SEC Comment Letter 0000000000-23-004359 to JONES LANG LASALLE INC (JLL) (CIK 0001037976) (JLL)
JONES LANG LASALLE INC (JLL) (CIK 0001037976)
Date: April 28, 2023 · CIK: 0001037976 · Accession: 0000000000-23-004359
AI Filing Summary & Sentiment
File numbers found in text: 001-13145
Letter
United States securities and exchange commission logo April 28, 2023 Karen Brennan Chief Financial Officer Jones Lang LaSalle Inc. 200 East Randolph Drive Chicago, IL 60601 Re:Jones Lang LaSalle Inc. Form 10-K for the year ended December 31, 2022 Filed February 28, 2023 File No. 001-13145 Dear Karen Brennan: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the year ended December 31, 2022 Item 8 Financial Statements and Supplementary Data Revenue Recognition Work Dynamics, page 82 1.We note your disclosure that pricing for workplace management contracts typically includes a management fee and, in many instances, an incentive fee or other form of variable consideration. We further note that you generally act as principal for workplace management contracts with respect to third-party vendors and subcontractors engaged to deliver operational services to your clients' facilities. Please provide us with more information regarding the structure of your workplace management contracts, including the terms of any fees earned by you under the contracts. In your response, please tell us whether the terms of your contracts specifically require the customer to reimburse you for amounts paid to third-party vendors and subcontractors and include an example of the contract terms in your response.
FirstName LastNameKaren Brennan Comapany NameJones Lang LaSalle Inc. April 28, 2023 Page 2 FirstName LastName Karen Brennan Jones Lang LaSalle Inc. April 28, 2023 Page 2 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. You may contact Paul Cline at 202-551-3851 or Robert Telewicz at 202-551-3438 if you have questions regarding our comment. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
April 28, 2023
Karen Brennan
Chief Financial Officer
Jones Lang LaSalle Inc.
200 East Randolph Drive
Chicago, IL 60601
Re:Jones Lang LaSalle Inc.
Form 10-K for the year ended December 31, 2022
Filed February 28, 2023
File No. 001-13145
Dear Karen Brennan:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the year ended December 31, 2022
Item 8 Financial Statements and Supplementary Data
Revenue Recognition
Work Dynamics, page 82
1.We note your disclosure that pricing for workplace management contracts typically
includes a management fee and, in many instances, an incentive fee or other form of
variable consideration. We further note that you generally act as principal for workplace
management contracts with respect to third-party vendors and subcontractors engaged to
deliver operational services to your clients' facilities. Please provide us with more
information regarding the structure of your workplace management contracts, including
the terms of any fees earned by you under the contracts. In your response, please tell us
whether the terms of your contracts specifically require the customer to reimburse you for
amounts paid to third-party vendors and subcontractors and include an example of the
contract terms in your response.
FirstName LastNameKaren Brennan
Comapany NameJones Lang LaSalle Inc.
April 28, 2023 Page 2
FirstName LastName
Karen Brennan
Jones Lang LaSalle Inc.
April 28, 2023
Page 2
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.
You may contact Paul Cline at 202-551-3851 or Robert Telewicz at 202-551-3438 if you
have questions regarding our comment.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction