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In future filings, please revise your non-GAAP presentations of Adjusted Operating Margin percentage to add the comparable GAAP operating margin percentage for reported periods. In addition, revise the description of "Other items" within your reconciliation to note the respective amounts which should facilitate historical comparisons; one of the reasons for your use of non-GAAP measures.

Rest of the question

Please refer to the Commissions "Conditions for Use of Non-GAAP Financial Measures" Release No. 33-8176, footnote 27.

FactSet acknowledges the Staff’s comments regarding the Company’s disclosure of Non-GAAP Financial Measures on page 37 of the Form 10-K. In future filings, the Company intends to include the comparable GAAP operating margin percentage for reported periods when it refers to adjusted operating margin percentage for such periods.

Rest of the answer

In addition, in future filings, the Company will expand the description of “Other items” within its reconciliation to note the respective amounts included within such item to facilitate historical comparisons and will provide the reason for our use of non-GAAP measures.

In connection with the Company’s response, FactSet acknowledges that it is responsible for the accuracy and adequacy of the disclosure in its filings, notwithstanding any review, comments, action, or absence of action by the Staff.

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