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United States securities and exchange commission logo





                             April 28, 2023

       Karen Brennan
       Chief Financial Officer
       Jones Lang LaSalle Inc.
       200 East Randolph Drive
       Chicago, IL 60601

                                                        Re: Jones Lang LaSalle
Inc.
                                                            Form 10-K for the
year ended December 31, 2022
                                                            Filed February 28,
2023
                                                            File No. 001-13145

       Dear Karen Brennan:

             We have reviewed your filing and have the following comment. In
our comment, we
       may ask you to provide us with information so we may better understand
your disclosure.

              Please respond to this comment 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
       comment applies to your facts and circumstances, please tell us why in
your response.

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

       Form 10-K for the year ended December 31, 2022

       Item 8 Financial Statements and Supplementary Data
       Revenue Recognition
       Work Dynamics, page 82

   1.                                                   We note your disclosure
that pricing for workplace management contracts typically
                                                        includes a management
fee and, in many instances, an incentive fee or other form of
                                                        variable consideration.
We further note that you generally act as principal for workplace
                                                        management contracts
with respect to third-party vendors and subcontractors engaged to
                                                        deliver operational
services to your clients' facilities. Please provide us with more
                                                        information regarding
the structure of your workplace management contracts, including
                                                        the terms of any fees
earned by you under the contracts. In your response, please tell us
                                                        whether the terms of
your contracts specifically require the customer to reimburse you for
                                                        amounts paid to
third-party vendors and subcontractors and include an example of the
                                                        contract terms in your
response.
 Karen Brennan
Jones Lang LaSalle Inc.
April 28, 2023
Page 2

        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 Paul Cline at 202-551-3851 or Robert Telewicz at
202-551-3438 if you
have questions regarding our comment.



FirstName LastNameKaren Brennan                           Sincerely,
Comapany NameJones Lang LaSalle Inc.
                                                          Division of
Corporation Finance
April 28, 2023 Page 2                                     Office of Real Estate
& Construction
FirstName LastName
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