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CORRESP

 HUNTON & WILLIAMS LLP

 FOUNTAIN PLACE

1445 ROSS AVENUE

 SUITE 3700

DALLAS, TEXAS 75202-2799

TEL 214 • 979 • 3000

 FAX 214 • 880 •
0011

 September 12, 2014

Mr. Michael Clampitt

 Senior Staff Attorney

United States Securities and Exchange Commission

 101 F Street,
NE

 Washington, D.C. 20549

Re:
Enova International, Inc.

 Registration Statement on Form 10

Filed July 31, 2014

File No. 001-35503

 Ladies and
Gentlemen:

 On behalf of Enova International, Inc. (the “Company”), we are transmitting the following responses of the Company
to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), as set forth in the letter of Mr. Michael Clampitt, Senior Staff Attorney, dated August 26, 2014 (the
“Comment Letter”), regarding the above-referenced registration statement on Form 10 (the “Form 10”). The Company is filing on EDGAR these responses concurrently with the filing of Amendment No. 1 to the Form 10 (the
“Amendment”). The Amendment incorporates changes responsive to the comments set forth in the Comment Letter. For your convenience, we have repeated each comment in italics prior to the response.

The references to page numbers in the headings are to the original information statement filed as Exhibit 99.1 to the Form 10, and all
references to page numbers in the Company’s responses below are to the information statement filed as Exhibit 99.1 to the Amendment.

 Exhibit
99.1

 General

1.
Please note that the Form 10 goes effective by lapse of time 60 days after the date filed pursuant to Section 12(g)(1) of the Securities Exchange Act of 1934. After that date, you will be subject to the
reporting requirements under Section 13(a) of the Securities Exchange Act of 1934. In addition, we will continue to review your filing until all of our comments have been addressed.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 12, 2014

 Page
 2

 Company Response:

The Company’s Form 10 was filed pursuant to Section 12(b) of the Securities Exchange Act of 1934 (“Exchange Act”). As a
result, as we have discussed with the Staff, the Form 10 will become effective, in accordance with Section 12(d) of the Exchange Act, 30 days (unless declared effective prior to such date) from the date the New York Stock Exchange
(“NYSE”) certifies that the Company’s securities have been approved for listing, rather than under Section 12(g)(1).

2.
Please revise the Form 10 to include the information that is currently incorporated by reference. The Exhibit 99.1 is not able to be incorporated unless previously filed. See Item 10(d) of Regulation S-K.

 Company Response:

The Company has revised the Form 10 to clarify that the information statement contained as Exhibit 99.1 is not incorporated by reference into
the Form 10. As revised, only information from specified sections of the information statement is now incorporated by reference into the Form 10. The Company believes that the incorporation of specified information from identified sections of the
information statement is permitted by Exchange Act Rule 12b-23, which provides that “. . . information may be incorporated by reference in answer, or partial answer, to any item of a registration statement or report,” provided, among
other things, “[i]nformation in any part of the registration statement or report may be incorporated by reference in answer, or partial answer, to any other item of the registration statement or report.” Since the information statement is
filed as Exhibit 99.1 to the Form 10 and is part of the registration statement, the Company respectfully advises the Staff that it believes that it is eligible to incorporate by reference specific information contained in the information statement
filed as part of the registration statement in answer to an item of the Form 10 in accordance with Exchange Act Rule 12b-23.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 12, 2014

 Page
 3

3.
We note that Cash America’s information statement was filed as an exhibit to Enova’s Form 10. Cash America should either file the information statement on Schedule 14C or provide the staff with an analysis
as to why a separate filing is not required. You may refer to Staff Legal Bulletin No. 4 for further guidance. Please note that, once the Schedule 14C is filed, the staff may have additional comments specifically related to that filing.

