SecProbe.io

July 30, 2014

Via E-mail
Mr. Craig W.  Safian
Chief Financial  Officer
Gartner, Inc.
P.O. Box 10212
56 Top Gallant Road
Stamford, CT 06902

Re: Gartner, Inc.
 Form 10-K for year ended December 31, 201 3
Filed on February 26, 2014
File No. 001-14443

Dear Mr. Safian :

We have reviewed your filing an d have the following comment s.  We have limited our
review to only your financial statements and related disclosures and do not intend to expand our
review to other portions of your document.  In our comment s, we may ask you to provide us with
information so we may better understand your  disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comment s apply to your facts an d circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comment s, we may have  additional comments.

Form 10 -K for the year ended December 31, 2013

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 15

Obligations and Commitments, page 28

Contractual Cash Commitments, page 29

1. It appears that the amounts  for your Deferred compensation arrangement relates to your
supplemental deferred compensation plan, which is structured as a rabbi trust.  Please tell
us how you determined it was not necessary to disclose the cash requirements for your
defined ben efit pe nsion plans.  Please refer to footnote 46 in our Release 33 -8350.

Mr. Craig W. Safian
Gartner, Inc.
July 30, 2014
Page 2

 Financial Statements

Notes to Consolidated Financial Statements, page 44

8 – Stock -based Compensation, page 54

Restricted Stock Units, page 56

2. Please tell us how you determined it is appropriate to expense your performance -based
RSUs on an accelerated basis.  Please refer to ASC 718.

12 – Fair Value Disclosures, page 62

3. We note your table on page 63.  In future periodic filings, please disagg regate your fair
value information by level 1, 2 or 3 within your table.  Please refer to paragraphs 2 and 8
of ASC 820 -10-50.

Form 10 -Q for the quarterly period ended March 31, 2014

Financial Statements

Notes to  Condensed  Consolidat ed Financial State ments, page 7

Note 1 – Business and Basis of Presentation, page 7

Acquisition, page 8

4. Please tell us how you have accounted for the possible payment of $31.9 million related
to the acquisition of Software Advice.  Within your response, please tell us th e nature of
the certain employment conditions to be achieved.  Additionally, please tell us if you
concluded that this payment is compensation or contingent consideration and how you
made that determination.  Please refer to paragraphs 24 -25 of ASC 805 -10-55.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Mr. Craig W. Safian
Gartner, Inc.
July 30, 2014
Page 3

  In responding to our comment s, please provide  a written statement from the company
acknowledging 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.

You may contact Jennifer Monick,  Senior Staff Accountant, at 202 -551-3295  or the
undersigned at 202-551-3629 if you have questions.

Sincerely,

 /s/ Kevin Woody

Kevin Woody
Branch Chief