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CORRESP
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March 20, 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

1.

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 is not materially different
from 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.

2

          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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