VIA EDGAR
March 1, 2010
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Kevin Dougherty |
| Division of Corporation Finance |
| Re: | Points International Ltd. |
| Form 20-F for the year ended December 31, 2008 | |
| Filed 6/30/09 | |
| File No. 000-51509 |
Dear Mr. Dougherty:
In reference to our telephone conversation on February 26, 2010, Points International Ltd. (the “Company”) undertakes to include in future Form 20-F filings, to the extent applicable, a discussion, under Item 4 of that form, as to how the Company assesses its dependence on customer contracts.
The Company acknowledges and affirms the following:
- the Company is responsible for the adequacy and accuracy of the disclosure in the filing;
- staff comments or changes to disclosure in response to staff comments do not foreclose the U.S. Securities and Exchange Commission (“SEC”) from taking any action with respect to the filing; and
- the Company may not assert staff comments as a defense in any proceeding initiated by the SEC or any person under federal securities laws of the United States.
If you have any questions regarding the contents of this letter, please do not hesitate to contact me at (416) 596-6361.
Very truly yours,
/s/ Marc Shewchun
Marc Shewchun
Vice-President and General Counsel