SecProbe.io

CORRESP
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    56 Top Gallant Road

P.O. Box 10212

Stamford, CT 06904-2212

    Telephone  +1-203-316-1111

Facsimile    +1-203-316-6300

gartner.com

June 3, 2013

United States Securities & Exchange Commission

Division of Corporation Finance, 100 F. Street, N.E.

Washington, DC 20549-7010

Attention: Kevin Woody

Accounting Branch Chief

    Re:
    Gartner, Inc.

    Form 10-K for the fiscal year ended December 31, 2012

    Filed on February 22, 2013

    File No. 001-14443

Ladies and Gentlemen:

Gartner, Inc. (the “Company”
or “Gartner” or “we”) submits this letter in response to comments from the Staff of the Securities and
Exchange Committee received by letter dated May 22, 2013, relating to the Company’s Form 10-K for the fiscal year ended December
31, 2012, which was filed on February 22, 2013.

In this letter, we have
recited the comment from the Staff in italicized, bold type and have followed the comment with the Company’s response. Capitalized
terms used but not defined herein shall have the meanings ascribed to them in the Company’s Form 10-K.

FORM 10-K FOR THE FISCAL YEAR ENDED DECEMBER 31, 2012

Note 1. Business and Significant Accounting Policies

Stamford headquarters lease renewal, page 42

    1.
    In regards to your $25 million tenant improvement allowance, please tell us management’s basis for recording the cash reimbursements from your landlord in operating cash flows yet the corresponding outflows are recorded within investing activities.

Response:

The Company’s cash flow classification
of the landlord cash reimbursements and the corresponding outflows was based on published U.S. GAAP as well as SEC Staff guidance:

US GAAP

The justification for the classification
of the landlord cash reimbursements as an operating cash flow was based on the following guidance provided by the Financial Accounting
Standards Board Accounting Standards Codification (“ASC”), along with our interpretation:

 — ASC Topic 840-20-25-5, which requires that such incentives be reported as a reduction of rent expense
for P&L reporting. We believe that reporting the cash reimbursements as an operating cash flow is conceptually consistent with
this GAAP requirement.

 — ASC Topic 230-10-45-16(c), which requires that refunds from suppliers to be reported as an operating
cash flow. Again, we believe that reporting the cash reimbursements as an operating cash flow is consistent with this GAAP requirement.

The Company’s justification for reporting
the cash outflows for the leasehold improvements within the investing activities section of the cash flow statement is based on
ASC Topic 230-10-45-13(c), which states that cash paid to purchase property, plant, and equipment and other similar productive
assets should be classified in the cash flow statement as an investing cash outflow.

SEC Staff Guidance

We also would bring the Staff’s attention
to an interpretive letter provided by the Office of the Chief Accountant. In that letter, dated February 7, 2005, Mr. Donald T.
Nicolaisen, then the Chief Accountant of the SEC Office of the Chief Accountant, provided certain guidance for public registrants
for leasehold improvements made by a lessee that were funded by landlord incentives under an operating lease arrangement.

Specifically, on page 2 of that letter,
the Office of the Chief Accountant provided the following view of the accounting for leasehold improvements funded by the landlord:
…“(c) a registrant’s statement of cash flows should reflect cash received from the lessor that is accounted
for as a lease incentive within operating activities and the acquisition of leasehold improvements for cash within investing activities.”
(italics added)

In conclusion, the Company based its cash
flow presentation on established U.S. GAAP and interpretive guidance provided by the Office of the Chief Accountant.

Note 14 – Segment Information, pages 59 –
60

    2.
    We note you present gross contribution as a segment performance measure and gross contribution is defined as operating income excluding certain COS and SG&A expenses, depreciation, acquisition and integration charges, and amortization of intangibles. Please provide us and revise future periodic filings to include a reconciliation of gross contribution to net income and separately identify and

    describe significant reconciling items. Reference is made to paragraphs 280-10-50-30(b) and 31 of the Accounting Standards Codification.

Response:

In response to the Staff’s comment,
the Company has provided a reconciliation of the gross contribution to net income, along with the identification and description
of significant reconciling items, for the fiscal years ended December 31, 2012, 2011, and 2010. The reconciliation is attached
to this letter as Attachment 1.

In addition, the Company
will, in future filings, provide a reconciliation of gross contribution to net income and separately identify and describe significant
reconciling items in accordance with ASC Topic 280-10-50-30(b) and 31.

***

In connection with its
responses, the Company acknowledges that it is responsible for the adequacy and accuracy of the disclosure in its filings; that
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with
respect to the filings; and that 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.

Please direct any comments
or questions regarding the Company’s responses to the attention of the undersigned at (203) 316-6876. In addition, we respectfully
request that you provide any additional comments to me at christopher.lafond@gartner.com, and to my staff, Stephen Baranowski,
email address stephen.baranowski@gartner.com, and Clare Kretzman, email address clare.kretzman@gartner.com.

Thank you for your assistance.

    Sincerely,

    /s/ Christopher J. Lafond

    Christopher J. Lafond

    Executive Vice President

    Chief Financial Officer

    cc:
    Mr. Wilson K. Lee

    Division of Corporation Finance

ATTACHMENT 1

GARTNER, INC.

Reconciliation of Total Segment Gross Contribution
to Net Income

(In thousands)

    For the Twelve Months

    Ended December 31,

    2012
    2011
    2010

    Total segment gross contribution
    $ 963,714
    $ 863,239
    $ 742,296

    Costs and expenses:

    Cost of services and product development - unallocated
      6,973   (a)
      3,406   (a)
      6,080
    (a)

    Selling, general and administrative
      678,843
      613,707
      543,174

    Depreciation
      25,369
      25,539
      25,349

    Amortization of intangibles
      4,402
      6,525
      10,525

    Acqusition and integration charges
      2,420
      —
      7,903

    Operating income
      245,707
      214,062
      149,265

    Interest expense, net
      8,859
      9,967
      15,616

    Other expense (income), net
      1,252
      1,911
      (436 )

    Provision for income taxes
      69,693
      65,282
      37,800

    Net income
    $ 165,903
    $ 136,902
    $ 96,285

(a) Consists of certain bonus and related fringe costs recorded
in Consolidated Cost of services and product development expense that are not allocated to segment expense. The Company's policy
is to only allocate bonus and related fringe charges to segments for up to 100% of the segment employee's target bonus.