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April 27, 2023

Mr. Karl Hiller

Branch Chief

Division of Corporation Finance

Office of Energy and Transportation

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Dear Mr. Hiller:

Pitney Bowes Inc. (the “Company”) is submitting the following response to the Staff’s comment letter dated April 4, 2023, relating to the Company’s Form 10-K for the fiscal year ended December 31, 2022, filed on February 17, 2023. In preparing our response, we have utilized the subheadings and item number references consistent with your letter.

Form 10-K for the Fiscal Year Ended December 31, 2022

Overview, page 16

1.We note that your discussion and analysis does not include GAAP measures of earnings on either a consolidated or segment basis. For example, you have comparisons of revenue and total Segment EBIT on a consolidated basis in the tabulation on page 16 and accompanying narratives, and similar comparisons along with cost of revenue and gross margin percentages on a segment basis, in the tabulations on pages 18-19.

We also note that in discussing revenues you attribute changes to various volumetric factors, such as "declining meter population and a shift to cloud-enabled products," "lower lease extensions," "Lower cross-border services volumes," "lower digital delivery services," and offsets for "domestic parcel delivery services," and "growth in subscription services," although you do not provide any quantification of the volumetric measures.

Item 303(a) and (b)(2) of Regulation S-K require a discussion and analysis of the consolidated financial statements, including

•significant components of revenues and expenses that would be material to an understanding of the results of operations;

•unusual or infrequent events or transactions, or significant economic changes that materially affected the amount of reported income from continuing operations;

•known trends or uncertainties that have had or that are reasonably likely to have a material favorable or unfavorable impact on revenue or income from continuing operations; events that are reasonably likely to cause a material change in the relationship between costs and revenues; and

•the extent to which material changes in revenues are attributable to changes in prices or to changes in volumes or amounts of goods or services being sold.

Please expand your discussion and analysis to more clearly address the consolidated results of operations, to encompass activity reported on page 38, such as revenues, cost of sales and net income, also to show the composition of Segment EBIT, to illustrate how your measure correlates with your cost of revenue amounts, gross margin percentages, and various changes in gross margin and the operating expenses referenced in your discussion of segment activity. Please also discuss the

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volumetric measures underlying revenues and the extent to which these have changed from period-to-period.

Given your references to productivity improvements in the Outlook section on page 17, Risk Factors section on page 11, and in discussing the Presort Services gross margin on page 19, please also clarify how you measure productivity for your various services and incorporate the relevant measures in your discussion and analysis.

Response:

The Company acknowledges the Staff’s comment regarding the tables on page 16 showing period-over-period comparison of revenue and Segment EBIT and related discussion. In future filings, the Company will expand its discussion and analysis to more clearly address consolidated results of operations. For example, the Company will provide a discussion of changes in consolidated revenues and net income in the “Overview of Consolidated Results” section of Management’s Discussion and Analysis of Financial Condition and Results of Operations.

The Company also acknowledges the Staff’s comment regarding the composition of segment EBIT. In future filings, the Company will expand its tabular disclosures of segment results to include the operating expenses of each segment, similar to the following example:

 Year Ended December 31,

     Favorable/(Unfavorable)

 2022  2021  Actual % Change  Constant Currency % change

Business Services Revenue $ 1,576,348    $ 1,702,580    (7) %  (7) %

Cost of Business Services 1,440,807    1,577,628    9  %

Gross Margin 135,541    124,952    8  %

Gross Margin % 8.6  %  7.3  %

Selling, general and administrative  225,514    212,705    (6) %

Research and development 10,335    10,920    5  %

Adjusted segment EBIT $ (100,308)   $ (98,673)   (2) %

The Company acknowledges the Staff’s comment regarding volumetric measures. In future filings, the Company will expand its discussion to be more descriptive about the types of volumes (i.e. parcels, print labels, etc.) it is referring to when discussing period-over-period changes.

The Company acknowledges the Staff’s comment regarding productivity improvements in the Outlook section on page 17, Risk Factors section on page 11, and in discussing the Presort Services gross margin on page 19. In future filings, the Company will expand its discussion to be more descriptive about how it measures productivity improvements. The Company also supplementally provides the following information:

•For its Presort segment, the Company primarily measures labor productivity based on mail “pieces fed per labor hour”, or PFpLH, which measures the number of mail pieces that are sorted per labor hour.

