SEC Comment Letter for GARTNER INC (IT) (CIK 0000749251) (IT) — Jan 15, 2008
GARTNER INC (IT) (CIK 0000749251)
Date: Jan. 15, 2008 · CIK: 0000749251 · Accession: 0000000000-08-002577
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4561 January 15, 2008 Mr. Christopher Lafond Chief Financial Officer Gartner, Inc. 56 Top Gallant Road, P.O. Box 10212 Stamford, CT 06902-7700
Re: Gartner, Inc. Form 10-K for the fiscal year ended December 31, 2006 File No. 1-14443
Dear Mr. Lafond:
We have reviewed your first response letter filed on December 19, 2007 and have the following additional comment. Where indicated, we think you should revise your document in response to this comment in future filings. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as nece ssary in your explanation. In our comment, we may ask you to provide us with supplemental inform ation so we may better understand your disclosure. After reviewing this inform ation, we may or may not raise additional comments.
Form 10-K for the fiscal year ended December 31, 2006
Financial Statements
Stock-based Compensation
Restricted Stock Units, page 52 1. We note your response to prior comment 3. Please provide additional information regarding your compliance with SFAS 123(R). Based upon your response it is not clear how you are currently recognizi ng the expense for these RSUs and how your current program is similar to the one discussed in paragraph A69. Within
Mr. Lafond Gartner, Inc. January 15, 2008 Page
your response, please specifi cally tell how you are r ecognizing expense, the specific provisions of the plan and how you have complied with SFAS 123(R). Additionally, please tell us what effect, if any, the a dditional RSUs issued above the target at the end of the first performance peri od has on the recognition of expense.
As appropriate, please respond to our comm ent within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your proposed revisions that keys your response to our comment and provides any requested information. Detailed cover letters greatly facilitate our review. Please submit your cover letter on EDGAR. Pleas e understand that we may ha ve additional comments after reviewing your response to our comment. You may contact Howard Efron, Staff Accountant, at (202) 551-3439 or me at (202) 551-3629 if you have questions regard ing comments on the financial statements and related matters. S i n c e r e l y ,
Kevin Woody Branch Chief
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Mail Stop 4561 January 15, 2008 Mr. Christopher Lafond Chief Financial Officer Gartner, Inc. 56 Top Gallant Road, P.O. Box 10212 Stamford, CT 06902-7700 Re: Gartner, Inc. Form 10-K for the fiscal year ended December 31, 2006 File No. 1-14443 Dear Mr. Lafond: We have reviewed your first response letter filed on December 19, 2007 and have the following additional comment. Where indicated, we think you should revise your document in response to this comment in future filings. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as nece ssary in your explanation. In our comment, we may ask you to provide us with supplemental inform ation so we may better understand your disclosure. After reviewing this inform ation, we may or may not raise additional comments. Form 10-K for the fiscal year ended December 31, 2006 Financial Statements Stock-based Compensation Restricted Stock Units, page 52 1. We note your response to prior comment 3. Please provide additional information regarding your compliance with SFAS 123(R). Based upon your response it is not clear how you are currently recognizi ng the expense for these RSUs and how your current program is similar to the one discussed in paragraph A69. Within Mr. Lafond Gartner, Inc. January 15, 2008 Page 2 your response, please specifi cally tell how you are r ecognizing expense, the specific provisions of the plan and how you have complied with SFAS 123(R). Additionally, please tell us what effect, if any, the a dditional RSUs issued above the target at the end of the first performance peri od has on the recognition of expense. As appropriate, please respond to our comm ent within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your proposed revisions that keys your response to our comment and provides any requested information. Detailed cover letters greatly facilitate our review. Please submit your cover letter on EDGAR. Pleas e understand that we may ha ve additional comments after reviewing your response to our comment. You may contact Howard Efron, Staff Accountant, at (202) 551-3439 or me at (202) 551-3629 if you have questions regard ing comments on the financial statements and related matters. S i n c e r e l y , Kevin Woody Branch Chief