency of cash flow, we
believe interest payments should be included in  the table.  Disclose any assumptions used
to arrive at the estimated amounts based on va riable rates.  If you choose not to include
these payments, please provide information regarding future interest payments in a
footnote to the table.  See Section IV.A and footnote 46 to the Commission’s Guidance
Regarding Management’s Discussion and Analys is of Financial Condition and Results of
Operations, SEC Release No. 33-8350, issu ed December 19, 2003 and available on our
website at http://www.sec.gov/rules/interp/33-8350.htm .

Item 9A—Controls and Procedures, page 86
 Evaluation of Disclosure Cont rols and Procedures, page 86

4. You disclose under this heading that “[ your] management, incl uding [your] principal
executive officer and principal financial o fficer, concluded an evaluation of the
effectiveness of [your] disclo sure controls and procedures  as of May 31, 2008 [and this]
evaluation tested controls and other proce dures designed to ensure that information
required to be disclosed … in the reports th at [you] file or submit under the …Exchange
Act … is recorded, processed, summarized a nd reported within the time periods specified
in the SEC’s rules and forms. Based on [your] evaluation, as of May 31, 2008, [your]
management, including [your] principal executive officer and principal financial officer,
concluded that [your] disclosure controls  and procedures were effective.”
 Please confirm to us, and revise future fili ngs to clarify, if tr ue, that your officers
concluded that your disclosure controls and pr ocedure also are effective to ensure that
information required to be disclosed in the reports that you file or submit under the
Exchange Act is accumulated and communi cated to your management, including your
principal executive officer and principal fi nancial officer, to allow timely decisions

Paul R. Garcia
Global Payments Inc.
November 21, 2008 Page 3
regarding required disclosure.  See Exchange  Act Rule 13a-15(e).  Alternatively, you
may revise future filings to simply state that  your disclosure contro ls and procedures are
effective or ineffective without providing the definitions.
 Index to Exhibits, page 96

 General

5. We note that your exhibit list does not include the credit facility you entered into with the
National Bank of Canada in April 2008.  Please tell us why this agreement is not required
to be filed as an exhibit or includ e it as an exhibit in your next filing.
 Exhibits 31.1 and 31.2

Rule 13a-14(a)/15d-14(a) Certifications
6. We note that the wording of your certifications  pursuant to Section 302 of the Sarbanes-
Oxley Act of 2002 does not precisely match the language set forth in Item 601(b)(31) of
Regulation S-K.  In this rega rd, your certifica tions (1) include a reference in number 2 of
the certification to this “annual” report, and (2 ) do not track the text of Item 601(b)(31) of
Regulation S-K in number 4(d).  We note simila r alterations to the certifications filed
with the August 31, 2008 Form 10-Q. Please confirm you will revise in future filings.

* * * * *

As appropriate, please respond to these comments  within 10 business days or tell us when
you will provide us with a response.  If you ame nd one of your filings, you may wish to provide
us with marked copies of the amendment to exped ite our review.  Please furn ish a letter that keys
your responses to our comments a nd provides any requested informa tion.  Detailed letters greatly
facilitate our review.  Please understand that we may have additional comments after reviewing
your responses to our comments.
             We urge all persons who are res ponsible for the accuracy and adequacy of the disclosure
in this filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.

Paul R. Garcia
Global Payments Inc. November 21, 2008 Page 4
  In connection with responding to our comment s, 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
filing;
 ‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
 ‚ the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities 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 sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.
 Please contact Catherine Brown, Staff A ttorney, at (202) 551-3513 or me at
(202) 551-3720 with any questions you may have.

Sincerely,

H. Christopher Owings  Assistant Director