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April 24, 2023
William Sperry
Chief Financial Officer
HUBBELL INC
40 Waterview Drive
Shelton, CT 06484
Re:HUBBELL INC
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed, February 9, 2023
File No. 001-02958
Dear William Sperry:
            We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the fiscal year ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Adjusted Operating Measures, page 23
1.We note your reconciliations of adjusted operating measures on page 24 appear to
essentially provide a non-GAAP income statement as they include most of the line items
and subtotals presented on your GAAP income statement.  Please explain to us how you
determined the current format is appropriate and complies with Question 102.10 of the
Division of Corporation Finance's Compliance & Disclosure Interpretations on Non-
GAAP Financial Measures or tell us how you plan to modify it in future filings, so as not
to give undue prominence to the non-GAAP financial measures presented.
2022 Compared to 2021, page 25
2.It appears to us your current disclosures related to multiple financial statement line items
are similar and do not adequately quantify the factors you identify or explain the

 FirstName LastNameWilliam Sperry
 Comapany NameHUBBELL INC
 April 24, 2023 Page 2
 FirstName LastName
William Sperry
HUBBELL INC
April 24, 2023
Page 2
underlying reasons for changes, including if and how the changes could impact future
results.  Please revise your disclosures in future annual and quarterly filings to more fully
address the following:
•When you disclose and discuss multiple factors that impact your results, quantify the
impact of the factors you identify, for example, we note you identify multiple and
offsetting factors that impacted consolidated net sales, net sales by segment, cost of
goods sold, gross profit, operating income, and operating income by segment;
•In regard to consolidated net sales and net sales by segment, quantify the impact of
favorable price realization and higher unit volumes and disclose and discuss the
reasons for changes;
•In regard to cost of goods sold, gross profit, operating income, and operating income
by segment, quantify the impact of favorable price realization and higher costs and
disclose and discuss the reasons for changes; and
•In regard to the Utility Solutions segment, more fully explain the facts and
circumstances related to the commercial resolution and disclose the impact.

            In closing, 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.
            You may contact Kevin Stertzel at (202) 551-3723 or Anne McConnell at (202) 551-
3709 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing