United States securities and exchange commission logo January 15, 2021 Ronald F. Clarke Chief Executive Officer Fleetcor Technologies, Inc. 3280 Peachtree Road, Suite 2400 Atlanta, GA 30305 Re: Fleetcor Technologies, Inc. Form 10-K for Fiscal Year Ended December 31, 2019 Filed March 2, 2020 File No. 1-35004 Dear Mr. Clarke: 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 Trade & Services cc: Joel May