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Please reconcile the non-GAAP liquidity measure, gross cash flow, on page 6 of your Annual Report to Shareholders to the most comparable GAAP liquidity measure, net cash provided by operating activities. Refer to Rule 100(a) of Regulation G.

Rest of the question

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.

A reconciliation of the non-GAAP liquidity measure, Gross Cash Flow, to the most comparable GAAP liquidity measure for the fiscal year ended December 31, 2022, is as follows:

Calculation of Gross Cash Flow Reconciliation of Gross Cash Flow to Net Cash Provided by Operating Activities

Net Earnings $1,086.9 Gross Cash Flow $1,263.5

Depreciation & Amortization 176.6 Subtract: Depreciation & Amortization (176.6)

Gross Cash Flow $1,263.5 Net Earnings 1,086.9

Add: Depreciation & Amortization 176.6

Add (Subtract): All other uses or proceeds of operating cash flow 1.6

Add (Subtract): Net

Rest of the answer

Working Capital(1)

(324.1)

Net Cash Provided by Operating Activities $941.0

(1) Defined as changes to operating assets and liabilities, net of acquisitions

The reconciliations of Gross Cash Flow to Net Cash Provided by Operating Activities for the fiscal years ended December 31, 2021, 2020, and 2019, are attached to this letter as Exhibit A.

To the extent that we include Gross Cash Flow in our Annual Report to Shareholders in the future, we will expand our disclosure, beginning with our 2023 Annual Report to Shareholders, to include a reconciliation of the non-GAAP liquidity measure, Gross Cash Flow, to the most comparable GAAP liquidity measure. In particular, we will include the following disclosure on page 6 that currently identifies Gross Cash Flow as a non-GAAP measure: “Gross Cash Flow is a non-GAAP financial measure. It is reconciled to the most closely comparable GAAP measure, Net Cash Provided by Operating Activities, by removing the net impact of changes to operating assets and liabilities, net of acquisitions (which was $___, $(324.1), $(318.9), and $65.6 for 2023, 2022, 2021, and 2020, respectively(2)) and the net impact of all other uses or proceeds of Net Cash Provided by Operating Activities (which was $___, $1.6, $(6.7), and $14.7 for 2023, 2022, 2021, and 2020, respectively.(2))”

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The non-GAAP measure, free cash flow, on page 4 of your Annual Report to Shareholders is incorporated by reference into the Selected Financial Data section. Please disclose why you believe this non-GAAP measure is useful to investors and, to the extent material, the additional purposes for which management uses this non-GAAP measure. Refer to Item 10(e)(1)(i)(C) and (D) of Regulation S-K.

We will expand our disclosure in future filings, beginning with our 2020 Annual Report to Shareholders to the extent that this information is incorporated by reference into Item 6 of Form 10-K, to include additional information on why management believes the presentation of free cash flow provides useful information to investors on our financial condition as follows:

Free Cash Flow

We define free cash flow as GAAP net cash provided by operating activities less purchases of property and equipment, net of proceeds from sale of property and equipment.

Rest of the answer

Our management uses free cash flow as a supplemental measure in the evaluation of our business as we believe it provides our management and our investors a meaningful evaluation of our liquidity. Free cash flow is not a financial measure calculated in accordance with GAAP. Accordingly, it should not be considered in isolation or as a substitute for net cash flow from operations or other financial measures prepared in accordance with GAAP.

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