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United States securities and exchange commission logo
July 5, 2023
Craig W. Safian
Chief Financial Officer
Gartner, Inc.
P.O. Box 10212
56 Top Gallant Road
Stamford, Connecticut 06902-7700
Re: Gartner, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2022
Filed February 16,
2023
File No. 001-14443
Dear Craig W. Safian:
We have reviewed your May 12, 2023 response to our comment letter
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. Unless we note otherwise, our references to prior comments are
to comments in our
April 18, 2023 letter.
Form 10-K for Fiscal Year Ended December 31, 2022
Controls and Procedures
Disclosure Controls and Procedures, page 31
1. We note the revised
disclosure in your response to comment 1 and in the Form 10-Q for
the fiscal quarter
ended March 31, 2023. However, the conclusion language still refers to
only a portion of the
definition of disclosure controls and procedures. This gives the
appearance your
conclusion applies only to this portion and leaves open your conclusion
with respect to the
remainder of the definition. Your conclusion does not need to recite
the full definition as
long as it refers to the definition as defined by Exchange Act Rules
13a-15(e) and
15d-15(e). Please revise your conclusion as appropriate. If your
conclusion is limited
to only the portion of the definition stated, please advise.
Craig W. Safian
Gartner, Inc.
July 5, 2023
Page 2
Notes to Consolidated Financial Statements
Note 12 - Income Taxes, page 66
2. Refer to your response to comment 2. You say the $122.9 million
deferred tax asset for
the tax basis in intangible assets is recorded in the line titled
"Intangible Assets" in the
applicable table. Please reconcile this amount with the $35.8 million
amount presented in
that line for 2022. If the deferred tax asset and offsetting valuation
allowance were netted
in this line, please present each component separately in the table as
appropriate. Refer to
ASC 740-10-50-6. In connection with this, if these two amounts also
were netted in the
statutory tax rate reconciliation table, there does not appear to be a
basis to do this in this
table pursuant to Rule 4-08(h)(2) of Regulation S-X. Accordingly,
present each
component separately in this table as appropriate.
You may contact Aamira Chaudhry at 202-551-3389 or Doug Jones at
202-551-3309 if
you have questions regarding comments on the financial statements and related
matters.
FirstName LastNameCraig W. Safian Sincerely,
Comapany NameGartner, Inc.
Division of
Corporation Finance
July 5, 2023 Page 2 Office of
Trade & Services
FirstName LastName