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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

 December 4, 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 S-1

Filed October 30, 2014

File No. 333-199733

 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 Counsel, dated November 18, 2014 (the “Comment
Letter”), regarding the above-referenced registration statement on Form S-1 (the “Registration Statement”). The Company is filing on EDGAR these responses concurrently with the filing of Amendment No. 1 to the Registration
Statement (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.

Registration Statement on Form S-1

1.
Please revise to clarify whether the offering will be conducted on a continuous 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.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 December 4, 2014

 Page
 2

 Company Response:

The offering will be conducted on a continuous or delayed basis. In response to the Staff’s comment, the Company has deleted the sentence
on the cover page of the prospectus that indicates that our “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” in order to reconcile and clarify the
disclosure.

2.
Given 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 Securities 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 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 factors 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 various 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 guidance.

 Company
Response:

 For the reasons discussed below, the Company respectfully submits to the Staff that the offering (the “Offering”)
of shares of common stock of the Company by Cash America International, Inc. (“Cash America”) pursuant to the Registration Statement (the “Shares”) should be viewed as a secondary offering as contemplated by Rule 415(a)(1)(i) and
not as a primary offering on behalf of the Company.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 December 4, 2014

 Page
 3

 Background

Set forth below are facts relevant to the analysis that follows and a detailed description of the relationship between the Company and Cash
America.

 Formation of the Company and Acquisition of the Shares. On September 7, 2011, Cash America formed the Company
under the laws of Delaware. Six days later, on September 13, 2011, Cash America contributed to the Company all of the entities through which Cash America conducted its e-commerce business in exchange for all of the Company’s issued and
outstanding common stock in an internal tax-free transfer. Cash America first entered into the e-commerce business on September 15, 2006 through its purchase of the assets of The Check Giant, LLC, an unrelated party, for $255.2 million.

The Spin-off. On October 22, 2014, the Board of Directors of Cash America approved a tax-free distribution of approximately
80% of the Company’s issued and outstanding common stock to Cash America’s shareholders (the “Spin-off”). On November 13, 2014, the Spin-Off was completed. Cash America retained 20% of the Company’s common stock in
connection with the Spin-off, and it is these shares that are to be covered by the Registration Statement. Following the Spin-off, Enova continues the active conduct of its e-commerce business, independently from Cash America and with its separate
management and employees.

 The Company’s shares of common stock were registered under the Securities Exchange Act of 1934, as amended
(the “Exchange Act”), in October 2014 in connection with the Spin-off and are listed and actively traded on the New York Stock Exchange. The Company’s public float consists of approximately 80% of the Company’s issued and
outstanding common stock.

 The Private Letter Ruling from the Internal Revenue Service Relating to Cash America’s Retention of
the Shares and Related Control Restrictions. The Spin-off was effected in a manner intended to qualify as a tax-free distribution so that Cash America’s shareholders receiving shares of the Company’s common stock in the Spin-off
would not recognize gain or loss under federal income tax laws upon receipt of the shares. To qualify for nontaxable treatment under section 355 of the Internal Revenue Code, among other requirements, Cash America was required to distribute an
amount of stock of the Company to Cash America’s shareholders constituting “control” of the Company within the meaning of section 368(c) of the Internal Revenue Code. Because Cash America intended to retain 20% of the Company’s
outstanding common stock, section 355(a)(1)(D)(ii) of the Internal Revenue Code required that Cash America establish to the satisfaction of the Internal Revenue Service (“IRS”) that its retention of the Shares was not in pursuance of a
plan having as one of its principal purposes the avoidance of federal income tax. In order to meet this requirement, Cash America requested, and received on October 10, 2014, a private letter ruling (“PLR”) from the IRS ruling that
the retention of the Shares by Cash America met this requirement for nontaxable treatment of the Spin-off. This PLR was based upon actions to be taken by Cash America and specific representations made by Cash America to the IRS to satisfy IRS
requirements for the issuance of the PLR.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 December 4, 2014

 Page
 4

 Specifically, Cash America represented to the IRS that Cash America would vote the Shares
that it retained in proportion to the votes cast by the Company’s other stockholders on matters submitted to a vote of stockholders and would grant the Company a proxy to vote the Shares in proportion to the votes cast by the Company’s
other stockholders. Pursuant to a Stockholder’s and Registration Rights Agreement between Cash America and the Company, Cash America granted a proxy to the Company to vote the Shares of common stock retained by Cash America in proportion to the
votes cast by the Company’s other stockholders.1 As such, Cash America no longer possesses the voting power over any shares of the Company’s common stock.

Cash America also represented to the IRS that Cash America and the Company will operate as independent companies having separate boards of
directors, and to the extent that they interact with each other, they would do so under commercially reasonable terms similar to those that would be agreed to by third parties negotiating at arm’s-length. Cash America further represented that
the separate boards of directors will have no overlapping members, with the exception of Daniel R. Feehan, Cash America’s chief executive officer (“CEO”) and president, who could serve as a director of both corporations for a
transitional period not to exceed two years following the Spin-off to accommodate needs of the Company, as discussed below under “The Company’s Board of Directors and Officers.”2

 The PLR also requires that, with the potential exception of a small portion of the Shares reserved to settle certain restricted stock
unit awards and deferred director equity-based compensation (representing approximately 2% of the Company’s outstanding shares), the Shares retained by Cash America will be sold by Cash America not later than two years after the Spin-off.

