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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

 June 5, 2015

 Via EDGAR

 Mr. Raymond Be, Office of Chief Counsel

Mr. Dietrich King, Assistant Director

 United States
Securities and Exchange Commission

 101 F Street, NE

Washington, D.C. 20549

Re:
Enova International, Inc.

 Registration Statement on Form S-1 (the
“Registration Statement”)

 File No. 333-199733

Messrs. Be and King:

 On behalf of Enova
International, Inc. (the “Company”), we are transmitting this letter to address the matters discussed on our call held on Friday, May 22, 2015.

Discussion of Staff Legal Bulletin No. 4

The Securities and Exchange Commission (the “SEC”) has stated that a dividend of securities generally does not constitute a
“sale” within the meaning of Section 2(a)(3) of the Securities Act of 1933, as amended (the “Securities Act”), because such dividend does not constitute a disposition “for value” within the meaning of that section.
See Securities Act Release No. 33-929 (July 29, 1936). The Staff of the SEC issued Staff Legal Bulletin No. 4 dated December 16, 1997 (the “Staff Bulletin”) to address whether Section 5 of the Securities Act
applies to spin-offs. The Staff Bulletin states that a subsidiary does not have to register its shares under the Securities Act if the following five conditions are met:

1.
the parent shareholders do not provide consideration for the spun-off shares;

2.
the spin-off is pro-rata to the parent shareholders;

3.
the parent provides adequate information about the spin-off and the subsidiary to its shareholders and to the trading markets;

4.
the parent has a valid business purpose for the spin-off; and

 United States Securities and Exchange Commission

Messrs. Raymond Be and Dietrich King

 June 5, 2015

Page 2

5.
if the parent spins-off “restricted securities,” it has held those securities for at least two years.

The Company respectfully submits that Cash America International, Inc., a Texas corporation (“Cash America”), and the Company
complied with the Staff Bulletin and met all five conditions set forth above in connection with the tax-free distribution of approximately 80% of the Company’s issued and outstanding common stock to Cash America’s shareholders (the
“Spin-off”).

 We will discuss each condition in turn:

1.
The parent shareholders do not provide consideration for the spun-off shares

 In the
Spin-off, Cash America’s shareholders received shares of the Company’s common stock and were not required to make, and did not make, any payment or provide any consideration for the shares received.

2.
The spin-off is made pro rata to parent’s shareholders

 The Spin-off was made on a
pro rata basis to all of Cash America’s shareholders in proportion to each shareholder’s proportionate share ownership in Cash America. Each Cash America shareholder of record on the record date for the Spin-off received 0.915 shares of
Enova common stock for every one share of Cash America common stock held on the record date. The Cash America shareholders had the same proportionate ownership interest in the Company and Cash America both before and after the distribution.
Furthermore, fractional shares were handled in a manner that satisfied Question 6 of the Staff Bulletin. Fractional share interests were aggregated into whole shares and sold in the open market at prevailing market prices by an independent
distribution agent and the aggregate net cash proceeds of the open market sales were distributed pro rata, to each holder who would have otherwise received a fractional share. The distribution agent, in its sole discretion, without any influence of
Cash America or the Company, determined when, how and through which broker-dealer, and at what price to sell the whole shares, and the distribution agent was not an affiliate of either Cash America or the Company.

3.
The parent must provide adequate information to its shareholders and the trading markets

 United States Securities and Exchange Commission

Messrs. Raymond Be and Dietrich King

 June 5, 2015

Page 3

 Cash America satisfied the requirement of providing adequate information by filing the Form
10 (File No. 001-35503), including the Information Statement contained as Exhibit 99.1 (the “Information Statement”), to register the Company’s shares under the Securities Exchange Act of 1934, as amended (the “Exchange
Act”), and mailing to Cash America’s shareholders the Information Statement. The Information Statement described the Spin-Off and the Company and substantially complied with Regulation 14A or Regulation 14C under the Exchange Act, as
called for by the Staff Bulletin. The Company discussed this specific condition in its response letter, dated September 12, 2014, to the Staff’s comment letter, dated August 26, 2014, on the Company’s Registration Statement on
Form 10.

