SEC Comment Letter for GLOBAL PAYMENTS INC (GPN) (CIK 0001123360) (GPN) — Feb 20, 2013
GLOBAL PAYMENTS INC (GPN) (CIK 0001123360)
Date: Feb. 20, 2013 · CIK: 0001123360 · Accession: 0000000000-13-009396
AI Filing Summary & Sentiment
Letter
February 20, 2013 Via E -mail David E. Mangum Chief Financial Officer Global Payments Inc. 10 Glenlake Parkway, North Tower Atlanta, GA 30328 -3473
Re: Global Payments Inc. Form 10-K for the Fiscal Year Ended May 31, 2012 Filed July 27, 2012 File No . 001 -16111
Dear Mr. Mangum :
We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or 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. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.
Sincerely,
/s/ Jim Allegretto
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February 20, 2013 Via E -mail David E. Mangum Chief Financial Officer Global Payments Inc. 10 Glenlake Parkway, North Tower Atlanta, GA 30328 -3473 Re: Global Payments Inc. Form 10-K for the Fiscal Year Ended May 31, 2012 Filed July 27, 2012 File No . 001 -16111 Dear Mr. Mangum : We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or 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. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Jim Allegretto Jim Allegr etto Senior Assistant Chief Accountant