September 12, 2019

Daniel Chism
Chief Financial Officer
EZCORP INC
2500 Bee Cave Road
Rollingwood, TX 78746

       Re: EZCORP INC
           Form 10-K for the Fiscal Year Ended September 30, 2018
           Filed November 14, 2018
           File No. 000-19424

Dear Mr. Chism:

      We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.

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

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

Form 10-K for the Fiscal Year Ended September 30, 2018

Item 7 - Management's Discussion and Analysis of Financial Condition and
Results of
Operations
Critical Accounting Policies and Estimates
Goodwill and Other Intangible Assets, page 43

1.    We note your statement that your reporting units with goodwill are
equivalent to your
      operating segments for fiscal 2018. We have the following comments:

          Please tell us your operating segments as of September 30, 2018. If
your operating
          segments changed during 2019, also tell us your operating segments as
of June 30,
          2019.

          If you have aggregated any of your operating segments when
determining your
          reportable segments, please revise the segment footnote in your
financial statements to
          disclose that operating segments have been aggregated. See ASC
280-10-50-21(a).
 Daniel Chism
FirstNameINC
EZCORP LastNameDaniel Chism
Comapany 12, 2019
September NameEZCORP INC
Page 2
September 12, 2019 Page 2
FirstName LastName
             Also tell us how you considered identifying your operating
segments within
             this Critical Accounting Policy to provide your investors with
greater insight into the
             estimates and judgments made by management when determining your
reporting units.

             We note that you test goodwill for impairment annually during your
fourth fiscal
             quarter and you recorded no goodwill impairment in fiscal 2018.
Please tell us
             whether you performed a quantitative impairment test in fiscal
2018. If so, please tell
             us the percentage by which the fair value of each of your
reporting units exceeded the
             carrying value of each such reporting unit as of the date of that
test. If you only
             performed a qualitative assessment in fiscal 2018, please tell us
how you considered
             the guidance in ASC 350-20-35-3C through 35-3G, and how those
factors supported a
             conclusion that it was not more likely than not that the fair
value of each reporting unit
             was less than its carrying value. Your response also should
address how you
             considered the decline in your stock price during the last several
months of fiscal 2018
             which resulted in the book value of your shareholders' equity
significantly exceeding
             the market capitalization of your company as of September 30,
2018. If you believe
             the market capitalization of your company was not representative
of the fair value of
             your reporting units, please tell us why.

             We note the volatility of your stock price during fiscal 2019 and
that as of June 30,
             2019 the book value of your stockholders' equity continued to
significantly exceed the
             market capitalization of your company. With reference to ASC
350-20-35-30, please
             tell us how you considered whether you should perform an interim
test of impairment
             for your goodwill balances. If you believe the market
capitalization of your company
             was not representative of the fair value of your reporting units
as of June 30, 2019,
             please tell us why.

             Please tell us whether you have completed your annual goodwill
impairment testing
             for fiscal 2019. If so, please tell us whether you only performed
a qualitative
             assessment or whether you performed a quantitative assessment, and
the results of
             such testing.
        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.
 Daniel Chism
EZCORP INC
September 12, 2019
Page 3

       You may contact Robert Babula, Staff Accountant at (202) 551-3339, if
you have
questions regarding comments on the financial statements and related matters.
Please contact
Jennifer Thompson, Branch Chief at (202) 551-3737, with any other questions.



FirstName LastNameDaniel Chism                             Sincerely,
Comapany NameEZCORP INC
                                                           Division of
Corporation Finance
September 12, 2019 Page 3                                  Office of Consumer
Products
FirstName LastName