TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo May 6, 2024 Olivier Leonetti Chief Financial Officer Eaton Corporation plc Eaton House, 30 Pembroke Road Dublin 4, Ireland D04 Y0C2 Re: Eaton Corporation plc Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 000-54863 Dear Olivier Leonetti: We have reviewed your May 3, 2024 response to our comment letter and have the following comment. 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 April 8, 2024 letter. Form 10-K for the Fiscal Year Ended December 31, 2023 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations General, page 77 1. We note your response to prior comment 1. Considering management use the measures noted in your response in managing your segments and they believe such information is useful to investors, please confirm that you will include a quantified discussion of such measures in future Form 10-Q and Form 10-K filings regardless of whether you include them in your earnings releases. Refer to SEC Release No. 33-10751. Olivier Leonetti FirstName LastNameOlivier Leonetti Eaton Corporation plc Comapany May 6, 2024NameEaton Corporation plc May 6, Page 2 2024 Page 2 FirstName LastName Please contact Megan Akst at 202-551-3407 or Kathleen Collins at 202-551-3499 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology cc: Lizbeth Wright