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May 3, 2022
Katie Rooney
Chief Financial Officer
Alight, Inc.
4 Overlook Point
Lincolnshire, IL 60069
Re:Alight, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed March 10, 2022
Form 8-K Furnished February 23, 2022
File No. 001-39299
Dear Ms. Rooney:
            We have limited our review of your filings to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Review of Results
Non-GAAP Financial Measures, page 33
1.Please revise to move this disclosure to follow your discussion and analysis of results of
operations on a GAAP basis.
Adjusted EBITDA and Adjusted EBITDA less Capital Expenditures, page 34
2.For the non-GAAP financial measure Adjusted EBITDA less Capital Expenditures, please
address the following:
•Please revise the title of Adjusted EBITDA less Capital Expenditures to better
describe the nature of this non-GAAP financial measure.  In this regard, we note that
its reconciliation to the most directly comparable GAAP measure starts with cash

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Alight, Inc.
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provided by operating activities rather than net (loss)/income.  In addition, you
defined free cash flow as Adjusted EBITDA less capital expenditures and used these
terms interchangeably in your fiscal year end earnings release (Exhibit 99.1 to Form
8-K filed on February 14, 2022).
•As you define free cash flow as Adjusted EBITDA less capital expenditures in your
earnings release, please tell us how you considered Item 10(e)(1)(ii) of Regulation S-
X.  In this regard, certain adjustments to arrive at the non-GAAP financial measure
appear to be charges that required cash settlement (e.g. transaction and integration
expenses, non-recurring professional expenses, transformation initiatives, etc.).
Segment Revenue and Adjusted EBITDA, page 39
3.Please revise to include a discussion and analysis of all material costs and expenses
attributable to your reportable segments that are not included in computing the segment
measure of adjusted EBITDA, for example, depreciation and amortization.  Refer to
104.02 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations
for further guidance.
Notes to Consolidated Financial Statements
10. Share-Based Compensation Expense, page F-31
4.Please revise to disclose all information required under ASC 718-10-50-2 (e.g. general
terms of awards, methods utilized to measure compensation cost, a description of the
significant assumptions used to estimate the fair value, aggregate intrinsic value of RSUs
and PRSUs, etc.).
Item 9A. Controls and Procedures
Internal Control over Financial Reporting, page F-45
5.Please revise to include the internal control over financial reporting language in the
introductory portion of paragraph 4 of the Section 302 certification, as well as paragraph
4(b).  Refer to Section 215.02 of the Regulation S-K Compliance & Disclosure
Interpretations.
Form 8-K Furnished February 23, 2022
Exhibit 99.1
6.Throughout your press release, you present non-GAAP financial measures to describe
performance while their respective most directly comparable GAAP measures were
omitted. Please revise to present the most directly comparable GAAP measures with equal
or greater prominence. Refer to Item 10(e)(i)(a) of Regulation S-K and Question 102.10 of
the Non-GAAP Compliance and Disclosure Interpretations.
            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

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 Comapany NameAlight, Inc.
 May 3, 2022 Page 3
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Katie Rooney
Alight, Inc.
May 3, 2022
Page 3
absence of action by the staff.
            You may contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services