August 8, 2018

Himanshu Patel
Chief Financial Officer
First Data Corporation
225 Liberty Street, 29th Floor
New York, NY 10281

       Re: First Data Corporation
           Form 10-Q for the Quarterly Period Ended March 31, 2018
           Filed May 1, 2018
           File No. 001-11073

Dear Mr. Patel:

       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 the Fiscal Period Ended December 31, 2017

General

1.     1. In your letter to us dated September 19, 2014, you told us that you
could have indirect
          contact with Syria and Sudan in connection with the processing of
debit or credit card
          transactions conducted in those countries with cards issued by a
financial institution
          for which you provide processing services. As you know, Syria and
Sudan are
          designated by the State Department as state sponsors of terrorism and
are subject to
          U.S. economic sanctions and/or export controls. Please describe to us
the nature and
          extent of any direct or indirect contacts with Syria and Sudan during
the last three
          fiscal years and the subsequent interim period, whether through
subsidiaries, affiliates,
          or other direct or indirect arrangements. For instance, your third
quarter 2017 earnings
          conference call transcript quotes your Chief Executive Officer as
stating that First
 Himanshu Patel
First Data Corporation
August 8, 2018
Page 2
             Data was chosen as the issuer processing partner for First Abu
Dhabi Bank. First Abu
             Dhabi Bank has branches and an office in Sudan. Tell us whether
any contacts
             involve the governments of Syria or Sudan or entities controlled
by those
             governments.
Form 10-Q for the Quarterly Period Ended March 31, 2018

Consolidated Financial Statements
Note 3: Revenue Recognition, page 14

2.       Please tell us and revise future filings to disclose the method by
which you amortize initial
         payments for new contracts and contract renewals over the period of
benefit. Refer to
         ASC 340-40-50-2.
       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 Rebekah Lindsey, Staff Accountant at (202) 551-3303 or
Craig Wilson,
Senior Assistant Chief Accountant at (202) 551-3226 with any questions.



                                                               Sincerely,
FirstName LastNameHimanshu Patel
                                                               Division of
Corporation Finance
Comapany NameFirst Data Corporation
                                                               Office of
Information Technologies
August 8, 2018 Page 2                                          and Services
FirstName LastName