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SEC Company Response from TEAM INC (TISI) (CIK 0000318833) (TISI) — Aug 10, 2017

TEAM INC (TISI) (CIK 0000318833)
Date: Aug. 10, 2017 · CIK: 0000318833 · Accession: 0000318833-17-000042

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File numbers found in text: 001-08604

Referenced dates: August 1, 2017

Date
August 10, 2017
Author
/s/ Greg L. Boane
Form
CORRESP
Company
TEAM INC (TISI) (CIK 0000318833)

Letter

United States Securities and Exchange Commission Form 10-K for Fiscal Year Ended December 31, 2016 Filed March 16, 2017 Form 8-K filed May 10, 2017 File No. 001-08604

Dear Mr. French:

This letter responds to the comment Team, Inc. (“we,” “our,” “Team,” or the “Company”) received from the U.S. Securities and Exchange Commission (the “SEC”) by letter dated August 1, 2017 regarding the above-referenced filing.

We hope this letter is responsive to your comment and request for information. The Company’s goal is to address the comment in a manner that is acceptable to the SEC staff.

For your convenience, our response is prefaced by the SEC’s comment.

Form 8-K filed May 10, 2017

In future filings, please remove the description “non-routine” from any non-GAAP adjustment that has occurred in the prior two years or is reasonably likely to recur within the next two years. Please refer to Question 102.03 of the updated Non-GAAP Compliance and Disclosure Interpretations issued on May 17, 2016.

Team Response:

We acknowledge the staff’s comment and in future filings we will remove the description “non-routine” from any non-GAAP adjustment that has occurred in the prior two years or is reasonably likely to recur within the next two years as noted in Question 102.03 of the updated Non-GAAP Compliance and Disclosure Interpretations issued on May 17, 2016.

* * * *

Page 1 of 2

We would be pleased to address any further comments that the Commission has with respect to our filings.

Very truly yours,
/s/ Greg L. Boane

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CORRESP
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		Document

13131 Dairy Ashford, Suite 600

Sugar Land, Texas 77478

August 10, 2017

BY EDGAR

United States Securities and Exchange Commission

100 F Street, NE

Washington D.C. 20549

Mail Stop 3720

Attn: Terry French

RE:

 Team, Inc.

 Form 10-K for Fiscal Year Ended December 31, 2016

 Filed March 16, 2017

 Form 8-K filed May 10, 2017

 File No. 001-08604

Dear Mr. French:

This letter responds to the comment Team, Inc. (“we,” “our,” “Team,” or the “Company”) received from the U.S. Securities and Exchange Commission (the “SEC”) by letter dated August 1, 2017 regarding the above-referenced filing.

We hope this letter is responsive to your comment and request for information. The Company’s goal is to address the comment in a manner that is acceptable to the SEC staff.

For your convenience, our response is prefaced by the SEC’s comment.

Form 8-K filed May 10, 2017

In future filings, please remove the description “non-routine” from any non-GAAP adjustment that has occurred in the prior two years or is reasonably likely to recur within the next two years. Please refer to Question 102.03 of the updated Non-GAAP Compliance and Disclosure Interpretations issued on May 17, 2016.

Team Response:

We acknowledge the staff’s comment and in future filings we will remove the description “non-routine” from any non-GAAP adjustment that has occurred in the prior two years or is reasonably likely to recur within the next two years as noted in Question 102.03 of the updated Non-GAAP Compliance and Disclosure Interpretations issued on May 17, 2016.

* * * *

Page 1 of 2

We would be pleased to address any further comments that the Commission has with respect to our filings.

Very truly yours,

/s/ Greg L. Boane

Greg L. Boane

Executive Vice President and Chief Financial Officer

Page 2 of 2