TEXT-EXTRACT 2 filename2.txt October 1, 2019 Jeffrey Sloan Chief Executive Officer GLOBAL PAYMENTS INC 3550 Lenox Road Atlanta, Georgia 30326 Re: GLOBAL PAYMENTS INC Form 10-K for the fiscal year ended December 31, 2018 Filed February 21, 2019 Form 8-K filed July 30, 2019 Response dated August 19, 2019 File No. 1-16111 Dear Mr. Sloan: We have reviewed your August 19, 2019 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 8-K Filed July 30, 2019 Exhibit 99.1, page 1 1. We reviewed your response to the prior comment in our letter dated July 30, 2019 and note your proposed disclosures related to Adjusted net revenue plus network fees. Please revise this measure in future filings to exclude the adjustment for "network fees." The measure does not conform to Question 100.04 of the Non-GAAP Compliance & Disclosure Interpretations. The term "revenue" should not be used when discussing this measure on a gross basis. You may contact Ta Tanisha Meadows, Staff Accountant, at (202) 551-3322 or Donna Di Silvio, Staff Accountant, at (202) 551-3202 if you have questions regarding comments on the financial statements and related matters. Please contact Lilyanna Peyser, Special Counsel, at (202) 551-3222 with any other questions. Jeffrey Sloan GLOBAL PAYMENTS INC October 1, 2019 Page 2 Sincerely, FirstName LastNameJeffrey Sloan Division of Corporation Finance Comapany NameGLOBAL PAYMENTS INC CF Office of Trade & Services October 1, 2019 Page 2 cc: David Green, General Counsel FirstName LastName