January 19, 2006


Mail Stop 4561

VIA U.S. MAIL AND FAX (770) 829-8224

Mr. James G. Kelly
Chief Financial Officer
Global Payments, Inc.
10 Glenlake Parkway, North Tower
Atlanta, GA  30328-3495

      Re:	Global Payments, Inc.
      Form 10-K for the year ended May 31, 2005
      Filed August 15, 2005
      File No. 001-16111

Dear Mr. Kelly:

      We have reviewed your filing and have the following
comments.
We have limited our review to only the issues addressed below and
will make no further review of your documents.  In our comments,
we
ask you to provide us with supplemental information so we may
better
understand your disclosure.  After reviewing this information, we
may
or may not raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the year ended May 31, 2005

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations
Application of Critical Accounting Policies
Reserve for Operating Losses, pages 27 - 28

1. Your critical accounting estimate disclosure should supplement,
not duplicate, the description of accounting policies already
disclosed in the notes to the financial statements.  The
disclosure
should provide greater insight into the quality of the information
regarding financial condition and operating performance as well as
the variability that is reasonably likely to result from applying
the
accounting policy over time.  Please expand your disclosure in
future
filings to disclose your known historical losses and processing
volume used in developing an estimate of your operating losses and
qualitatively and quantitatively discuss how a change in these
assumptions could impact your financial statements.  Please show
us
how you will revise your disclosure in response to this comment.
Refer to SEC Release 33-8350.

Financial Statements and Notes
Note 1, Summary of Significant Accounting Policies
Goodwill and Other Intangible Assets, pages 38-39

2. Please tell us how you considered all of the factors in
paragraph
11 of SFAS 142 in determining that your DolEx trademark intangible
asset has an indefinite life.  In this regard please also describe
any legal, regulatory, contractual, competitive, economic or other
factors associated with this intangible asset and how you
considered
whether any of these factors limit the useful life of the
intangible
asset.  Finally, please tell us how you determined the fair value
including the assumptions and methodology used supporting the
value
assigned to this intangible asset.


*  *  *  *

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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 they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

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

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.



	You may contact Josh Forgione, at (202) 551-3431, or me, at
(202) 551-3403, if you have questions. Please respond to the
comments
included in this letter within 10 business days or tell us when
you
will provide us with a response.  Please file your response on
EDGAR.

								Sincerely,



      Steven Jacobs
      Accounting Branch Chief

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Mr. James G. Kelly
Global Payments, Inc.
January 19, 2006
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