September 17, 2018 Himanshu Patel Chief Financial Officer First Data Corporation 225 Liberty Street, 29th Floor New York, NY 10281 Re: First Data Corporation Form 10-K for the Fiscal Period Ended December 31, 2017 Filed February 21, 2018 File No. 001-11073 Dear Mr. Patel: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Information Technologies and Services