October 3, 2024

Josh Whipple
Chief Financial Officer
Global Payments Inc.
3550 Lenox Road
Atlanta, GA 30326

        Re: Global Payments Inc.
            Form 10-K for Fiscal Year Ended December 31, 2023
            File No. 001-16111
Dear Josh Whipple:

       We have reviewed your September 25, 2024 response to our comment letter
and have the
following comment(s).

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

        After reviewing your response to this letter, we may have additional
comments. Unless we
note otherwise, any references to prior comments are to comments in our August
27, 2024 letter.

Form 10-K for Fiscal Year Ended December 31, 2023
Other
Earnings slide deck dated February 14, 2024
Reconciliation of Non-GAAP Financial Measures, page 9

1.     We note    net revenue adjustments    primarily consist of adjustments
for gross-up related
       payments (included in operating expenses) associated with certain lines
of business to
       reflect economic benefits to the company. Please tell us the nature of
these payments and
       where they are classified in your statements of income.
Other
Earnings call transcript dated February 14, 2024, page 7

2.     In prepared remarks, you stated Issuer Solutions performance declined
compared to the
       prior year due to a difficult comparison resulting from vendor benefits
reflected in that
       period. Please tell us the nature of these vendor benefits, quantify the
amounts for us, and
       tell us how you account for them.
 October 3, 2024
Page 2

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Year Ended December 31, 2023 Compared to Year Ended December 31, 2022, page 42

3.     We note your response to prior comment 1. Regarding results of
operations discussion
       and analysis, you state you primarily list factors in order of
magnitude, provide
       quantitative data where material to an understanding of results, and use
qualitative
       language that provides context for the relative magnitude of factors.

       While listing factors in order of magnitude and using qualitative
language is not
       objectionable in and of itself, it is an indirect and less useful way to
provide needed
       information to your investors. We believe investors are best served by
direct and clear
       quantification of all material factors driving results.

       In this regard, we note your intended, revised disclosure continues to
either not quantify
       certain factors at all or to sometimes quantify them in an indirect
manner, such as by
       references to percentages of accounts balances or by stating them in
terms of basis points.
       We believe you should make it easy for investors to obtain quantified
impacts of factors,
       by stating them in absolute dollars.

       You also state you will quantify significant contributing factors where:
(a) you describe
       two or more factors and (b) to the extent such information is available
and appropriate to
       enhance investors    understanding of the magnitude of the impact of
each factor. It would
       appear unlikely that you would be able to attribute a change in results
to a factor while not
       having quantification of such factor. In addition, we are not aware of
circumstances in
       which it would not be appropriate to provide quantification to investors
of information
       that is available internally to, and used by, management.

       Excluding the three sentences that repeat revenue amounts and percentage
changes
       already disclosed in the immediately preceding table on page 41, your
original discussion
       and analysis of revenues in your Form 10-K was limited to three brief
sentences, none of
       which included a single quantification of factors affecting revenue
results. For a company
       with the size and breadth of operations as yours, we do not believe that
this brief
       disclosure adequately discussed and analyzed your results sufficient to
provide your
       investors with the depth of understanding and knowledge necessary to
properly evaluate
       your results.

       As such, we believe you should revise your disclosure and consider:

             relying on tables to present dollar and percentage changes in
accounts, rather than
           including and repeating such information in narrative text form;
             using additional tables to list, quantify, and sum all of the
material individual factors
           to which changes in accounts are attributable;
             refocusing the narrative text portion of the disclosure on
analysis of the underlying
           business reasons for the individual factors in the tables above;
             ensuring that all material factors are quantified and analyzed;
and
 October 3, 2024
Page 3

             quantifying the effects of changes in price, volume, and
acquisitions/dispositions on
           revenues and expense categories, where appropriate.