•For its Global Ecommerce segment, the Company primarily measures labor productivity based on the number of parcels processed per labor hour, or PPH.

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2.We note that you present various tabulations and commentary within the annual report and in earnings releases that include your measures of Segment EBIT, and summations of these measures, without presenting any corresponding GAAP measures of performance. We also note that your description of the measure does not correlate with the definition set forth in Exchange Act Release No. 47226 or Item 10(e)(1)(ii)(A) of Regulation S-K.

Item 10(e) of Regulation S-K requires certain disclosures when presenting non-GAAP financial measures including

•a presentation, having equal or greater prominence, of the most directly comparable GAAP financial measure;

•a reconciliation from the most directly comparable GAAP measure to the non-GAAP measure;

•the reasons you believe the non-GAAP measure provides useful information to investors regarding your financial condition and results of operations, and

•any additional purposes for which the non-GAAP measure is utilized.

Please expand your disclosures to include the relevant consolidated GAAP measures of financial performance along with a discussion and analysis having details that are responsive to the requirements referenced above. You will also need to select an alternate label for your segment and consolidated measures of EBIT, consistent with the guidance in the answer to Question 103.01 of our Non-GAAP Compliance and Disclosure Interpretations (C&DIs). You may also refer to the answers to Questions 102.10(a) and (b) and 104.04 of the Non-GAAP C&DIs, if you require further clarification or guidance regarding prominence and consolidated versions of segment performance measures.

Please similarly conform disclosures in earnings releases to comply with § 244.100 of Regulation G, particularly with regard to your use of the acronyms EBIT and EBITDA. Please submit the revisions that you propose to address the concerns outlined above in your periodic filings and associated communications.

Response:

The Company acknowledges the Staff’s comment regarding expanding its disclosures and discussion to include relevant consolidated GAAP measures of financial performance and refers the Staff to our response above for Comment 1.

The Company also acknowledges the Staff’s comment regarding selecting an alternate label for Segment EBIT and Segment EBITDA. The Company will revise Segment EBIT to Adjusted Segment EBIT and Segment EBITDA to Adjusted Segment EBITDA in future periodic filings and associated communications. The Company further provides that in future filings it will remove its disclosure and discussion of aggregate adjusted segment EBIT from its Management’s Discussion & Analysis (see pages 16-17 in the Company’s Form 10-K for the fiscal year ended December 31, 2022) and continue to provide the reconciliation of aggregate adjusted segment EBIT to net income provided in Note 3 – Segment Information on page 51 in the Company’s Form 10-K for the fiscal year ended December 31, 2022.

The Company will further update its labeling and other disclosures in future earnings releases. The Company has included as Exhibit 1 its year-end earnings release and accompanying schedules revised to reflect its proposed revisions.

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Management's Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources, page 21

3.We note your disclosure explaining that operating cash flows declined by $126 million in 2022 compared to 2021, that growth in your trade and finance receivables accounted for $100 million of this change, and that $34 million in certain payments during the more recent period accounted for the balance.

Please clarify how these details reconcile to the changes in the corresponding receivables reported on page 40, which appear to have increased $53 million, and the associated adjustments in the cash flow reconciliation on page 41 of $42 million and explain the reasons for the increases in trade and finance receivables.

Response:

The Company respectfully provides the following supplemental information regarding its disclosures of operating cash flows:

•As reported in its Consolidated Statement of Cash Flows, cash flows related to changes in trade and finance receivables were a net cash outflow, or use, of $42 million for the year ended December 31, 2022, compared to a net cash inflow, or source, of $58 million for the year ended December 31, 2021. Accordingly, the source of cash of $58 million from changes in trade and finance receivables in 2021 and the use of cash of $42 million from changes in trade and finance receivables in 2022 accounted for the year-over-year decrease in cash flows of $100 million from changes in these items.

•The difference between the increase in trade and finance receivables at December 31, 2022 reported in our Consolidated Balance Sheet (page 40) of $53 million and the associated change reported in the Consolidated Statement of Cash Flows (page 41) of $42 million for the year ended December 31, 2022, is due to noncash and nonoperating balance sheet changes totaling $11 million within trade and finance receivables which are reported on separate lines within the Consolidated Statements of Cash Flows. For example, these items include the impact of foreign currency changes on reported balances, noncash charges for credit loss, and changes in trade and finance receivables related to business dispositions and investments in loan receivables

The Company also respectively advises the Staff that the decrease of $100 million in year-over-year cash flows from trade and finance receivables was primarily due to significantly higher trade and finance receivables at the beginning of 2021 due to the impacts of COVID, relative to the beginning of 2022, which resulted in higher cash collections during 2021 relative to 2022.