4.
The parent has a valid business purpose for the spin-off

 Cash America’s Board of
Directors determined that there were valid business purposes for the Spin-off. In this regards, Cash America’s Board of Directors determined that the separation of Cash America’s storefront retail business and the Company’s online
financial services business and the Spin-off would achieve a number of business purposes. The following benefits were set forth on pages 64 to 65 of the Information Statement:

•

Strategic Focus and Operational Flexibility. Position each company to pursue a more focused, industry-specific strategy, with the Company well-positioned to pursue value creation strategies in the online
financial services business and beyond, and Cash America well-positioned to focus on its remaining storefront retail services business, and create additional operational flexibility within each of the Company and Cash America.

•

Management Focus. Allow management of each company to concentrate that company’s resources wholly on its particular market segments, regulatory requirements, customers and core lending businesses, with
greater ability to anticipate and respond rapidly to changing markets and new opportunities.

•

Isolation of regulatory oversight and risks for each company. Allow for better definition of regulatory responsibilities, implementation of more efficient compliance activities and relations with regulators that
are more focused on each company’s distinct operations. In addition, the risk profile for each company will be directly aligned to each company’s operations.

•

 Recruiting and Retaining Employees. Allow each company to recruit and retain employees with expertise directly applicable to its needs and
pursuant to compensation

 United States Securities and Exchange Commission

Messrs. Raymond Be and Dietrich King

 June 5, 2015

Page 4

policies that are appropriate for its specific lines of business. In particular, following the distribution, the value of equity-based incentive compensation arrangements offered by each company
should be more closely aligned with the performance of its businesses, and the employee benefits offered by each company should be better tailored to the nature of each company’s business.

•

Access to Capital and Capital Structure. Eliminate competition for capital between the business lines. Instead, both companies will have direct access to the debt and equity capital markets to fund their
respective growth strategies and to establish a capital structure and dividend policy appropriate for their business needs.

•

Distinct investment identity. Enable investors to evaluate the merits, performance and future prospects of each company’s businesses and to invest in each company separately based on these distinct
characteristics and the investor’s particular different industry focus, investment goals and risk profile.

 The Staff
Bulletin states that “the parent must determine whether there is a valid business purpose for the spin-off.” The Company has been advised that Cash America determined that these constituted valid business purposes for the Spin-off, and the
Company believes that these were valid business purposes for the Spin-off.1

 While
the Staff Bulletin provides that “the facts of a particular situation will determine whether the business purpose is valid,” the Staff Bulletin goes on to say that the Staff has recognized the following examples as valid business purposes
for a spin-off: (i) “allowing management of each business to focus solely on that business,” (ii) “providing employees of each business stock-based incentives linked solely to his or her employer,”
(iii) “enhancing access to financing by allowing the financial community to focus separately on each business,” or (iv) “enabling the companies to do business with each other’s competitors.” Three of these examples
of valid business purposes are in sync with Cash America’s business purposes for the Spin-off set forth in the Information Statement.

Furthermore, the Staff Bulletin also provides three examples of invalid business purposes: (i) “creating a market in the spun-off
securities without providing adequate

1
 As discussed in this letter under “Private Letter Ruling and Request,” the tax-free characterization of the Spin-off required that the
Spin-off be carried out for one or more corporate business purposes.

 United States Securities and Exchange Commission

Messrs. Raymond Be and Dietrich King

 June 5, 2015

Page 5

information to the shareholders or to the trading markets,” (ii) “the creation of a public market in the shares of a company that has minimal operations or assets,” or
(iii) “the creation of a public market in the shares of a company that is a development stage company that has no specific business plan or whose business plan is to engage in a merger or acquisition with an unidentified company.”
None of these three invalid business purposes are applicable to the Company as (x) adequate information was provided to Cash America’s shareholders and the trading markets as discussed above, (y) the Company did not have minimal
operations or assets and (z) the Company’s business was not in any development stage and there were no plans for the Company to engage in a merger or acquisition following the Spin-off.

5.
If the parent spins-off “restricted securities,” the parent must have held those securities for at least two years

The Staff Bulletin states that the two-year holding period condition does not apply where the parent formed the subsidiary being spun-off,
rather than acquiring the business from a third-party. Cash America formed the Company on September 7, 2011, and accordingly, the Company respectfully submits that this final condition has been satisfied. Additionally, Cash America held the
shares for more than two years prior to the Spin-off, which also satisfies this condition.

 Discussion of Spin-offs of Less Than All of a
Subsidiary’s Shares

 The Staff Bulletin states that “[i]n a spin-off, a parent company distributes shares of a subsidiary to
the parent company’s shareholders.” The Staff Bulletin does not provide that the parent company is required to distribute all of the shares of a subsidiary to the parent company’s shareholders. In some cases, a parent may
distribute fewer than all of the shares of the spin-off company.

