September 4, 2019

Richard Stoddart
Chief Executive Officer
INNERWORKINGS INC
600 West Chicago Avenue, Suite 850
Chicago, IL 60654

       Re: INNERWORKINGS INC
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed March 19, 2019
           Form 8-K Filed August 8, 2019
           Form 10-Q for the Quarterly Period Ended June 30, 2019
           Filed August 9, 2019
           File No. 000-52170

Dear Mr. Stoddart:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2018

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Critical Accounting Policies
Goodwill, page 24

1.    Please provide information for investors to assess the probability of
future goodwill
      impairment charges. For example, please disclose whether your North
American
      reporting unit is at risk of failing step one of the quantitative
impairment test or that the
      fair value of this reporting unit is substantially in excess of carrying
value and is not at
      risk of failing step one. If the North American reporting unit is at risk
of failing step one,
      you should disclose:
 Richard Stoddart
FirstName LastNameRichard Stoddart
INNERWORKINGS INC
Comapany 4, 2019
September NameINNERWORKINGS INC
September 4, 2019 Page 2
Page 2
FirstName LastName
             the percentage by which fair value exceeded carrying value at the
date of the most
             recent step one test;

             the amount of goodwill allocated to the reporting unit;

             a detailed description of the methods and key assumptions used and
how the key
             assumptions were determined;

             a discussion of the degree of uncertainty associated with the
assumptions; and

             a description of potential events and/or changes in circumstances
that could reasonably
             be expected to negatively affect the key assumptions.

         Please refer to Item 303(a)(3)(ii) of Regulation S-K, which requires a
description of
         known uncertainties, and Section V of the Commission's Guidance
Regarding
         Management's Discussion and Analysis of Financial Condition and
Results of Operations,
         SEC Release No. 34-48960, issued December 19, 2003 and available on
our website at
         www.sec.gov.
Item 8. Financial Statements and Supplementary Data
Notes to Consolidated Financial Statements
19. Business Segments, page 71

2.       Please disclose total expenditures for additions to long-lived assets
for each reportable
         segment. Refer to ASC 280-10-50-25b.
3.       Please tell us your consideration of providing revenue by geography as
set forth in ASC
         280-10-50-41 including disclosure of your domestic revenues separately
from your
         foreign revenues.
Form 8-K Filed August 8, 2019

Exhibit No. 99.1
Outlook, page 1

4.       Reference is made to your disclosure of non-GAAP diluted earnings per
share and
         adjusted EBITDA guidance for 2019. Please disclose, with equal or
greater prominence,
         the most directly comparable financial measure or measures calculated
and presented in
         accordance with GAAP and a reconciliation, which shall be
quantitative, to the extent
         available without unreasonable efforts, of the differences between the
non-GAAP
         financial measure disclosed with the most directly comparable
financial measure or
         measures calculated and presented in accordance with GAAP. Refer to
Item 10(e)(i)(A)-
         (B) of Regulation S-K.
 Richard Stoddart
INNERWORKINGS INC
September 4, 2019
Page 3
Form 10-Q for the Quarterly Period Ended June 30, 2019

Item 1. Condensed Consolidated Financial Statements (Unaudited)
Notes to Condensed Consolidated Financial Statements (Unaudited)
11. Commitments and Contingencies, page 19

5.       We note disclosure in your Form 10-K that a decision was pending on
your Motion to
         Dismiss filed November 26, 2018 pertaining to the securities class
action complaint.
         Please update your disclosure. Refer to ASC 270-10-50. Further, please
disclose an
         estimate of the possible loss or range of loss or a statement that
such an estimate cannot be
         made. Refer to ASC 450-20-50-4.
       In closing, 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.

        You may contact Adam Phippen, Staff Accountant, at (202) 551-3336 or
Donna Di
Silvio, Staff Accountant, at (202) 551-3202 with any questions.



FirstName LastNameRichard Stoddart                             Sincerely,
Comapany NameINNERWORKINGS INC
                                                               Division of
Corporation Finance
September 4, 2019 Page 3                                       Office of
Consumer Products
FirstName LastName