SecProbe.io

CORRESP
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March   16, 2007

Ms. Linda van Doorn

Senior Assistant Chief   Accountant

Division of Corporation   Finance

Securities and Exchange   Commission

Mail Stop 4561

100 F Street, NE

Washington, DC 20549

RE:

Global Payments Inc.

Form 10-K for the year ended   May 31, 2006

Filed August 4, 2006

Form 10-Q for the quarter   ended August 31, 2006

Filed October 6, 2006

File No. 1-16111

Dear Ms. van Doorn:

          This letter sets forth the response of Global Payments Inc. (the “Company”) to your comment with regard to the above-referenced filings.  Our responses include the supplemental information that you requested in your letter dated February 28, 2007.

Form 10-K for the year ended May 31, 2006

Consolidated Financial Statements

Note 1 – Summary of Significant Accounting Policies, page 45

Goodwill and Other Intangible Assets, page 49

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Comment:  We   have read your response to prior comments 1 and 2 and note that you intend to   adopt an accelerated method of amortization as of December 1, 2006 (the first   day of your third quarter of fiscal 2007) on a prospective basis for your   significant customer-related intangible assets.  Please provide us with the proposed disclosure that you intend   to include in your Form 10-Q for the quarter ended February 28, 2007.  Your disclosure should describe the   accelerated method you have adopted and clarify that for your three   significant acquisitions that comprised approximately 90% of the net book   value of your assets, the straight-line method approximated the amount of   amortization expense that would have been recognized had the accelerated   method been followed.  Please further   explain that for the remaining 10% of your customer-related intangible assets   that you will continue to amortize under the straight-line
method, there has   not been and is not expected to be a significant difference between the   amortization expense under the accelerated and straight-line methods.

Response:  In   our Goodwill   and other intangible assets section of our footnote 1 –   Summary of Significant Accounting Policies in our Form 10-Q for the quarter   ended February 28, 2007, we intend to supplement our existing disclosure with   the below language to explain our adoption of the accelerated method of   amortization described below for our significant customer-related intangible   assets.  Please note that these   specific assets include our “Canada”, “MAPP”, and “MUZO” acquisitions, as   described in our February 9, 2007 letter to you.  We also adopted this method of amortization for our recent   “HSBC” acquisition, which was completed on July 24, 2006 and was described in   our Form 10-Q for the quarter ended August 31, 2006.

For all periods through   November 30, 2006, the straight-line method of amortization was employed   for all customer-related intangible assets.    On December 1, 2006, we adopted the accelerated method of amortization   described below over the respective periods of expected cash flows for our   significant customer-related intangible assets.  These particular assets reflected 90% of the carrying value of   our total customer-related intangible assets as of November 30, 2006.  In determining amortization expense under   our accelerated method for any given period, we calculate the expected cash   flows for that period that were used in determining the acquired value of the   asset and divide that amount by the expected total cash flows over the   estimated life of the asset.  We   multiply that percentage by the initial carrying value of the asset to arrive   at the amortization expense for that period.  In addition, if the cash flow
patterns that we experience are   less favorable than our initial estimates, we will adjust the amortization   schedule accordingly.  These cash flow   patterns are derived using certain assumptions and cost allocations due to a   significant amount of asset interdependencies that exist in our business.

We believe that our   accelerated method better approximates the distribution of cash flows   generated by our acquired customer relationships. We adopted this method   prospectively for our existing significant customer-related intangible assets   described above and intend to adopt this method for future acquisitions of   customer-related intangible assets.    The use of this amortization method prior to December 1, 2006 would   have resulted in amortization expense that was materially consistent with the   amount recognized under the straight-line method used by us during the same   periods.  Lastly, we will continue to   use the straight-line method of amortization for the certain customer-related   intangible assets that reflected 10% of the carrying value of our total such   assets as of November 30, 2006.  For   these assets, the amortization expense using a straight-line method   historically resulted in, and is expected to continue to
result in, amortization   expense that is not materially different from the amount that would be   recognized under the accelerated method of amortization described above.

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          The Company hereby acknowledges that it is responsible for the adequacy and accuracy of the disclosures in the filings, staff comments or changes to disclosures in response to staff comments do not foreclose the Commission from taking any action with respect to the filings, 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.

          Again, we appreciate your assistance in enhancing the overall disclosure in our filings.  Please do not hesitate to contact me or Martin Picciano, our Chief Accounting Officer, at 770-829-8000 with any questions or further comments.

Sincerely,

/s/ Joseph C. Hyde

Joseph C. Hyde

Chief   Financial Officer

  Global Payments Inc.

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