May 21, 2025

Craig Safian
Executive Vice President and Chief Financial Officer
Gartner, Inc.
P.O. Box 10212
56 Top Gallant Road
Stamford, Connecticut 06902

       Re: Gartner, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2024
           Form 8-K Dated May 6, 2025
           File No. 001-14443
Dear Craig Safian:

       We have reviewed your filing and have the following comments.

       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 Fiscal Year Ended December 31, 2024
Notes to Consolidated Financial Statements
Note 16 - Segment Information, page 73

1.     Please tell us how your disclosure complies with the requirement to
disclose how the
       chief operating decision maker uses your reported measure of segment
profit or loss in
       assessing segment performance and deciding how to allocate resources
pursuant to
       ASC 280-10-50-29.f. Refer to ASC 280-10-55-47.bb for guidance.
Form 8-K Dated May 6, 2025
Exhibit 99.1, page 6

2.     We note that you adjust GAAP diluted EPS for the impact of amortization
of acquired
       intangibles in calculating Adjusted EPS to arrive at a measure that
excludes items that
       may not be indicative of your core operating results. It is unclear why
you exclude
       amortization of assets acquired through acquisitions considering this
measure includes
       revenue from operations being generated in part by these acquired
assets. Please
 May 21, 2025
Page 2

       expand your disclosure to more fully explain the adjustment and to
clarify that
       although amortization of these acquired intangibles is being excluded,
revenue
       generated from these assets is still included in the measure and that
these assets
       contribute to revenue generation.
        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 Abe Friedman at 202-551-8298 or Theresa Brillant at
202-551-3307 if
you have questions regarding comments on the financial statements and related
matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services