 Company Response:

The Company respectfully submits that a filing of the information statement by Cash America International, Inc. (“Cash America”) on
Schedule 14C is not required because Section 14(c) of the Exchange Act does not require such filing. Section 14(c) of the Exchange Act provides:

Unless proxies, consents, or authorizations in respect of a security registered pursuant to Section 12 of this title, or a security
issued by an investment company registered under the Investment Company Act of 1940, are solicited by or on behalf of the management of the issuer from the holders of record of such security in accordance with the rules and regulations prescribed
under subsection (a) of this section, prior to any annual or other meeting of the holders of such security, such issuer shall, in accordance with rules and regulations prescribed by the Commission, file with the Commission and transmit
to all holders of record of such security information substantially equivalent to the information which would be required to be transmitted if a solicitation were made . . . (emphasis added)

Similarly, Rule 14c-2 of Schedule 14C of the Exchange Act provides:

(a)(1) In connection with every annual or other meeting of the holders of the class of securities registered pursuant to section 12 of the
Act or of a class of securities issued by an investment company registered under the Investment Company Act of 1940 that has made a public offering of securities, including the taking of corporate action by the written authorization or consent
of security holders, the registrant shall transmit to every security holder of the class that is entitled to vote or give an authorization or consent in regard to any matter to be acted upon and from whom proxy authorization or consent is not
solicited on behalf of the registrant pursuant to section 14(a) of the Act: (i) A written information statement containing the information specified in Schedule 14C . . . (emphasis added)

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 12, 2014

 Page
 4

 The Company understands that Section 14(c) of the Exchange Act and Rule 14c-2 of
Schedule 14C require that if there is to be a meeting of shareholders, including taking of corporate action by written consent, and proxies are not solicited under Section 14(a) of the Exchange Act by the registrant for action to be taken at
the meeting, before action can be taken by shareholders at the meeting, the registrant must deliver an information statement on Schedule 14C to the shareholders. That is not the case here.

Cash America is a Texas corporation and is governed by the Texas Business Organizations Code (“TBOC”). Under Section 21.455(a)
of the TBOC, a sale, transfer, assignment or other conveyance does not require the approval or consent of the shareholders of a Texas corporation, such as Cash America, “unless the transaction constitutes a sale of all or substantially all of
the assets of the corporation.” In turn, the phrase “sale of all or substantially all of the assets” is defined narrowly in Section 21.451(2) of the TBOC. The definition of “sale of all or substantially all of the
assets” expressly states that “the term [sale of all or substantially all of the assets] does not include a transaction that results in the corporation directly or indirectly: (A) continuing to engage in one or more businesses.”
Because Cash America will continue to engage in its retail store-front pawn and lending businesses after the distribution, the distribution is not a “sale of all or substantially all of the assets” of Cash America under Texas law. That
being the case, under Section 21.455(a) of the TBOC, no shareholder action or consent is required and none is being taken in connection with the distribution. The distribution will be authorized by the Board of Directors of Cash America, alone.

 Because the distribution does not require a shareholder vote or written consent in lieu of a shareholder vote under the TBOC to authorize
the distribution, the Company respectfully submits that the provisions of Section 14(c) of the Exchange Act and Rule 14c-2 of Schedule 14C do not require the filing of an information statement on Schedule 14C by Cash America. The fact that
no vote of the Cash America shareholders is required in connection with the distribution is disclosed in the information statement. For example, this is disclosed on page (i) of the information statement filed as Exhibit 99.1 to the Form 10.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 12, 2014

 Page
 5

 Consistent with this analysis, shareholder approval has not been sought in significant
spin-offs by Delaware companies when, like Texas, there is law to support the determination that a spin-off does not constitute a sale, lease or exchange of all or substantially all of the assets of a corporation, and therefore, no shareholder
approval is required. For example, none of the following significant spin-off transactions listed below sought shareholder approval in connection with these spin-off transactions nor filed an information statement on Schedule 14C.

•

Tribune Company’s spin-off of Tribune Publishing Company (File No. 001-36230) (Form 10 originally filed December 9, 2013 and certification from NYSE received by the Commission on July 21, 2014);

•

Time Warner Inc.’s spin-off of Time Inc. (File No. 001-36218) (Form 10 originally filed November 22, 2013 and certification from NYSE received by the Commission on May 9, 2014);

•

Simon Property Group, Inc.’s spin-off of SPG SpinCo Subsidiary Inc. (File No. 001-36252) (Form 10 originally filed December 24, 2013 and certification from NYSE received by the Commission on May 6, 2014);

•

Sears Holdings Corporation’s spin-off of Lands’ End, Inc. (File No. 001-09769) (Form 10 originally filed December 6, 2013 and certification from The Nasdaq Stock Market received by the Commission on March 18,
2014); and

•

Valero Energy Corporation’s spin-off of Corner Store Holdings, Inc. (File No. 001-35743) (Form 10 originally filed November 16, 2012 and certification from NYSE received by the Commission on April 9, 2013).