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The Company acknowledges that:

•the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

•the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We trust the above comments are responsive to the questions raised by the Staff. We would be pleased to answer any further questions on these matters. Should there be any questions, please do not hesitate to call Julie Solomon at (203) 351-6779.

/s/ Ana Maria Chadwick

Ana Maria Chadwick

Executive Vice President, Chief Financial Officer

Copies:

Brian Lane - Gibson, Dunn & Crutcher, LLP

PricewaterhouseCoopers LLP

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EXHIBIT 1

Pitney Bowes Announces

Fourth Quarter and Full Year 2022 Financial Results

STAMFORD, Conn, January 31, 2023 – Pitney Bowes (NYSE: PBI), a global shipping and mailing company that provides technology, logistics, and financial services, today announced its financial results for the fourth quarter and full year 2022.

“We have made important progress in the quarter against several initiatives that are key to our long-term objectives,” said Marc B. Lautenbach, President and Chief Executive Officer. “Although financial performance did not meet our expectations, we have seen significant improvements which lay the groundwork for future success. Our SendTech and Presort businesses continued to deliver a solid and predictable performance, reaping the benefits of the investments we have made in those businesses over the last several years. Importantly, our Financial Services business performed very well and Global Ecommerce made substantial progress in ramping network volumes, profitability, and service levels.”

Fourth Quarter Financial Highlights

•Revenue in the quarter was $909 million, a decrease of 8 percent on a reported basis and flat on a comparable basis (1)

•GAAP EPS was $0.04 and Adjusted EPS was $0.06 in the quarter versus $0.01 and $0.06, respectively, in fourth quarter 2021

•Net income was $6 million and Adjusted EBIT was $49 million in the quarter compared to $5 million and $38 million, respectively, in third quarter 2022 and $1 million and $47 million, respectively, in fourth quarter 2021

•GAAP cash from operating activities was $167 million; Free Cash Flow was $108 million

•Cash and short-term investments were $681 million at the end of the year

Fourth Quarter Business Highlights

•Global Ecommerce processed 54 million in Domestic Parcel volume, ending the quarter with an annualized exit rate of approximately 200 million

•Global Ecommerce gross margins improved 300 basis points versus prior year, but short of our expectations

•Presort grew year-over-year revenues and expanded adjusted segment EBIT margins by 440 basis points versus third quarter 2022

•SendTech shipping-related revenues grew 30 percent year-over-year

Full Year 2022 Financial Highlights

•Revenue of $3.5 billion, a decrease of 4 percent on a reported basis and flat on a comparable basis

•GAAP EPS was $0.21 in 2022 versus ($0.01) in 2021; Adjusted EPS was $0.15 in 2022 versus $0.32 in 2021

•Net income was $37 million and Adjusted EBIT was $179 million in 2022 compared to a net loss of $1 million and Adjusted EBIT of $203 million, respectively, in 2021

•GAAP cash from operating activities and Free Cash Flow were $176 million and $68 million, respectively

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Full Year 2022 Business Highlights

•Global Ecommerce processed Domestic Parcel volumes of 170 million, grew Domestic Parcel revenue 10 percent, and expanded unit margins by $0.34 versus prior year

•Presort processed 16 billion pieces of mail and grew revenue by 5 percent

•SendTech grew equipment sales by 1 percent on a reported basis and 4 percent on a constant currency basis and increased finance receivables by $44 million to $1.2 billion

•SendTech introduced the Shipping 360 Platform and launched PitneyShip Pro, which helped drive shipping-related revenue growth of 22 percent

Earnings per share results are summarized in the table below

 Fourth Quarter Full Year

 2022 2021 2022 2021

GAAP EPS $0.04 $0.01 $0.21 ($0.01)

Discontinued Operations - - - $0.03

GAAP EPS from Continuing Operations $0.04 $0.01 $0.21 $0.02

Loss on Debt Redemption/Refinancing - - $0.02 $0.24

Restructuring Charges $0.03 $0.03 $0.