SEC Company Response from Cushman & Wakefield Ltd. (CWK) (CIK 0001628369) (CWK) — Feb 26, 2020
Cushman & Wakefield Ltd. (CWK) (CIK 0001628369)
Date: Feb. 26, 2020 · CIK: 0001628369 · Accession: 0001193125-20-050434
AI Filing Summary & Sentiment
Letter
Ryan Lawrence
Deputy General Counsel
225 West Wacker, Suite 3000
Chicago, IL 60606
Main +1 312 470 1800
ryan.lawrence@cushwake.com
cushmanwakefield.com
February 26, 2020
Via EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate & Construction
100 F Street, N.E.
Washington, D.C. 20549
Attn: Jennifer Monick
Jeffrey Lewis
Re: Cushman & Wakefield plc
Ladies and Gentlemen:
This letter is being submitted by Cushman & Wakefield plc (the “Company”) following additional telephonic conversations with the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to the Staff’s review of the Company’s Annual Report on Form 10-K for the year ended December 31, 2018 (the “Form 10-K”).
The Company acknowledges the Staff’s verbally-issued comment relating to the disclosure and presentation set forth in the section captioned “Management’s Discussion and Analysis of Financial Condition and Results of Operations” (the “MD&A”) and undertakes to enhance its MD&A disclosure in future filings with the Commission in a manner consistent with its discussions with the Staff.
* * * * *
Securities and Exchange Commission
February 26, 2020
Page
Should you have any questions relating to any of the foregoing, please feel free to contact the undersigned at (312) 424-8285 or Robert M. Hayward of Kirkland & Ellis LLP, counsel to the Company, at (312) 862-2133.
Thank you for your assistance in this matter.
Sincerely,
/s/ Ryan Lawrence
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CORRESP
Ryan Lawrence
Deputy General Counsel
225 West Wacker, Suite 3000
Chicago, IL 60606
Main +1 312 470 1800
ryan.lawrence@cushwake.com
cushmanwakefield.com
February 26, 2020
Via EDGAR
U.S. Securities and Exchange
Commission
Division of Corporation Finance
Office of Real
Estate & Construction
100 F Street, N.E.
Washington, D.C. 20549
Attn:
Jennifer Monick
Jeffrey Lewis
Re:
Cushman & Wakefield plc
Ladies and Gentlemen:
This letter is being
submitted by Cushman & Wakefield plc (the “Company”) following additional telephonic conversations with the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
relating to the Staff’s review of the Company’s Annual Report on Form 10-K for the year ended December 31, 2018 (the “Form 10-K”).
The Company acknowledges the Staff’s verbally-issued comment relating to the disclosure and presentation set forth in the section
captioned “Management’s Discussion and Analysis of Financial Condition and Results of Operations” (the “MD&A”) and undertakes to enhance its MD&A disclosure in future filings with the Commission in a manner
consistent with its discussions with the Staff.
* * * * *
Securities and Exchange Commission
February 26, 2020
Page
2
Should you have any questions relating to any of the foregoing, please feel free to contact
the undersigned at (312) 424-8285 or Robert M. Hayward of Kirkland & Ellis LLP, counsel to the Company, at (312) 862-2133.
Thank you for your assistance in this matter.
Sincerely,
/s/ Ryan Lawrence
Ryan Lawrence
Deputy General Counsel
Enclosure
cc:
Robert M. Hayward
Kirkland & Ellis LLP