SecProbe.io

November 18, 2014

Via E -mail
David A. Fisher
President and Chief Executive Officer
Enova International, Inc.
200 West Jackson Blvd.
Chicago, IL  60606

Re: Enova International, Inc.
Registration Statement on Form S -1
Filed October 30, 2014
  File No.  333-199733

Dear Mr. Fisher :

We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter  by amending your registration statement and providing the
requested information .  Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After revi ewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S -1

1. Please revise to clarify whether the offering will be conducted on a c ontinuous or delayed
basis.  In this regard, we note that the cover page of the registration statement indicates
that the offering will be commenced “[a]s soon as practicable after this registration
statement becomes effective.”  However, the cover page of  the prospectus indicates that
your “registration of the shares of common stock covered by this prospectus does not
mean that Cash America will offer or sell any of the shares.”  Please revise to reconcile
and clarify your disclosure, as appropriate.

2. Give n the nature of Cash America’s relationship to you, it appears possible that these
securities are being offered by or on behalf of the registrant.   We also note that you are
not eligible to make an at -the-market offering under Rule 415(a)(4) under the Sec urities
Act because you are not eligible to make an offering under Rule 415(a)(1)(x).   Please
provide us with a detailed analysis as to why the proposed offering is not a primary

David A. Fisher
Enova International, Inc.
November 18, 2014
Page 2

 offering on your behalf and thus should be appropriately characterized as a secondary
offering eligible to be made pursuant to Rule 415(a)(1)(i), including in such analysis a
detailed description of the relationship between you and Cash America, an analysis of
whether Cash America is your parent and affiliate, and the other factor s set forth in
Securities Act Rules Compliance and Disclosure Interpretation 612.09.  Please also
address in your analysis the fact that one of your directors, Daniel R. Feehan, is the
President and Chief Executive Officer of Cash America as well as the va rious operating
and other agreements (see pages 55 - 62) in effect now or contemplated in the future.
Also, address the debt guarantees.  Please also refer to Question 212.15 of our
Compliance & Disclosure Interpretations for Securities Act Rules for guid ance.

Part II.

Item 17. Undertakings, page II -3

3. Please provide all the appropriate undertakings required by Item 512 of Regulation S -K
that apply.  Specifically, it appears that Rule 430C of the Securities Act of 1933 may be
applicable and the undertak ings required by Item 512(a)(5)(ii) of Regulation S -K should
be included.  Please revise or advise.

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 informat ion the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and 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 t hey have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant t o delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effect iveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceler ation of the effective date of the registration statement as confirmation

David A. Fisher
Enova International, Inc.
November 18, 2014
Page 3

 of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact David Lin at (202) 551 -3552  or me at (202) 551 -3434  with any questions.

Sincerely,

 /s/ Michael Clampitt

Michael Clampitt
Senior Counsel

cc: Via E -mail
Lisa M. Young , Esq.
L. Steven Leshin, Esq.