January 13, 2025 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 completed our review of your filing. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Office of Trade & Services