United States securities and exchange commission logo




                                                                                
                              May 6, 2024

       James Kehoe
       Chief Financial Officer
       Fidelity National Information Services, Inc.
       347 Riverside Avenue
       Jacksonville, FL 32202

                                                        Re: Fidelity National 
Information Services, Inc.
                                                            Form 10-K for the 
fiscal Year Ended December 31, 2023
                                                            Form 8-K furnished 
February 26, 2024
                                                            File No. 001-16427

       Dear James Kehoe:

                                                        We have reviewed your 
filings and have the following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in 
your response.

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

       Form 8-K furnished February 26, 2024

       Constant currency revenue, page 4

   1.                                                   Please provide a clear 
description of the process for calculating the constant currency
                                                        amounts. Refer to 
Question 104.06 of the Non-GAAP Financial Measures Compliance
                                                        and Disclosure 
Interpretations..
       Free cash flow, page 9

   2.                                                   Please revise the title 
of your free cash flow measure to adjusted free cash flow or a
                                                        similar description as 
your calculation differs from the typical calculation of cash flows
                                                        from operating 
activities less capital expenditures. Refer to Question 102.07 of the Non-
                                                        GAAP Financial Measures 
Compliance and Disclosure Interpretations.
 James Kehoe
FirstName  LastNameJames    Kehoe
Fidelity National Information Services, Inc.
Comapany
May  6, 2024NameFidelity National Information Services, Inc.
May 6,
Page 2 2024 Page 2
FirstName LastName
Notes to Unaudited - Supplemental GAAP to Non-GAAP Reconciliations for the 
three months
and years ended December 31, 2023 and 2022.
Exhibit H, page 13

3.       We note your adjustment for acquisition, integration and other costs 
includes    Enterprise
         transformation, including Future Forward and platform modernization.   
 Please tell us the
         nature of these costs, your consideration of Question 100.01 of the 
Non-GAAP Financial
         Measures Compliance and Disclosure Interpretations, including why they 
are not related
         to normal, recurring, cash operating expenses and explain why this 
adjustment is deemed
            non-operational.   
        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.

       Please contact Scott Stringer at 202-551-3272 or Joel Parker at 
202-551-3651 if you have
questions regarding our comments.



                                                             Sincerely,

                                                             Division of 
Corporation Finance
                                                             Office of Trade & 
Services