Global Payments Inc.

3550 Lenox Road

Atlanta, Georgia 30326

770-829-8000

www.globalpay.com

October 10, 2019

Via EDGAR

William H. Thompson

Accounting Branch Chief Office of Consumer Products

United States Securities and Exchange Commission

Mail Stop 3561

100 F Street, NE

Washington, D.C. 20549

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

File No. 1-16111

Request for Extension

Dear Mr. Thompson:

Global Payments Inc. (the "Company") acknowledges receipt of the letter dated October 1, 2019 from the Staff of the Division of Corporate Finance of the Securities and Exchange Commission. In an email exchange today with Ta Tanisha Meadows of the Staff, Ms. Meadows kindly granted the Company’s request for an extension to November 4, 2019 to respond to the Staff’s comment. Accordingly, the Company plans to respond to the Staff's comment letter on or before that date. The Company greatly appreciates the Staff's cooperation in this regard.

Sincerely,

/s/ David M. Sheffield

David M. Sheffield

Senior Vice President and Chief Accounting Officer

Service. Driven. Commerce