SecProbe.io

Mail Stop 3561
September 16 , 2015

David M. Sheffield
Senior Vice President and Chief Accounting 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, 2 015
Filed July 30, 3015
File No. 1-16111

Dear Mr. Sheffield :

We have limited our review  of your filing  to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Item 7 – Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Fiscal Year Ended May 31, 2015 Compared to Fiscal Year Ended May 31, 2014, page 31

1. In future filings where you describe two or more factors that contributed to a materia l
change in a financial statement line item between periods, including revenues, operating
expenses, selling general and administrative expenses, operating income and operating
margin for segments, corporate, operating income, and other income/expense,  pl ease
quantify, to the extent practicable, the incremental impact of each factor identified.  For
example, you indicate on page 32 that your European “ . . . merchant services revenues for
fiscal 2015 increased 4.9% to $616.0 million compared to the prior year driven primarily
by card transaction and volume growth and a decrease in interchange rates in Spain,
service fee growth in the United Kingdom and growth in our e -commerce channel,
partially offset by the unfavorable effect of changes in exchange rates  and weakness in
Russia ” without separately quantifying the contributing factors.

 David M. Sheffield
 Global Payments, Inc.
 September 16 , 2015
 Page 2

 Consolidated Balance Sheets, page 49

2. We note your common stock has no par value.  Please explain to us why no amount has
been credited to common stock

Note 3 – Business an d Intangible Asset Acquisitions and Joint Ventures, page 61

3. We note in regards to the purchase of Realex and Ezidebit, you appear to have allocated a
significant amount of the purchase price consideration to goodwill.  Please explain to us
how you evaluat ed these acquisitions for the existence of other intangible assets in
accordance with ASC 805 -20-55.  Please disclose any intangible assets that did not
qualify for separate recognition in accordance with ASC 805 -30-50 and provide more
robust disclosure of  the factors that make -up the goodwill recognized.

Note 14 – Segment Information, page 80

4. Please tell us how you have identified your operating segments.  It is unclear to us if your
operating segments are the same as your six reportable units  for goodwill purposes .  If
they are the same, please explain why Canada is not an operating segment and a
reportable segment and how you report your Brazilian operations currently and under the
new segment structure beginning in fiscal 2016.  In addition,  to the extent you have
aggregated your operating segments into your reportable segments, please disclose that
fact and tell us how you have considered the aggregation criteria in ASC 280 -10-50-11
and the quantitative thresholds in ASC 280 -10-50-12.

We ur ge 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 Exchange Act rules require.   Since the company an d 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 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 th e 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.

 David M. Sheffield
 Global Payments, Inc.
 September 16 , 2015
 Page 3

 You may contact Scott Stringer, Staff Accountant, at (202) 551 -3272 o r Donna Di Silvio,
Staff Accountant, at (202) 551 -3202 if you have questions regarding our comment s.  Please
contact me at (202) 551 -3344 with any other questions.

Sincerely,

 /s/ William H. Thompson

William H. Thompson
Accounting Branch Chief
       Office of Consumer Products