SecProbe.io

September 26, 2011
 Via E-mail

Paul R. Garcia Chairman of the Board of Directors and Chief Executive Officer Global Payments Inc.
10 Glenlake Parkway
North Tower Atlanta, Georgia 30328-3473

Re: Global Payments Inc.  Form 10-K for Fiscal Year Ended May 31, 2011
Filed July 25, 2011 Definitive Proxy Statement on Schedule 14A Filed August 18, 2011 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 proposed revisions.
 Please respond to this letter within te n business days 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 circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.               Form 10-K for Fiscal Year Ended May 31, 2011

 General

1. Please file, with your next periodic report, complete copies of each of your credit
facilities, including the schedul es and exhibits thereto, which are currently filed as
Exhibits 10.23, 10.29, 10.31 and 10.41 to the repo rt.  While you may omit schedules and
exhibits to agreements filed pursuant to Item 601(b)(2) of Regul ation S-K, you may not
omit schedules and exhibits to agreements  filed pursuant to Item 601(b)(10) of
Regulation S-K.

Paul R. Garcia Global Payments Inc. September 26, 2011 Page 2

 Item 7—Management’s Discussion and Analysis  of Financial Condition and Results of
Operations, page 26

2. Please discuss the material impacts that you expect the Durbin Amendment to have on
your results of operations and financial condition.   We note that Mr. Garcia stated in your
fourth quarter earning conference call that the Durbin Amendment will be a “net positive” and will be “beneficia l for [you] for some prici ng opportunities.”  Please also
discuss the extent to which you expect the Comerica investment w ould cause your fiscal
2011 results of operations to not be indicative of your future results of operations.  See
Item 303(a)(3)(ii) of Regulation S-K and Instru ction 3 to Item 303(a) of Regulation S-K.
 Item 15—Exhibits, Financial Statement Schedules, page 96

3. Please revise the description of Exhibit 10.31 to  reference the date of the Current Report
on Form 8-K with which the Term Loan Cred it Agreement dated July 10, 2009 was filed.
Please also revise the description of Exhi bit 10.41 to include the date of the Revolving
Credit Agreement and the date of the Curre nt Report on Form 8-K with which it was
filed.
 Signatures, page 101

4. Please move the signatures for the persons sign ing in their capacities as your principal
executive officer, principal financial officer and principal accounting officer to below the
second paragraph.  Please continue to have  an authorized officer sign on your behalf
below the first paragraph.
 Definitive Proxy Statement on Schedule 14A

 Election of Directors; Nominees, page 5

 F.  Overview of Executive Compensation Program Elements, page 31

 Short Term Incentives, page 32

 Annual Performance Plan, page 32

 Payout Based upon Individual Perf ormance Objectives, page 35

5. Please disclose the actual performance objectives that you established for each named
executive officer for fiscal 2011.  Please al so disclose whether each named executive
officer met the objectives established for hi m and how you determined the percentage of
target that each named executive officer achieved.

Paul R. Garcia Global Payments Inc. September 26, 2011 Page 3

 Long Term Incentive Program, page 36

6. Please disclose your policies for allocating 25 % of the LTI value to stock options and
75% of the LTI value to performance units.  See Item 402(b)(2)(iii ) of Regulation S-K.
 B.  Grants of Plan-Based Awards, page 45

7. Please revise the table to show the grants of stock awards and the gr ants of option awards
in the same row as the row disclosing their grant date fair value.
 Section 16(a) Beneficial Ownersh ip Reporting Compliance, page 64

8. Please disclose the number of transactions th at were not reported on a timely basis as a
result of the late reports.  See Item 405(a)(2) of Regulation S-K.
 Proxy Card

9. Please revise proposal 3 to clarify that your stockholders are voting for or against, or
abstaining from voting on, a proposal to ap prove the compensation of your named
executive officer and not a proposal to hold an advisory vote on the compensation of your
named executive officers.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

Paul R. Garcia Global Payments Inc. September 26, 2011 Page 4

 Please contact Charles Lee at (202) 5 51-3427, Brigitte Lippmann at (202) 551-3713 or
me at (202) 551-3720 with any questions.
Sincerely,
   /s/ Brigitte Lippmann    for
Mara L. Ransom Assistant Director
cc: Daniel C. O'Keefe