November 21, 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 November 8, 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 October
3, 2024 letter.

Form 10-K for Fiscal Year Ended December 31, 2023
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

1.     We note your response to prior comment 3. Your intended, revised
disclosure
       continues to not quantify the effects of changes in price, volume, and
       acquisitions/dispositions on merchant revenues. You state the net effect
of acquisition
       and divestiture activities in Merchant Solutions contributed
approximately 8.6%
       growth to Merchant Solutions, primarily due to the revenues of the EVO
business
       acquired in March 2023. Please quantify for us the effect of the EVO
business
       acquisition on your Merchant Solutions segment revenues in absolute
dollars. Please
       also quantify for us the effect of other non-EVO related changes in
transaction volume
       on Merchant Solutions segment revenues in absolute dollars.
2.     You state Issuer Solutions revenue increased primarily due to an
increase in
 November 21, 2024
Page 2

      transaction volume. Please quantify for us the effect of changes in
transaction volume
      and any other material factors on this revenue category.
3.    Please quantify for us the effect of the divestiture of your consumer
business on cost
      of service in absolute dollars, which your intended, revised disclosure
describes as
      being approximately 1.5% of the 3.5% decline in cost of service as a
percent of
      revenue. Please also quantify for us the effect of the EVO acquisition on
cost of
      service. Lastly, tell us and revise to explain whether the $28.4 million
decrease in
      professional services and facilities costs is expected to continue in
future periods as
      part of prudent expense management.
4.    Please separately quantify for us the effect of acquired businesses,
divested
      businesses, and changes in corporate expenses on your selling, general
and
      administrative expenses in absolute dollars.
       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