SEC Comment Letter 0000000000-24-001827 to JONES LANG LASALLE INC (JLL) (CIK 0001037976) (JLL)
JONES LANG LASALLE INC (JLL) (CIK 0001037976)
Date: Feb. 15, 2024 · CIK: 0001037976 · Accession: 0000000000-24-001827
AI Filing Summary & Sentiment
File numbers found in text: 001-13145
Referenced dates: December 8, 2023
Letter
United States securities and exchange commission logo February 15, 2024 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 December 8, 2023 File No. 001-13145 Dear Karen Brennan: We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s). 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 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 reviewed your letter dated December 8, 2023. Please remove the adjustment for Gross contract costs from your non-GAAP measures Fee revenue and Fee-based operating expenses. Refer to Regulation G and, for additional guidance, Questions 100.01 and 100.04 of the Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.
FirstName LastNameKaren Brennan Comapany NameJones Lang LaSalle Inc. February 15, 2024 Page 2 FirstName LastName Karen Brennan Jones Lang LaSalle Inc. February 15, 2024 Page 2
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 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
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United States securities and exchange commission logo
February 15, 2024
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 December 8, 2023
File No. 001-13145
Dear Karen Brennan:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
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 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 reviewed your letter dated December 8, 2023. Please remove the adjustment for
Gross contract costs from your non-GAAP measures Fee revenue and Fee-based operating
expenses. Refer to Regulation G and, for additional guidance, Questions 100.01 and
100.04 of the Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures.
FirstName LastNameKaren Brennan
Comapany NameJones Lang LaSalle Inc.
February 15, 2024 Page 2
FirstName LastName
Karen Brennan
Jones Lang LaSalle Inc.
February 15, 2024
Page 2
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 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