1
The proxy will terminate as to shares upon the sale or transfer of such shares from Cash America to any other person.

2
The PLR provides that Mr. Feehan will be eligible to serve on the Company’s Board of Directors after this two year transitional period if he is no longer serving as an executive officer of Cash America.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 December 4, 2014

 Page
 5

 These foregoing requirements that Cash America agreed to with the IRS based on these
representations are referred as the “IRS Control Restrictions.” The Company has been informed by Cash America that Cash America intends to comply with these IRS Control Restrictions since, if it fails to do so, it could invalidate the PLR
and jeopardize the tax-free treatment of the Spin-off.

 The Separation-Related Agreements. As part of the separation and
distribution, the Company and Cash America entered into the following agreements (the “Separation-Related Agreements”):

•

Separation and Distribution Agreement. The Separation and Distribution Agreement governed the terms of the separation of the Company from Cash America. This agreement contains Cash America’s and the
Company’s agreements relating to the restructuring steps taken to complete the Spin-off, including the assets, equity interests and rights to be transferred, liabilities to be assumed, contracts to be assigned, mutual releases, indemnities,
agreements as to insurance following the Spin-off and related matters. This agreement also specified the conditions that were required to be satisfied prior to the Spin-off and contains certain post-Spin-off obligations of both the Company and Cash
America.

•

Tax Matters Agreement. As a result of the Spin-off, the Company and its subsidiaries ceased to be members of the affiliated group (as that term is defined in the Internal Revenue Code) of which Cash America was
the common parent, a so-called tax deconsolidation. The Tax Matters Agreement governs Cash America’s and the Company’s respective rights, responsibilities and obligations with respect to taxes, tax attributes, tax returns, tax contests and
certain other tax matters.

•

Stockholder’s and Registration Rights Agreement. Under the Stockholder’s and Registration Rights Agreement, Cash America agreed to vote the Shares that it retained in proportion to the votes cast by the
Company’s other stockholders on matters submitted to a vote of stockholders and granted a proxy to the Company to vote the Shares in proportion to the votes cast by the Company’s other stockholders. In addition, the Company agreed to use
its best efforts to register the Shares retained by Cash America to the extent such shares are not registered and sold pursuant to the Registration Statement.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 December 4, 2014

 Page
 6

•

Transition Services Agreement. Pursuant to the Transition Services Agreement, Cash America agreed to provide the Company, on a transitional basis, certain information systems support generally consistent with
similar services provided by Cash America to the Company before the Spin-off at a fee of $18,000 per month plus reimbursement of Cash America’s out-of-pocket expenses. This fee is intended to allow Cash America to recover the costs directly
associated with providing these services, with nominal profit. The Company expects that it will complete the transition of these services on or before 12 months following the Spin-off.

•

Software Lease and Maintenance Agreement. Pursuant to the Software Lease and Maintenance Agreement, the Company leased a version of its consumer loan underwriting model for use by Cash America in its consumer
credit business and provides maintenance, and Cash America agreed to pay the Company lease and maintenance fees.

 Critical
to the tax-free treatment and the continued validity of the PLR, the post-spin relationships of Cash America and the Company may not be tantamount to continued control of the Company by Cash America. None of these Separation-Related Agreements grant
Cash America the power to direct or cause the direction of the management and policies of the Company or grant any rights permitting Cash America to participate in the management or day-to-day operations of the Company’s business nor do they
grant Cash America indicia of control of the Company since doing so would conflict with requirements for the tax-free treatment of the Spin-off and jeopardize tax-free treatment.

Further, in connection with the Spin-off, all guarantees by the Company of Cash America’s indebtedness were released, and the Company is
not an obligor or guarantor of any Cash America indebtedness. In addition, Cash America is not an obligor or guarantor of any of the Company’s indebtedness (although, as further discussed below, Cash America’s guaranty of the
Company’s lease obligations on its present headquarters lease has not been released by the landlord and as such, Cash America’s guaranty will remain in place likely until in 2017 when the lease term expires). Approximately six months prior
to the Spin-off, the Company repaid all intercompany indebtedness owed to Cash America. There are not any financing agreements between Cash America and the Company. Each of the company’s financing arrangements is independent of each other.

The Company does not currently intend to enter into any other agreements with Cash America.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 December 4, 2014

 Page
 7

 The Company’s Board of Directors and Officers. Cash America does not have
the right, whether by contract or otherwise, to elect any members of the Company’s Board of Directors. The Board of Directors of the Company consists of seven members, five of whom are outside, independent directors, one of whom is the
Company’s Chief Executive Officer and the other is Mr. Feehan, Cash America’s CEO. The five outside, independent directors have no relationship or prior involvement or business dealings with Cash America. The Company expects that
Mr. Feehan will serve on the Company’s Board of Directors during a transitional period not to exceed two years from the date of the Spin-off to accommodate the Company’s need for his unique industry experience, to leverage his
well-developed relationships with banking and regulatory groups, and to provide a sense of business continuity. Mr. Feehan will stand for re-election as a director by the Company’s stockholders along with all of the Compa