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Correspondence

 HUNTON & WILLIAMS LLP

FOUNTAIN PLACE

 1445 ROSS AVENUE

SUITE 3700

DALLAS, TEXAS 75202-2799

 TEL

 FAX

 214 • 979 • 3000

214 • 880 • 0011

 February 10, 2015

Mr. Michael Clampitt

 Senior Counsel

United States Securities and Exchange Commission

 101 F Street,
NE

 Washington, D.C. 20549

Re:
Enova International, Inc.

 Amendment No. 1 to Registration Statement on Form S-1

 Filed December 5, 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 January 15, 2015 (the “Comment
Letter”), regarding the above-referenced registration statement on Form S-1 (the “Registration Statement”). For your convenience, we have repeated the comment in italics prior to the response.

Registration Statement on Form S-1

1.
 We note your response to prior comment 2 in our letter dated November 18, 2014. Based on your response, we are unable to concur with your view
that the subject transaction is appropriately characterized as a secondary offering under Rule 415(a)(1)(i). In this regard, we note that prior to November 13, 2014, Cash America was your parent company and owned all of the outstanding shares
of your common stock. Given that Cash America was your parent both at the time the instant registration statement (File No. 333-199733) was filed on October 30, 2014 and when you and Cash America entered into the Stockholder’s and
Registration Rights Agreement on November 12, 2014, it appears that the transaction represents a primary offering on behalf of the Company. Additionally, we note that pursuant to the Transition Services Agreement, dated November 12, 2014,
Cash America will provide to the Company certain services for a transitional period, including, without limitation, the maintenance of existing general ledger accounts and the opening/closing of monthly periods. See Schedule 1 to

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 February 10, 2015

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the Transition Services Agreement. Therefore, certain aspects of the offering continue to cause us to believe that the transaction should be viewed as a primary offering on behalf of the Company
and not a secondary offering as contemplated by Rule 415(a)(1)(i). Please revise or advise.

 Company Response:

 A. Timing of Filing of the Registration Statement and the Entering Into of the Stockholder’s and Registration Rights Agreement

 In our discussions with the Staff, the Staff explained that the Staff did not view the offering of the Company’s shares by Cash
America International, Inc. (“Cash America”) to be a secondary offering of shares by Cash America but viewed it as a disguised primary offering by the Company because at the time of the filing of the Registration Statement and entering
into of the Stockholders’ and Registration Rights Agreement (the “Registration Rights Agreement”) Cash America held all of the stock of the Company and had control over the Company. We advised the Staff that the terms of the
Registration Rights Agreement were not unilaterally established by Cash America. We discussed with the Staff that although at that time Cash America held all of the stock of the Company, procedures established by Cash America and extant
circumstances resulted in a more robust bargaining as to the terms of the registration rights than the Staff had inferred. The Company respectfully submits that the facts and circumstances discussed in this response letter demonstrate that at the
time that the Registration Statement was filed and the Registration Rights Agreement was entered into, the terms of the Registration Rights Agreement and the other four separation-related agreements were negotiated between the parties
notwithstanding Cash America’s share ownership.

 First, to understand how there could exist a negotiating environment between the
Company and Cash America, it is critical to understand the relationship between the Company and Cash America. A culture of separateness existed between the two companies largely because the e-commerce business (conducted through the Company) and the
retail services business (conducted through Cash America) are distinct and dissimilar businesses that were operated largely independently prior to the spin-off. Further underpinning the sense of separateness or independence was that the
Company’s business was conducted and directed through its own management team from a geographically distinct location. The Company’s headquarters are located in Chicago, Illinois, and Cash America’s headquarters are located in Fort
Worth, Texas. This is as a result of the purchase of the Company (then known as

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 February 10, 2015

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CashNetUSA) by Cash America in 2006 from its private owners who had established the Company just three years earlier. Because the businesses were distinct, the Company continued to operate
autonomously with no management from Cash America relocated to Chicago to supervise the business. Some services were shared between the companies at various times during the eight years that the Company was owned by Cash America, but many
traditional shared services such as human resources, information technology, accounting (except for accounts payable), marketing and legal were managed largely by the Company. In addition, the Company maintained its own management team, had its own
chief executive officer, had its own general counsel, and since July, 2014, had its own outside, independent law firm, Kirkland & Ellis LLP, all separate from Cash America.

