NINiSource

We note your presentation of the non-GAAP measure net revenues. Please present a reconciliation for this non-GAAP measure in accordance with Item 10(e)(1)(i)(B) of Regulation S-K. In doing so, reconcile this measures to the most directly comparable GAAP measure of gross margin.

Rest of the question

If you do not believe gross margin that includes depreciation and amortization is the most directly comparable GAAP measure, please tell us why in your response.

The Company respectfully acknowledges the Staff’s comment. The Company has been reconciling its presentation of the non-GAAP measure of net revenues to the GAAP measure of operating income because it believed the approach to be

U.S. Securities and Exchange Commission appropriate given that the Company had not previously calculated or presented the GAAP measure of gross margin.

In consideration of the Staff’s comment and how disclosures have evolved over time in this area, the Company intends to no longer present net revenues when discussing its financial results in future filings.

Rest of the answer

As such, the Company will remove references to net revenues when discussing its financial results in all future Form 10-K and 10-Q filings and in all future earnings releases furnished as exhibits to Form 8-K filings, beginning with its earnings release and Quarterly Report on Form 10-Q for the three months ended March 31, 2020.

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