JONES LANG LASALLE INC

On April 28, 2023, we received a comment letter from the staff (the “Staff”) of the SEC’s Division of Corporation Finance related to our Annual Report on Form 10-K for the fiscal year ended December 31, 2022. Following our written response to the Staff, we received an additional letter on June 6, 2023. In this follow-up letter, the Staff requested additional information related to our non-GAAP measure "Fee revenue" and the appropriateness of components of "Gross contract costs," our deduction from Revenue to calculate Fee revenue. Subsequent to the June 6, 2023 letter, we had telephonic conversations with the Staff and provided additional written responses. On February 15, 2024, we received an additional letter from the Staff informing us of their objection to our “Fee revenue” and “Fee-based operating expenses” non-GAAP measures, citing questions 100.04 and 100.01 of the SEC Staff’s non-GAAP Compliance & Disclosure Interpretations as it relates to our historical non-GAAP adjustment of Gross contract costs. As such, effective with our first-quarter 2024 reporting cycle, we will remove all references to both measures. We are currently reviewing options for revised presentation of our non-GAAP disclosures.