 In order for a partial spin-off to be tax-free, the parent must
generally distribute “control” of the spin-off company, as determined pursuant to the Internal Revenue Code (the “Code”) (i.e., at least 80% of the voting power of all of the shares and at least 80% of any non-voting
shares of the spin-off company), and the parent must establish to the satisfaction of the Secretary of the Treasury that it has a valid business purpose for retaining any shares of the spin-off
company.2

2
The additional requirement of having to satisfy the Secretary of the Treasury that a valid business purpose exists for retaining shares is likely a reason why 100% spin-offs are more common than partial spin-offs.

 United States Securities and Exchange Commission

Messrs. Raymond Be and Dietrich King

 June 5, 2015

Page 6

 While it is more common for parent companies to spin-off 100% of the shares of the company
being spun-off, other companies have engaged in partial spin-offs. We reviewed spin-off transactions that were filed with SEC on Form 10 over the last six years and we identified the following partial spin-offs filed in reliance on the Staff
Bulletin, in addition to the Company’s Spin-off:3

1.
Gannett Co., Inc.’s proposed spin-off of 98.5% of the outstanding shares of common stock of Gannett SpinCo, Inc. (File No. 001-36874) (Form 10 originally filed on March 12, 2015 and is currently in
process);

2.
Baxter International Inc.’s proposed spin-off of approximately 80.5% of the outstanding shares of common stock of Baxalta Incorporated (File No. 001-36782) (Form 10 originally filed on December 10, 2014
and is currently in process);

3.
Inland American Real Estate Trust, Inc.’s spin-off of 95% of the outstanding shares of common stock in Xenia Hotels & Resorts, Inc. (File No. 001-36594) (Form 10 originally filed on August 11,
2014 and effective in January 2015);

4.
Occidental Petroleum Corporation’s spin-off of at least 80.1% of the outstanding shares of common stock in California Resources Corporation (File No. 001-35743) (Form 10 originally filed June 5, 2014 and
effective on October 14, 2014);

5.
Tribune Company’s spin-off of 98.5% of the outstanding shares of common stock of Tribune Publishing Company (File No. 001-36230) (Form 10 originally filed December 9, 2013 and effective on July 21,
2014);

6.
Valero Energy Corporation’s spin-off of 80% of the outstanding shares of common stock of Corner Store Holdings, Inc. (File No. 001-35743) (Form 10 originally filed November 16, 2012 and effective on
April 9, 2013);

7.
Ralcorp Holdings, Inc.’s spin-off of at least 80% of the outstanding shares of common stock of Post Holdings, Inc. (File No. 001-35305) (Form 10 originally filed on September 26, 2011 and effective on
January 23, 2012);

3
None of the nine partial spin-offs listed involve spin-offs following an initial public offering, which was referred to in our telephone conference as one way in which companies effect spin-offs.

 United States Securities and Exchange Commission

Messrs. Raymond Be and Dietrich King

 June 5, 2015

Page 7

8.
Atlas Energy, L.P.’s spin-off of approximately 19.6% of its limited partner interest in Atlas Resource Partners, L.P. (File No. 001-35317) (Form 10 originally filed on October 17, 2011 and effective on
February 14, 2012); and

9.
Cardinal Health, Inc.’s spin-off of at least 80% of the outstanding shares of common stock in CareFusion Corporation. (File No. 001-34273) (Form 10 originally filed March 31, 2009 and effective on
July 24, 2009).

 We also have identified correspondence wherein the Staff has previously directly addressed and
accepted a registrant’s ability to rely on the Staff Bulletin in connection with a partial spin-off. Specifically, in a Staff comment letter dated November 15, 2011, the Staff requested Atlas Resource Partners, L.P. (“Atlas
Resource”) to provide a written analysis with respect to its eligibility to rely on the Staff Bulletin in connection with a partial spin-off of approximately 20% of Atlas Resource’s limited partnership interests by its parent Atlas Energy,
LP. See Atlas Resource Partners, dated November 15, 2011. In comment no. 8, the Staff wrote:

 “We note that you are not
registering the distribution of the registrant’s units to the unitholders of Atlas Energy, LP. If you intend to rely on Staff Legal Bulletin No. 4, please provide a detailed written analysis with respect to your eligibility to rely on such
interpretation. Please ensure that your response includes, without limitation, an analysis regarding how the distribution will be pro rata to the unitholders of Atlas Energy, LP.”

In a letter t