Correspondence

LOGO

October 7, 2010

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 4561

Washington, D.C. 20549

 

Attn: Melissa Walsh, Staff Accountant

 

  Re: Alliance Data Systems Corporation

Form 10-K for the Fiscal Year Ended December 31, 2009

Form 10-Q for the Quarterly Period Ended March 31, 2010

Form 10-Q for the Quarterly Period Ended June 30, 2010

File No. 001-15749

Dear Ms. Walsh:

Alliance Data Systems Corporation, a Delaware corporation (the Company), is in receipt of the letter dated September 23, 2010 from the Securities and Exchange Commission Staff (the “Staff”) relating to the Company’s Form 10-K for the Fiscal Year Ended December 31, 2009, Form 10-Q for the Quarterly Period Ended March 31, 2010 and Form 10-Q for the Quarterly Period Ended June 30, 2010, each filed with the Securities and Exchange Commission (the “Commission”) (the “Comment Letter”).

Per your instructions to the Company, this letter will confirm that the Company will submit its response to the Comment Letter after October 7, 2010, but on or before October 22, 2010. The additional time will enable the Company to coordinate the Company’s response with the Company’s third quarter 2010 earnings release.

If you have any questions with respect to the foregoing, please call Charles Horn, our Executive Vice President and Chief Financial Officer at (214) 494-3612.

 

Sincerely,

/s/ Alan M. Utay

Alan M. Utay
Executive Vice President and General Counsel


United States Securities and Exchange Commission

Attn: Melissa Walsh

October 7, 2010

Page 2

 

Copies:    Edward J. Heffernan
   President and Chief Executive Officer
   Alliance Data Systems Corporation
   7500 Dallas Parkway, Suite 700
   Plano, TX 75024
   Charles L. Horn
   Executive Vice President and Chief Financial Officer
   Alliance Data Systems Corporation
   7500 Dallas Parkway, Suite 700
   Plano, TX 75024