SEC Comment Letter for GLOBAL PAYMENTS INC (GPN) (CIK 0001123360) (GPN) — Nov 17, 2011
GLOBAL PAYMENTS INC (GPN) (CIK 0001123360)
Date: Nov. 17, 2011 · CIK: 0001123360 · Accession: 0000000000-11-066926
AI Filing Summary & Sentiment
File numbers found in text: 001-16111
Letter
November 17, 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 completed our review of your f ilings. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or the filings and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi lings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable rules require.
Sincerely,
/s/ Brigitte Lippmann for
Mara L. Ransom Assistant Director
cc: Daniel C. O'Keefe
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November 17, 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 completed our review of your f ilings. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or the filings and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi lings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Brigitte Lippmann for Mara L. Ransom Assistant Director cc: Daniel C. O'Keefe