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United States securities and exchange commission logo





                              September 25, 2020

       Michael Buckley
       Executive Vice President and Chief Financial Officer
       Robert Half International Inc.
       2884 Sand Hill Road, Suite 200
       Menlo Park, CA 94025

                                                        Re: Robert Half
International Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Response dated
September 17, 2020
                                                            File No. 1-10427

       Dear Mr. Buckley:

              We have reviewed your September 17, 2020 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       September 3, 2020 letter.

       Form 10-K for the Fiscal Year Ended December 31, 2019

       Item 8. Financial Statements and Supplementary Data
       Consolidated Statements of Operations, page 22

   1.                                                   Since the profits
(losses) on investments held in your rabbi trusts appear to be non-
                                                        operating in nature,
please present these amounts below all operating line items in a
                                                        location and manner
similar to the interest income, net line item. Refer to Rule 5-03.7(c)
                                                        of Regulation S-X.
       Consolidated Statements of Cash Flows, page 25

   2.                                                   Please present the
profits (losses) on investments held in your rabbi trusts as a separate
                                                        adjustment to reconcile
net income to net cash provided by operating activities at the top
                                                        of your operating
activities section, since these amounts do not relate to changes in
 Michael Buckley
Robert Half International Inc.
September 25, 2020
Page 2
         operating assets and liabilities. Unrealized holding profits (losses)
are a non-cash
         adjustment and realized profits (losses) are an adjustment to remove
the cash effects
         related to investing cash flows. Refer to ASC 230-10-45-28(b).
3.       We read your response to comment 1. You have elected to treat money
market funds held
         in your rabbi trusts as investments, rather than as cash equivalents.
Thus, the exchange of
         a mutual fund for a money market fund or another mutual fund would
appear to be a non-
         cash investing activity not presented in your statements of cash
flows, but requiring
         separate disclosure per ASC 230-10-50-3 and 50-4. Please tell us how
you applied this
         guidance or make the appropriate revisions.
Note A - Summary of Significant Accounting Policies
Fair Value of Financial Instruments, page 27

4.       We read your response to comment 2. Given the significance of the
investments held in
         your rabbi trusts to your total assets, please also present the asset
values of your mutual
         funds by type. Refer to ASC 820-10-55-100.
        You may contact Donna Di Silvio at (202) 551-3202 or Rufus Decker at
(202) 551-3769
if you have any questions.



FirstName LastNameMichael Buckley                              Sincerely,
Comapany NameRobert Half International Inc.
                                                               Division of
Corporation Finance
September 25, 2020 Page 2                                      Office of Trade
& Services
FirstName LastName
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