December 12, 2008

H. Christopher Owings

Assistant Director

United States Securities and Exchange Commission

Mail Stop 3561

100 F Street, NE

Washington, D.C. 20549

Form 10-K for the fiscal year ended May 31, 2008

Filed July 30, 2008

File No. 001-16111

Dear Mr. Owings:

This letter sets forth the responses of Global Payments Inc. (the “Company”) to the comments of the Staff of the Commission, dated November 21, 2008, with regard to the above referenced filing. Those comments requiring changes to our periodic disclosure will be reflected in our future required filings as detailed below, commencing with the Form 10-Q for the quarter ended November 30, 2008 and the Form 10-K for the year ending May 31, 2009, as applicable.

For convenience, each Staff comment is reprinted, numbered to correspond with the paragraph numbers assigned in the Staff’s letter, and is followed by the corresponding response of the Company.

Annual Report on Form 10-K for Fiscal Year Ended May 31, 2008

Item 1 – Business

General

Response: Our segments do not exhibit significant seasonality across fiscal quarters. While certain periods experience increases in processing volume and associated increases to our funding requirements, these peak periods tend to be either preceded or followed by periods of lower processing volume within the same fiscal quarter. As a result, the impact of seasonality is not significant on a quarterly basis. As a percentage of total annual revenue, quarterly revenue has been within a range of 23% to 28% for each of our segments over the last two fiscal years. On a consolidated basis, quarterly revenue has ranged from 24% to 27% of annual revenue over that same period.

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Our Canadian Credit Facility includes an expansion feature that is available to us if processing volumes warrant it. However, we have not drawn on this particular facility since August 2006.

Since our segments do not exhibit significant seasonality across fiscal quarters, we do not believe that a discussion of seasonality is material to an understanding of our business taken as a whole.

Response: We note that we have disclosed financial information about long-lived assets in our geographic areas in Note 11 to the Consolidated Financial Statements included in our Form 10-K for the fiscal year ended May 31, 2008. We confirm that we will include a cross-reference to this disclosure in the Business section of our Form 10-K for the fiscal year ending May 31, 2009.

Item 7 – Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 28

Commitments and Contractual Obligations, page 44

Response: We note that as of May 31, 2008 we did not have any long-term debt obligations. In June 2008, we entered into a new $200 million term loan facility as disclosed in Note 16 to the Consolidated Financial Statements and in the Credit Facilities discussion in Management’s Discussion and Analysis of Financial Condition and Results of Operations included in our Form 10-K for the fiscal year ended May 31, 2008. Such disclosures, including required principal payments and current interest rates, were repeated in both the Notes and MD&A included in our Form 10-Q for the quarter ended August 31, 2008 and will be repeated in future 10-Q filings. We will include both the required principal payments and estimated interest payments (based on LIBOR rates as of the balance sheet date) in the Commitments and Contractual Obligations table in our Form 10-K for the fiscal year ending May 31, 2009.

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Item 9A-Controls and Procedures, page 86

Evaluation of Disclosure Controls and Procedures, page 86

Please confirm to us, and revise future filings to clarify, if true, that your officers concluded that your disclosure controls and procedure also are effective to ensure that information required to be disclosed in the reports that you file or submit under the Exchange Act is accumulated and communicated to your management, including your principal executive officer and principal financial officer, to allow timely decisions regarding required disclosure. See Exchange Act Rule 13a-15(e). Alternatively, you may revise future filings to simply state that your disclosure controls and procedures are effective or ineffective without providing the definitions.

Response: We confirm that our officers concluded that our disclosure controls and procedures are also effective to ensure that information required to be disclosed in the reports that we file or submit under the Exchange Act is accumulated and communicated to our management, including our principal executive officer and principal financial officer, to allow timely decisions regarding required disclosure. We will revise future filings so that our disclosures under the heading Evaluation of Disclosure Controls and Procedures conform to the definition of disclosure controls and procedures set forth in Exchange Act Rule 13a-15(e), commencing with our Form 10-Q for the quarter ended November 30, 2008.

Index to Exhibits, page 96

General

Response: We do not consider the credit facility with the National Bank of Canada to be a material contract and determined that this agreement was not required to be filed as an exhibit to our Form 10-K for the fiscal year ended May 31, 2008. We based this assessment on both the nature and the amount available under the facility. This facility represents a contract made in the ordinary course of business that we use to fund merchants in advance of receipt of proceeds from card associations. We also note that the base amount of the facility ($45.3 million US based on the exchange rate at May 31, 2008) represents 3.1% of our total assets at May 31, 2008 and that the maximum amount, which is only available to us on specific days, represents 5.9% of our total assets as of May 31, 2008. Further, through the date of this letter our

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maximum borrowing under this facility has been $45.3 million US, or 3.1% of our total assets at May 31, 2008. Finally, monthly borrowings since the inception of this facility have averaged $4.4 million or 0.3% of our total assets at May 31, 2008. Based on the above, we do not consider the National Bank of Canada credit facility agreement to be a material contract.

Exhibits 31.1 and 31.2

Rule 13a-14(a)/15d-14(a) Certifications

Response: We confirm that we will revise future filings, commencing with our Form 10-Q for the quarter ended November 30, 2008, so that the wording of our certifications pursuant to Section 302 of the Sarbanes-Oxley Act of 2002 precisely matches the language set forth in Item 601(b)(31) of Regulation S-K.

In connection with our responses to your comments, we acknowledge that:

We appreciate your constructive comments to assist us in our compliance with the applicable disclosure requirements and to enhance the overall disclosure in our filings. Should you, or any member of your team, wish to discuss these responses with me, please contact me at (770) 829 – 8922 or Danny O’Keefe, our Chief Accounting Officer, at (770) 829 – 8492.

Sincerely,

GLOBAL PAYMENTS INC.

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