February 18, 2025

Marc Vandiepenbeeck
Chief Financial Officer
Johnson Controls International plc
One Albert Quay
Cork, Ireland T12 X8N6
T12 X8N6

        Re: Johnson Controls International plc
            Form 10-K for the Fiscal Year Ended September 30, 2024
            Form 8-K furnished on November 6, 2024
            File No. 001-13836
Dear Marc Vandiepenbeeck:

       We have limited our review of your filings to the financial statements
and related
disclosures 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 the Fiscal Year Ended September 30, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Segment Analysis, page 38

1.     As previously requested in comment 2 of our letter dated January 25,
2024, please
       revise to remove the non-GAAP measure total segment EBITA from your
periodic
       filings. Please refer to your response letter dated February 16, 2024
where you
       indicated that you would not present this measure in future filings.
Liquidity and Capital Resources
Working Capital, page 40

2.     In your response letter dated February 16, 2024, you stated you would
revise future
       filings to only include a calculation of working capital as defined in
the FASB
       Codification Master Glossary, however, we note your disclosure of
working capital is
       not consistent with the cited definition and is therefore a non-GAAP
measure. Please
 February 18, 2025
Page 2

       tell us how your presentation complies with Item 10(e)(1)(ii)(A) of
Regulation S-K
       which prohibits excluding charges or liabilities that required or will
require cash
       settlement from non-GAAP liquidity measures or revise your disclose
accordingly.
Form 8-K furnished on November 6, 2024
Cash Flow, Free Cash Flow and Free Cash Flow Conversion, page 17

3.     You present the measures free cash flow and adjusted free cash flow
conversion
       without presenting the most directly comparable GAAP measure of
operating cash
       flow conversion with equal or greater prominence. Please revise. Refer
to Item
       10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the Non-GAAP
C&DIs.
Statements of Income , page 23

4.     We note your presentation of Combined results here and on page 24 which
combine
       the results of continuing and discontinued operations. We also note your
references to
       revenue throughout the filing, including the tables on page 14 and 15
are that of
       combined revenue and not of GAAP revenue. As the R&LC HVAC business is
       classified as a discontinued operation and therefore the historical
financial results are
       reflected as a discontinued operation in all periods presented, the
combined results
       presented in your Form 8-K have the effect of changing the principles
required to be
       applied in accordance with GAAP and would be considered individually
       tailored. Please revise in future filings to remove these presentations.
Refer to
       Question 100.04 of the Non-GAAP C&DIs.
        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 Megan Masterson at 202-551-3407 or Christine Dietz at
202-551-3408
with any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Technology
cc:   John Donofrio