       Please provide us with a copy of your intended, revised disclosure.
4.     With regards to cost of service disclosure, we note that cost of service
decreased 1.4%
       despite a $0.67 billion, or 7.6%, increase in revenue. Your intended
revised disclosure
       attributes your consolidated cost of service expense result to
continued prudent expense
       management    and two other factors that    largely    offset each
other. Please revise to
       explain the nature of components of your cost of service expenses, such
that these costs
       are able to not vary significantly with changes in business volume.
Please also expand to
       explain your prudent expense management including what specifically that
entailed and
       how it impacted your expenses.
5.     You state you do not believe including a separate discussion of cost of
service for each
       segment is necessary for a user to understand trends in the business.
While disclosure
       should address known or reasonably likely trends in results, it should
also address
       material changes from period-to-period in line items and describe the
underlying reasons
       for these material changes in quantitative and qualitative terms. We
note operating
       margins in the Merchant Solutions segment were essentially flat year to
year, while
       operating margins in the Issuer Solutions declined. Based on your
description of your
       business, it appears that different lines of business within and between
your segments may
       have differing significant cost elements (e.g., technology-enabled and
relationship-led
       distribution channels in merchant solutions).

       We believe you should quantify and discuss the impact of each
significant component of
       costs comprising cost of service that caused it to materially vary (or
not vary when
       expected to). This disclosure should be presented in a manner to allow
investors to discern
       the relative contribution of each of multiple components cited to the
total change in cost
       of service. In addition, the impacts of material variances in components
of cost of service
       that offset each other should be separately disclosed, quantified, and
discussed (and not
       netted). Please also ensure that your disclosure provides appropriate
explanation of
       underlying reasons for changes (for example, in addition to quantifying
the impacts of
       changes in volume and acquisitions and dispositions in absolute amounts,
explain the
       underlying reasons "why" for these changes). Given the potential for
differing or
       offsetting results in your various segments, we encourage you to provide
the above
       disclosures at the segment level (which may make disclosure at the
consolidated level not
       needed). In any event, you should revise to provide discussion and
analysis of cost of
       revenue at the segment level when a change in a segment   s cost of
revenue materially
       impacts the segment   s measure of profit. Please provide us with a copy
of your intended,
       revised disclosure.
Notes to Consolidated Financial Statements
Note 1 - Basis of Presentation and Summary of Significant Accounting Policies
Revenue Recognition, page 65

6.     Please tell us where you classify signing incentives paid to customers
in your consolidated
       statements of cash flows.
 October 3, 2024
Page 4

Note 4 - Revenues, page 82

7.     We note your response to prior comment 2. We note that you provide
information about
       categories of your revenues in earnings calls and investor
presentations. For example,
       your February 14, 2024, fourth quarter 2023 earnings call contains the
following
       information:

             Merchant Solutions segment performance:
            o Was led by software-centric businesses, which delivered
double-digit growth in
              the quarter. Specifically, Zego, School Solutions, and AdvancedMD
delivered
              double-digit growth in the quarter and point-of-sale businesses
again grew
              roughly 20%.
            o Double-digit growth in Spain and Central Europe as well as in
Poland and
              Greece. LATAM business benefited from the strong secular payments
trends in
              Mexico and Chile. This performance was partially offset by
ongoing weakness in
              the macro environment in the UK and Canada.
            o A bullish area with prospects to drive better rates over time is
point-of-sale
              software, with meaningful investments in that area.
             Issuer Solutions segment performance:
             o Core issuer business grew mid-single-digits this quarter, driven
by strength in
                volume-based revenue. This was partially offset by slower
growth in managed
                and output services as you focus the issuer business on more
technology
                enablement.
             o Issuer transactions grew high single-digits led by commercial
card transactions,
                which increased low double-digits, highlighting ongoing
strength in cross-border
                corporate travel.

       Your investor presentation of the same date included the following
information:

             Merchant Solutions:
            o 20%+ increase in new Integrated sales
            o ~20% POS growth
            o Double digit organic growth in LATAM region

             Issuer Solutions:
             o 6% core Issuer growth
             o 17% growth in MineralTree mid-market channel


       Please tell us how you considered your provision of this information
outside the financial
       statements, which is presumably used by you and users of your financial
statements to
       evaluate performance, when determining your disaggregated revenue
disclosure. Refer to
       ASC 606-10-55-90.
 October 3, 2024
Page 5

       Please contact Robert Shapiro at 202-551-3273 or Lyn Shenk at
202-551-3380 if you
have questions regarding comments on the financial statements and related
matters.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Trade &
Services