SecProbe.io

United States securities and exchange commission logo
June 6, 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
Response dated May 11, 2023
File No. 001-13145
Dear Karen Brennan:
            We have reviewed your response dated May 11, 2023 and have the following comment.
            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 Supplemental Data
Revenue Recognition
Work Dynamics, page 82
1.We have considered your response to our prior comment.   In your response to our
comment you state that management fees are typically structured as a fixed monthly price
for an agreed-upon scope of work or a contractual mark-up to third party and contractor
spend that you manage.  Based on your response, it appears that your fee includes a mark-
up on reimbursed costs both when the fee is inclusive of or distinct from the costs of
providing the services. Given the terms of your contracts, please explain to us why you
believe it is appropriate to adjust revenues for the reimbursed gross contract revenues in
arriving at the non-GAAP fee based revenue measure and to adjust operating expenses for
gross contract expenses in arriving at the non-GAAP fee-based operating expenses
measure, which are disclosed on page 49.  In your response, please expand on why you
believe the non-GAAP measures are useful to investors despite the fact that fees earned
may be based on managed third-party or contractor spend.  Please also include

 FirstName LastNameKaren Brennan
 Comapany NameJones Lang LaSalle Inc.
 June 6, 2023 Page 2
 FirstName LastName
Karen Brennan
Jones Lang LaSalle Inc.
June 6, 2023
Page 2
an explanation of how you considered Question 100.04 of the Compliance & Disclosure
Interpretations on Non-GAAP Financial Measures in determining the appropriateness of
these adjustments.
            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.
            You may contact Paul Cline at 202-551-3851 or Robert Telewicz at 202-551-3438 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction