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United States securities and exchange commission logo





                            August 30, 2022

       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, 2021
                                                            File No. 001-10427

       Dear Mr. Buckley:

              We have reviewed your filings 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, 2021

       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
       22

   1.                                                   We note your non-GAAP
disclosures, specifically the reconciliation of the non-GAAP
                                                        adjusted summary of
operations to the reported summary of operations for the years ended
                                                        December 31, 2021 and
2020. Item 10(e)(1)(i)(A) of Regulation S-K requires that when a
                                                        registrant presents a
non-GAAP measure it must present the most directly comparable
                                                        GAAP measure with equal
or greater prominence. You present a full income statement to
                                                        reconcile your non-GAAP
measures. Please tell us your consideration of Question 102.10
                                                        of the Compliance and
Disclosure Interpretations on Non-GAAP Financial Measures and
                                                        Item 10(e)(1)(i)(A) of
Regulation S-K. This comment also applies to your Form 10-Q and
                                                        Item 2.02 Form 8-K for
the fiscal quarter ended June 30, 2022.
   2.                                                   Your results of
operations year-to-year comparison identifies key drivers for revenue
                                                        growth in each of the
reportable segments without quantifying the impact of each. Please
                                                        quantify the change for
each of the factors that you cite. Refer to Item 303(b) of
 Michael Buckley
Robert Half International Inc.
August 30, 2022
Page 2
         Regulation S-K.
Consolidated Statements of Cash Flows, page 30

3.       Please tell us why you classify capitalized cloud computing
implementation costs as
         operating cash flows referencing authoritative literature that
supports the classification.
        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 Nasreen Mohammed at 202-551-3773 or Adam Phippen at
202-551-
3336 if you have questions regarding comments on the financial statements and
related matters.



FirstName LastNameMichael Buckley                               Sincerely,
Comapany NameRobert Half International Inc.
                                                                Division of
Corporation Finance
August 30, 2022 Page 2                                          Office of Trade
& Services
FirstName LastName
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