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May 13, 2024
Joseph Brinkman
Vice President and Chief Financial Officer
Chart Industries, Inc.
220 Airport Industrial Drive
Suite 100
Ball Ground, GA 30107
Re:Chart Industries, Inc.
Form 10-K for Fiscal Year December 31, 2023
Form 8-K Filed February 28, 2024
File No. 001-11442
Dear Joseph Brinkman:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 8-K filed on February 28, 2024
Exhibit 99.1
Reconciliation of Earnings Per Common Share Attributable to Chart Industries, Inc. - Continuing
Operations..., page 16
1.Please address the following related to your reconciliation on page 16:
•Your non-GAAP measure, adjusted earnings per common share attributable to Chart
Industries, Inc. is reconciled to Income/Loss from Continuing Operations which does
not appear to be the most directly comparable GAAP measure.  Revise your
reconciliation to begin with Net Income/Loss Attributable to Chart Industries.
Alternatively, if the non GAAP measure is intended to relate to continuing
operations, please label it as such.
•Tell us why you are adjusting for the mandatorily redeemable preferred stock
dividend and explain how you calculated this adjustment.
•Finally, we note you have included several adjustments which do not have footnote

 FirstName LastNameJoseph Brinkman
 Comapany NameChart Industries, Inc.
 May 13, 2024 Page 2
 FirstName LastNameJoseph Brinkman
Chart Industries, Inc.
May 13, 2024
Page 2
disclosure describing the adjustment and how the adjustment was quantified.  Explain
the adjustments to us and revise future filings to include this disclosure.  For
adjustments that include multiple elements, explain and quantify each element
included in the adjustment.  This comment also applies to adjustments on
reconciliations included on pages 17-23.
Reconciliation of Net Cash Provided By (Used In) Operating Activities to Free Cash Flow and
Adjusted Free Cash Flow, page 17
2.We note that you provide a reconciliation of free cash flow (non-GAAP) and adjusted free
cash flow (non-GAAP). In future filings, please revise your free cash flow and adjusted
free cash flow titles to specifically identify whether it relates to continuing operations or
discontinued operations.
Reconciliation of Gross Profit to Adjusted Gross Profit..., page 18
3.Please revise future filings to present the most directly comparable measures prior to the
non-GAAP measures in accordance with Item 10(e)(1)(i)(A) to prevent undue
prominence.  In this regard, we note you have not included Gross Margin or Operating
Margin in the tables included on pages 18-21.  Additionally, on page 23 you should
disclose Net Income as a percent of sales alongside Adjusted EBITDA as a percent of
sales.
4.On pages 22 and 23, your presentation of Chart Industries, continuing operations pro
forma appears to be a non-GAAP measure, as such, in future filings, please provide
disclosures and presentation to comply with Article 11 of Regulation S-X and Question
100.05 of the Compliance and Disclosure Interpretations on Non-GAAP Financial
Measures.
Exhibit 99.2, page 32
5.As it appears you have furnished the supplemental information included in Exhibit 99.2
under Item 2.02 of Form 8-K, please note that Item 10(e)(1)(i) of Regulation S-K applies
to all disclosures of non-GAAP measures.  In this regard,  please also address the
following in future filings:
•We note that you have provided non-GAAP measures without disclosure of
and reconciliation to the most directly comparable GAAP measure.  Revise to comply
with Item 10 of Regulation S-K and the Compliance and Disclosure Interpretations
on Non-GAAP Measures.
•On page 32, your "Fourth Quarter 2023 Net Income & EBITDA Bridge" appears
to present a full non-GAAP income statement . Revise to eliminate this presentation
so as not to attach undue prominence to this non-GAAP information.  Refer
to Question 102.10(c) of the Non-GAAP Compliance and Disclosure Interpretations
for guidance.
•On pages 32 and 35, your presentation of EBITDA includes loss on debt

 FirstName LastNameJoseph Brinkman
 Comapany NameChart Industries, Inc.
 May 13, 2024 Page 3
 FirstName LastName
Joseph Brinkman
Chart Industries, Inc.
May 13, 2024
Page 3
extinguishment. We remind you that to the extent your calculation of  EBITDA
includes any item in addition to what the acronym suggests (e.g., loss on debt
extinguishment), you should revise the title of the measure or remove that item from
your calculation of EBITDA. Refer to Question 103.01 of the Compliance
& Disclosures Interpretations on Non-GAAP Financial Measures.

            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Mindy Hooker at 202-551-3732 or Ernest Greene at 202-551-3733 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing