 | Ryan Lawrence | |||||
| Deputy General Counsel | ||||||
| 225 West Wacker, Suite 3000 | ||||||
| Chicago, IL 60606 | ||||||
| Main +1 312 470 1800 | ||||||
| ryan.lawrence@cushwake.com | ||||||
| cushmanwakefield.com | ||||||
February 26, 2020
Via EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate & Construction
100 F Street, N.E.
Washington, D.C. 20549
| Attn: | Jennifer Monick |
Jeffrey Lewis |
| Re: | Cushman & Wakefield plc |
Ladies and Gentlemen:
This letter is being submitted by Cushman & Wakefield plc (the “Company”) following additional telephonic conversations with the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to the Staff’s review of the Company’s Annual Report on Form10-K for the year ended December 31, 2018 (the “Form10-K”).
The Company acknowledges the Staff’s verbally-issued comment relating to the disclosure and presentation set forth in the section captioned “Management’s Discussion and Analysis of Financial Condition and Results of Operations” (the “MD&A”) and undertakes to enhance its MD&A disclosure in future filings with the Commission in a manner consistent with its discussions with the Staff.
* * * * *
Securities and Exchange Commission
February 26, 2020
Page 2
Should you have any questions relating to any of the foregoing, please feel free to contact the undersigned at (312)424-8285 or Robert M. Hayward of Kirkland & Ellis LLP, counsel to the Company, at (312)862-2133.
Thank you for your assistance in this matter.
| Sincerely, |
| /s/ Ryan Lawrence |
| Ryan Lawrence |
| Deputy General Counsel |
Enclosure
| cc: | Robert M. Hayward |
Kirkland & Ellis LLP |