VRSKVerisk Analytics

We note several instances where you present non-GAAP measures with undue prominence For example, in Table 1 you disclose Adjusted EBITDA before Net Income, the comparable GAAP measure. Please ensure that the comparable GAAP measures are presented and discussed before the non-GAAP measures. Refer to Question 102.10 of the Non-GAAP Compliance and Disclosure Interpretations.

In future filings, we will revise our presentation of non-GAAP measures and ensure that comparable GAAP measures are presented and discussed before the non-GAAP measures. Read in the reply ↗

Revise to provide a more substantive discussion of how each of your non-GAAP measures is useful to investors. Refer to Item 10(e)(1)(i)(C) of Regulation S-K.

In future filings, we will provide a more substantive discussion of how each of our non-GAAP measures is useful to investors in accordance with Item 10(e)(1)(i)(C) of Regulation S-K. Read in the reply ↗

Please revise to reconcile consolidated Adjusted EBITDA to Net Income rather than Operating income. Refer to Question 103.02 of the Non-GAAP Compliance and Disclosure Interpretations.

In future filings, we will reconcile consolidated Adjusted EBITDA to Net Income. Read in the reply ↗

We note that you present segment adjusted EBITDA and margin. Revise to reconcile these non-GAAP measures to the most directly comparable GAAP financial measure, segment EBITDA and segment EBITDA margin. Please note that the reconciliations throughout the Form 8-K should begin with the comparable GAAP measure so your non- GAAP measures do not receive undue prominence.

Rest of the question

Also, ensure that your disclosure of segment adjusted EBITDA throughout the filing is preceded by disclosure of segment

In future filings, we will reconcile segment adjusted EBITDA and margin to segment EBITDA and segment EBITDA margin. We will also ensure that the reconciliations throughout the Form 8-K will begin with the comparable GAAP measures so that non-GAAP measures do not receive undue prominence. In addition, we will ensure that our disclosure of segment adjusted EBITDA throughout the filing is preceded by the disclosure of segment EBITDA. Read in the reply ↗