 The Company has reviewed Staff Legal Bulletin No. 4 (“SLAB No. 4”) and understands that it provides
five conditions under which a spin-off transaction does not require registration under the Securities Act of 1933. One of those conditions is adequacy of public information that describes the spin-off and the subsidiary, and that requirement is met,
according to the SLAB No. 4, if the distributing company delivers to its shareholders, by the date it spins-off the securities, an information statement that substantially complies with Regulation 14A or Regulation 14C under the Exchange Act.
While SLAB No. 4 requires that the information statement substantially comply with Regulation 14A or 14C, SLAB No. 4 does not require that such an information statement be filed on Schedule 14C under Regulation 14C. The information
statement contained in the Company’s Form 10 substantially complies with Regulation 14C as contemplated by SLAB No. 4 and, as discussed in the information statement, the information statement will be mailed to all of Cash America’s
shareholders as of the record date.

 In summary, the Company respectfully submits that Cash America is not required to make a separate
filing on Schedule 14C because such a filing is not required by Section 14(c) or Rule 14c-2 of the Exchange Act and the information statement (which substantially complies with Regulation 14C) will be mailed to all of Cash America’s
shareholders as of the record date in compliance with the requirements of SLAB No. 4.

 Risk Factors, page 25

4.
Some of your risk factors state that you cannot provide assurance of a certain outcome when the real risk is not your inability to provide assurance, but the underlying situation. Please revise this and similar
language to describe the real risks of the transaction.

 Company Response:

The Company has revised the risk factors and similar language in the Amendment to address the Staff’s comment.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 12, 2014

 Page
 6

 Basis of Presentation and Critical Accounting Policies, page 94

5.
We note your allowance for loan loss accounting policy disclosure on page 96. Please tell us and revise your filing to explain in further detail the discrete groups that your outstanding loans are divided into for
purposes of determining your allowance for loan losses. To the extent that these discrete loan groups are a further disaggregation of your short-term loans, installment loans and line of credit accounts, please include an enhanced discussion of how
such disaggregation is used to determine your allowance for loan losses.

 Company Response:

In the information statement, the Company has described its methodology used to estimate the allowance for loan losses by portfolio segment, as
required by Accounting Standards Codification (“ASC”) 310-10-50-11a, Receivables – Overall – Disclosure – Allowance for Credit Losses Related to Financing Receivables. The Company’s appropriate portfolio segments
are short-term loans, line of credit accounts and installment loans.

 In order to calculate the allowance or liability for estimated losses
on the Company’s consumer loan portfolio, the Company initially disaggregates its consumer loan portfolio primarily by loan product (short-term loans, installment loans and line of credit accounts) due to the different characteristics of the
products and reserve methodologies. The Company believes that disaggregating the portfolio into these discrete loan groups is the appropriate level for monitoring loan performance and is aligned with their underwriting differences. For each discrete
loan group, reserve rates are derived from the loan performance data and applied against consumer loans outstanding at each period end to arrive at the appropriate allowance and liability balance for estimated losses on consumer loans.

While the Company may further evaluate the loan performance data by functional currency or brand, if applicable, to calculate the allowance or
liability for estimated loan losses, the Company follows the same methodology in each product group (short-term loans, installment loans and line of credit accounts), even if those product groups are further evaluated by country or brand.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 12, 2014

 Page
 7

 Current and Delinquent Customer Accounts, page 95

6.
We note your disclosure that for one missed payment, only that payment is considered delinquent for an installment loan or line of credit. We also note that for two consecutive missed payments, the entire loan or
account is classified delinquent. Please quantify for us the installment loans and lines of credit total loan balances that are delinquent only one payment as of each period end presented.

Company Response:

 The
amounts of installment loans and line of credit account balances that are delinquent only one payment for each balance sheet date presented in the information statement are as follows:

 (in thousands)

June 30,
2014

December 31,
2013

June 30,
2013

December 31,
2012

 Payment Amounts Classified as Delinquent (One Delinquent Payment)

$
5,372

$
5,870

$
2,575

$
2,196

 Remaining Balance Classified as Current

16