May 28, 2009
Via EDGAR
Mr. Mark Webb
Legal Branch Chief
Securities and Exchange Commission
Washington, DC 20549
| Re: | First Data Corporation |
Form 10-K for the Fiscal Year Ended December 31, 2008
Filed March 25, 2009
File No. 001-11073
Dear Mr. Webb:
On behalf of First Data Corporation (the “Company”), I am writing in response to your letter of May 13, 2009 (the “Comment Letter”) with respect to the Company’s Annual Report on Form 10-K for the year ended December 31, 2008 (the “10-K”). For your convenience, set forth below is the comment contained in the Comment Letter along with the response of the Company.
COMMENT: We note that the schedules and exhibits have been omitted from your credit agreement filed as Exhibit 10.1 to the Form 10-K. Please amend the Form 10-K to file your credit agreement in its entirety.
RESPONSE: The Company will file an amendment to its Form 10-K to include the credit agreement with the schedules and exhibits as Exhibit 10.1.
In addition, the Company acknowledges as follows:
| • | 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 Commission 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 Commission or any person under the federal securities laws of the United States. |
** * * *
If you have any questions regarding the foregoing, please contact the undersigned at (303) 967-7579.
| Very truly yours, |
| /s/ Gregg W. Sonnen |
| Gregg W. Sonnen |
| Chief Accounting Officer |
| First Data Corporation |
