SecProbe.io

July 23, 2018
Philip Angelastro
Executive Vice President and Chief Financial Officer
Omnicom Group Inc.
437 Madison Avenue
New York, New York 10022
Re:Omnicom Group Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed February 15, 2018
Form 10-Q for the Quarter Ended June 30, 2018
Filed July 17, 2018
File No. 001-10551
Dear Mr. Angelastro:
            We have reviewed your June 27, 2018 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in
our June 12, 2018 letter.
Form 10-Q for the Quarter Ended June 30, 2018
Notes to Consolidated Financial Statements
2. Revenue, page 6
1.We have reviewed your response to comment three.  We note you have combined
managing third-party service providers on behalf of clients to produce content or deliver
media or production services with other services into a single performance obligation.
Please provide us with a specific and comprehensive discussion of the nature of the
activities involved in these management services.  In addition, please clarify if you earn

 FirstName LastNamePhilip Angelastro
 Comapany NameOmnicom Group Inc.
 July 23, 2018 Page 2
 FirstName LastName
Philip Angelastro
Omnicom Group Inc.
July 23, 2018
Page 2
any commissions specific to these services.  If so, please tell us when the associated
revenue is recognized.  Finally, please tell us how you considered the guidance related to
variable consideration for a series. Reference ASC 606-10-32-40.
2.We have reviewed your response to comment four.  We note in your commission
arrangements you consider the airing of media a constraint and only record revenue when
the media has been run.  Please further explain why an estimate of variable consideration
cannot be made in an earlier period.  In addition, please reconcile your response to your
disclosure on page 7 hereunder in which you state that commission revenue is recognized
when it is probable that the media will be run.  Reference ASC 606-10-32-5 through 14.
3.We note your response to comment five.  Please address the following items:
•Quantify the significance of media purchases where you act as an agent and those
where you act as a principal.
•We note your assessment of indicators.  Please provide us with a more specific and
comprehensive discussion of how you considered the definition of control in your
analysis and whether you are directing the use of the purchased media and studio
production services.
•Please discuss how you considered the use of your Annalect, Omni and
Accuen platforms.
•In order for us to better understand your analysis, please provide us with representative
contracts and related invoices, if applicable, for your purchased media and studio
production services.

            You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert
Littlepage, Accountant Branch Chief at (202) 551-3361  if you have questions regarding
comments on the financial statements and related matters.  Please contact  Courtney Lindsay,
Staff Attorney at (202) 551-7237 or  Celeste Murphy, Legal Branch Chief at (202) 551-3257
with any other questions.
Division of Corporation Finance
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