Please wait

February 22, 2024

Via EDGAR

Mr. Paul Cline

Mr. Robert Telewicz

Office of Real Estate & Construction

Division of Corporation Finance

U.S. Securities and Exchange Commission

Re:     Jones Lang LaSalle Incorporated

Form 10-K for the year ended December 31, 2022

File No. 001-13145

Dear Mr. Cline and Mr. Telewicz:

We are in receipt of your comment letter dated February 15, 2024, regarding Jones Lang LaSalle Incorporated’s (the “Company”) Form 10-K for the year ended December 31, 2022.

For your convenience, we have restated the comment received from the staff of the U.S. Securities and Exchange Commission (the “Staff”) in italics, followed by our response:

Form 10-K for the year ended December 31, 2022

Item 8. Financial Statements and Supplemental Data

Revenue Recognition

Work Dynamics, page 82

1.We have reviewed your letter dated December 8, 2023. Please remove the adjustment for Gross contract costs from your non-GAAP measures Fee revenue and Fee-based operating expenses. Refer to Regulation G and, for additional guidance, Questions 100.01 and 100.04 of the Compliance & Disclosure Interpretations of Non-GAAP Financial Measures.

Response

The Company acknowledges the Staff’s comment and advises the Staff that the Company will remove the adjustment for Gross contract costs from our non-GAAP measures related to Fee revenue and Fee-based operating expenses. The requested revisions will be reflected in our future filings, commencing with our first quarter 2024 reporting, with the United States Securities and Exchange Commission.

Sincerely,

/s/ Karen Brennan

Karen Brennan

Chief Financial Officer

Jones Lang LaSalle Incorporated