SecProbe.io

August 24, 2010
By U.S. Mail and facsimile to 770-829-8513
 Mr. Daniel O’Keefe

Chief Accounting Officer
Global Payments Inc. 10 Glenlake Parkway, North Tower  Atlanta, Georgia 30328

Re:  Global Payments Inc.
Form 10-K for the Fiscal Year Ended May 31, 2010
Filed July 28, 2010 File No. 1-16111
 Dear Mr. O’Keefe:
We have reviewed your filing and have the following comments.
We have limited
our review to only your financial statements and related disclosures and do not intend to
expand our review to other portions of your document.  In some of our comments, we may
ask you to provide us with information so  we may better underst and your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Mr. Daniel O’Keefe
Global Payments Inc.
August 24, 2010
Page 2  Form 10-K for the fiscal year ended May 31, 2010

 Critical Accounting Estimates, page 40

 Goodwill and long-lived asset valuations, page 42

1. Please expand your disclosure to provid e additional qualitative and quantitative
factors that convey to in vestors the current and ongoing risks related to the
recoverability of goodwill as well as the risks that additional charges may be
required in future periods.  Please re fer to Item 303 of Regulation S-K and
Section V of our Interpretive Release No. 33-8350. For example, identify the
reporting unit at which you test goodwill for impairment. In addition, you should also disclose whether any of your reporting units are at risk of failing step one of the impairment test or that the fair value of each of your reporting units is
substantially in excess of carrying value.  For each reporting unit that is at risk of
failing step one, you should:

• Disclose the percentage by which the fa ir value of the re porting unit exceeded
carrying value as of the date of the most recent test;
• Describe the methods and key assumpti ons used and how the key assumptions
were determined;

• Discuss the degree of uncertainty associ ated with the key assumptions.  The
discussion regarding uncertainty shoul d provide specifics to the extent
possible if the valuation model assumes recovery from a business downturn within a defined period of time; and

• Describe potential events and/or ch anges in circumstances that could
reasonably be expected to negativ ely affect the key assumptions.

Note 1 – Summary of Significan t Accounting Policies, page 55
 Settlement processing assets and obligations, page 56

2. Refer to page 57 where you state, “[ i]f the incoming amount from the card
networks precedes the Member’s fundi ng obligation to the merchant, we
temporarily hold the surplus on behalf of  the Member, in a joint deposit account
or in our account at the Member bank, and record a corresponding liability.”
Citing for us the relevant GAAP literature, please explain to us how you concluded it was appropriate to recognize an asset.  In this regard, please explain
to us who has legal ownership to the assets and what mechanism provides you
with the right to use the a ssets to satisfy the related settlement obligation.

Mr. Daniel O’Keefe
Global Payments Inc.
August 24, 2010 Page 3
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings to be certain th at the filings includes the information the
Securities Exchange Act of 1934 and all applic able Exchange Act ru les require. Since the
company and its management are in possessi on of all facts relating to a company’s
disclosure, they are responsible for the accur acy and adequacy of the disclosures they
have made.
In responding to our comments, please provide a written 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 co mments as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

You may contact Robert Ba bula, Staff Accountant, at  202-551-3339 or Donna
Di Silvio, Staff Accountant, at 202-551-3202 if you have questions regarding comments
on the financial statements and related ma tters.  Please contact me at 202-551-3720 with
any other questions.

Sincerely,
   Andrew Mew Accounting Branch Chief