SEC Comment Letter for GLOBAL PAYMENTS INC (GPN) (CIK 0001123360) (GPN) — Oct 21, 2015
GLOBAL PAYMENTS INC (GPN) (CIK 0001123360)
Date: Oct. 21, 2015 · CIK: 0001123360 · Accession: 0000000000-15-050797
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Mail Stop 3561
October 21 , 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, 2 015
File No. 1-16111
Dear Mr. Sheffield :
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
feder al 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 ru les require.
Sincerely,
/s/ William H. Thompson
William H. Thompson
Accounting Branch Chief
Office of Consumer Products