Second, Cash America and the Company recognized the potential conflict inherent from the fact that the Company was a wholly owned subsidiary
negotiating the separation-related agreements with its parent company and that the Company’s interests as a new public company and the interests of its future stockholders could diverge from the interests of Cash America. To assuage these
concerns that the Company and Cash America had, Cash America and the Company determined that it was in the best interest of Cash America’s shareholders and the future shareholders of the Company that the Company have an independent board of
directors prior to the spin-off to review, consider and approve, among other things, the separation-related agreements and the Registration Statement.1 The members of the board of directors were
personally recruited by the Company’s Chief Executive Officer, with assistance from the recruiting firm Crist Kolder Associates pursuant to a letter agreement signed on March 10, 2014. On October 1, 2014, Cash America, in its capacity
as sole stockholder of the Company, elected seven directors to serve as the Company’s board of directors, five of whom are outside, independent directors, one of whom is the Company’s Chief Executive Officer and the other is Daniel R.
Feehan, Cash America’s chief executive officer. The five outside, independent directors were identified and slated to become independent directors by the Chief Executive Officer of the Company and they have no relationship or prior involvement
or business dealings

1
 While one might infer that management of the Company had little leverage in the negotiations since they were ultimately employees of Cash America,
this would be too narrow of a view of the circumstances. The buy-in and support of Company management for the spin-off was considered by Cash America to be critical to the feasibility of the spin-off. As a result, in negotiating the
separation-related agreements, Cash America solicited and sought to address concerns and changes proposed by Company management and its counsel to avoid jeopardizing the success of the spin-off (which Cash America believed could be jeopardized if
key employees terminated their employment with the Company prior to the spin-off due to their dissatisfaction with the process of preparing separation-related agreements and the terms themselves).

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 February 10, 2015

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with Cash America. Mr. Feehan was asked by the Company’s Chief Executive Officer to join the Company’s Board so that the Company could have the benefit of Mr. Feehan’s industry
experience and not as a representative of Cash America. As discussed in the timeline below, it is this board of directors who reviewed, considered and, at a board meeting held on October 14, 2014, approved the separation-related agreements and
the filing of the Registration Statement and who signed the Registration Statement. Furthermore, the Company respectfully advises the Staff that no person from Cash America attended this meeting of the Company’s board of directors, except for
Mr. Feehan. Mr. Feehan attended in his capacity as a director of the Company and not in his capacity as an officer of Cash America. The meeting was attended by all seven directors, certain individuals from the Company’s management
team, including the Company’s general counsel, and the Company’s outside legal counsel from Kirkland & Ellis LLP. 2

In connection with the spin-off, the Company and Cash America entered into five separation-related agreements to govern the relationship of
the Company and Cash America after the spin-off was completed. These agreements were described in the Company’s December 4, 2014 response letter. The terms of these agreements were not unilaterally established by Cash America. To the
contrary, Cash America furnished drafts of these agreements to the Company’s management for their review, consideration and comment, and the Company and Cash America exchanged comments and proposed changes and engaged in multiple discussions to
negotiate the terms of these agreements. During this process, the Company was represented by its own outside legal counsel and its separate in-house general counsel in the negotiations of these agreements.

2
This process established by the Company and Cash America is commonly employed to address interested party transactions to remove any conflict taint. For example, see Section 144 of the Delaware General Corporation
Law that provides that no contract between a corporation and another corporation in which one or more of its directors or officers are directors and officers or have a financial interest shall be void or voidable if the material facts are disclosed
and the board or committee in good faith authorizes the contract or transaction by the affirmative vote of the disinterested directors. Here, the disinterested directors of the Company served to overcome any potential conflict with Cash America, and
the Company respectfully submits that despite the ownership of the Company by Cash America, the disinterested approval should overcome the Staff’s concerns regarding Cash America’s control of the Company at the time the Registration
Statement was filed and the Registration Rights Agreement was entered into.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 February 10, 2015

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 In addition to the foregoing background on the Company’s historical relationship with
Cash America, the Company believes that the following facts and circumstances are helpful in better understanding the timeline and steps that were involved in the preparation, negotiation and approval of the separation-related agreements, the
Registration Statement and certain other documents and demonstrate that the agreements were not predetermined by Cash America, but rather, they were the result of negotiations between the Company and its advisors and Cash America and its advisors.

