April 21, 2020

James Kelly
Chief Executive Officer
EVO Payments, Inc.
Ten Glenlake Parkway
South Tower, Suite 950
Atlanta, Georgia

       Re: EVO Payments, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2019
           Filed February 27, 2020
           File No. 001-38504
           Form 8-K filed February 27, 2020

Dear Mr. Kelly:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies
Income Taxes, page 61

1.    We note that you have not recorded a valuation allowance against your
significant U.S.
      jurisdiction deferred tax assets, other than the U.S. interest
limitation. In light of the
      objective and verifiable negative evidence in the form of cumulative
losses over the three
      years ended December 31, 2019, please tell us your consideration of
providing more
      robust critical accounting policy disclosures regarding the various
judgments and
      assumptions made in determining the deferred tax assets are realizable,
including a
      discussion of the degree of uncertainty associated with key assumptions.
Such discussion
      would desirably provide specifics (e.g., projected future taxable income
assumes revenue
 James Kelly
EVO Payments, Inc.
April 21, 2020
Page 2
         and margin growth rates of X% and positive net income by what year) as
well as a
         description of potential events and/or changes in circumstances that
could reasonably be
         expected to negatively affect the key assumptions. Please refer to
Item 303(a)(3)(ii) of
         Regulation S-K and SEC Release No. 34-48960.
Consolidated Financial Statements
Consolidated Statements of Changes in Equity, page 71

2.       We note your presentation of a combined total for equity securities,
inclusive of
         redeemable non-controlling interests. Since redeemable non-controlling
interests are
         classified as mezzanine equity in recognition of the distinction
between these interests and
         permanent equity, please tell us your basis for inclusion of this
combined total on the face
         of your financial statements. Please refer to ASC 480-10-S99-1.
Form 8-K filed February 27, 2020
Non-GAAP Financial Measures, page A-1

3.       We note you describe Adjusted EBITDA and Pro forma adjusted net income
as excluding
         "the impact of net income from consolidated subsidiaries (including
related depreciation
         and amortization)." However, it appears Adjusted EBITDA and Pro forma
adjusted net
         income exclude net income attributable to non-controlling interests in
consolidated
         entities. Please tell us your consideration of revising your
description of these measures
         for clarification.
4.       We note your disclosure of pro forma adjusted net income per share on
a historical and
         forward looking basis. Please disclose a reconciliation of pro forma
weighted average
         common shares used in computing these measures to weighted average
common shares as
         computed under GAAP. Please refer to Instruction 2 to Item 2.02 Form
8-K and Item
         10(e)(1)(i) of Regulation S-K.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Robyn Manuel at 202-551-3823 or Bill Thompson at
202-551-3344
with any questions.



FirstName LastNameJames Kelly                                  Sincerely,
Comapany NameEVO Payments, Inc.
                                                               Division of
Corporation Finance
April 21, 2020 Page 2                                          Office of Trade
& Services
FirstName LastName