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April 25, 2025
Earl Ellis
Chief Financial Officer
ABM Industries Incorporated
One Liberty Plaza, 7th Floor
New York, NY 10006
Re: ABM Industries Incorporated
Form 8-K Filed December 18, 2024
Response dated March 28, 2025
File No. 1-08929
Dear Earl Ellis:
We have reviewed your March 28, 2025 response to our comment letter and
have the
following comment(s).
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our March 6,
2025 letter.
Form 8-K Filed December 18, 2024
Exhibit 99.1
Reconciliations of Non-GAAP Financial Measures
1. We note your response to our prior comment. We believe that the "Prior
year self-
insurance adjustment" to arrive at the non-GAAP financial measures
Adjusted Net
Income and Adjusted EBITDA is inconsistent with the guidance in
Question 100.04
of the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations
because it removes a component of the reserve that is required by GAAP.
Please
revise your presentation to exclude this adjustment in your calculation
of any non-
GAAP financial measures presented in accordance with Item 10(e) of
Regulation S-K
or Regulation G.
April 25, 2025
Page 2
Please contact Ta Tanisha Meadows at 202-551-3322 or Joel Parker at
202-551-3651
if you have questions regarding comments on the financial statements and
related matters.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
cc: Dean Chin, Chief Accounting Officer