August 29, 2014

Cash America’s in-house legal counsel delivers drafts of the Separation and Distribution Agreement (the “Separation Agreement”), the Tax Matters Agreement and the Registration Rights Agreement to the Company’s
general counsel and certain members of the Company’s management team for their review and input.

September 4, 2014

The Company’s general counsel delivers drafts of the Separation Agreement, the Tax Matters Agreement and the Registration Rights Agreement to the Company’s outside law firm, Kirkland & Ellis LLP, seeking their comments
and input to these draft agreements.

September 7, 2014

The Company’s Director of Tax delivers to Cash America’s Vice President of Tax Administration comments to the Tax Matters Agreement.

September 8, 2014

The Company’s general counsel receives comments and proposed changes from Kirkland & Ellis LLP to the Registration Rights Agreement and the Separation Agreement and sends to Cash America’s in-house legal counsel (i)
comments and proposed changes to the Registration Rights Agreement prepared by the Company’s general counsel and Kirkland & Ellis LLP and (ii) comments and proposed changes to the Separation Agreement prepared by the Company’s general
counsel, the Company’s chief financial officer and Kirkland & Ellis LLP.

September 9, 2014

The Company’s general counsel distributes to Cash America comments and proposed changes to the Tax Matters Agreement prepared by the Company and Kirkland & Ellis LLP.

September 9, 2014

Cash America’s in-house legal counsel modifies the Registration Rights Agreement and Separation Agreement in response to proposed changes received from the Company and Kirkland & Ellis LLP and distributes revised drafts to
the Company.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 February 10, 2015

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September 12, 2014

Hunton & Williams LLP, Cash America’s outside counsel, modifies the Tax Matters Agreement in response to proposed changes received from the Company. Cash America’s Vice President of Tax Administration distributes a
revised draft of the Tax Matters Agreement to the Company.

September 12, 2014

The Company’s Director of Tax distributes to Cash America comments and proposed changes to the Tax Matters Agreement prepared by the Company. The Company’s Director of Tax and Cash America’s Vice President of Tax
Administration negotiate and discuss terms of the Tax Matters Agreement.

September 12, 2014

The Company’s chief financial officer and general counsel engage in discussions with Cash America’s in-house legal counsel and Hunton & Williams LLP regarding provisions in the Registration Rights Agreement and the
Separation Agreement. The Company and Cash America work to come to final agreement on the terms of the form of Registration Rights Agreement and Separation Agreement in order that the final forms of those agreements could be filed with Amendment No.
1 to the Form 10 Registration Statement (the “Form 10”). Amendment No. 1 to the Form 10, which included the forms of Registration Rights Agreement and Separation Agreement, was not filed until sign off of the forms by the
Company’s general counsel and chief financial officer.

September 15, 2014

The Company’s Director of Tax sends Cash America’s Vice President of Tax Administration proposed changes to the Tax Matters Agreement prepared by the Company and Kirkland & Ellis LLP.

September 16, 2014

The Company’s Director of Tax, Kirkland & Ellis LLP, Cash America’s Vice President of Tax Administration and Cash America’s counsel, Hunton & Williams LLP, have a conference call to discuss and negotiate
proposed changes by the Company and Kirkland & Ellis LLP to the Tax Matters Agreement.

September 20, 2014

Cash America’s in-house legal counsel delivers a draft of the Company’s Amended and Restated Certificate of Incorporation, Amended and Restated Bylaws, and Corporate Governance Principles to the Company’s general
counsel and Chief Executive Officer for their review and input.

 United States Securities and Exchange Commission

Mr. Michael Clampit