CORRESP 1 filename1.htm Document

Christopher Carroll
Senior Vice President and
Chief Accounting Officer

Interpublic Group
909 Third Avenue
New York, NY 10022

www.interpublic.com
(212) 704-1200

ipglogo61617a08.jpg

FOIA CONFIDENTIAL TREATMENT REQUESTED BY THE INTERPUBLIC GROUP OF COMPANIES, INC. PURSUANT TO RULE 83
CONFIDENTIAL TREATMENT HAS BEEN REQUESTED WITH RESPECT TO THE OMITTED PORTIONS OF THIS LETTER. INFORMATION THAT WAS OMITTED IN THE EDGAR VERSION HAS BEEN NOTED IN THIS LETTER WITH A PLACEHOLDER IDENTIFIED BY THE MARK "[***]".
February 9, 2018
Mr. Larry Spirgel
Assistant Director, Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-7010
Re:    The Interpublic Group of Companies, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2016
Filed February 21, 2017
File No. 001-06686

Dear Mr. Spirgel:
During a conference call on February 6, 2018, the staff of the U.S. Securities and Exchange Commission (the “Staff”) provided an additional comment to the comment response letter filed with the Staff on February 1, 2018 related to the Annual Report on Form 10-K of The Interpublic Group of Companies, Inc. (the “Company,” “Interpublic” or “we”) for the year ended December 31, 2016 filed on February 21, 2017. This letter sets forth our response to the additional comment provided by the Staff.
Because of the confidential nature of information contained herein, this submission includes a request for confidential treatment for selected portions of this letter, as indicated by [***], with respect to the Freedom of Information Act (“FOIA”). We have filed a separate letter with the Office of Freedom of Information and Privacy Act (the “FOIA Office”) in connection with the confidential treatment request, pursuant to Rule 83 of the Commission’s Rules on Information and Requests (17 C.F.R. § 200.83) (“Rule 83”). A complete version of the response letter has been separately filed with the Staff.


CONFIDENTIAL TREATMENT REQUEST BY THE INTERPUBLIC GROUP OF COMPANIES, INC.
THE INTERPUBLIC GROUP OF COMPANIES, INC. 1


Mr. Larry Spirgel
United States Securities and Exchange Commission
Page 2


Please promptly inform the Company of any request for disclosure of the confidential portions herein made pursuant to FOIA or otherwise so that the undersigned may substantiate the foregoing request for confidential treatment in accordance with Rule 83.
Rule 83 Confidential Treatment Request by The Interpublic Group of Companies, Inc. Request #1
1.
Quantify the 2017 revenues and operating margins of [***].
The Interpublic Group of Companies, Inc. respectfully requests that the information contained in this Request #1 be treated as confidential information and that the Commission provide timely notice to the individual noted on the Company's accompanying Rule 83 cover letter prior to disclosure of any such information.
Rule 83 Confidential Treatment Request by The Interpublic Group of Companies, Inc. Request #2
 
 
2017
 
Operating Segment
 
Revenue $Ms
Operating Margin %1
Change from 2016 Operating Margin %1
[***]
 
[***]
[***]
[***]
[***]
 
[***]
[***]
[***]
[***]
 
 
[***]
[***]
 
 
 
 
 
[***]
 
[***]
[***]
[***]
The Interpublic Group of Companies, Inc. respectfully requests that the information contained in this Request #2 be treated as confidential information and that the Commission provide timely notice to the individual noted on the Company's accompanying Rule 83 cover letter prior to disclosure of any such information.
1Operating Margin percentages exclude certain items for consistency including acquisition related expenses, certain non-recurring income and expense items and dispositions and reorganizations occurring during 2017.
Rule 83 Confidential Treatment Request by The Interpublic Group of Companies, Inc. Request #3
[***]
The Interpublic Group of Companies, Inc. respectfully requests that the information contained in this Request #3 be treated as confidential information and that the Commission provide timely notice to the individual noted on the Company's accompanying Rule 83 cover letter prior to disclosure of any such information.


CONFIDENTIAL TREATMENT REQUEST BY THE INTERPUBLIC GROUP OF COMPANIES, INC.
THE INTERPUBLIC GROUP OF COMPANIES, INC. 2


Mr. Larry Spirgel
United States Securities and Exchange Commission
Page 3


Rule 83 Confidential Treatment Request by The Interpublic Group of Companies, Inc. Request #4
The Company notes that [***] does not exceed the quantitative thresholds detailed in ASC 280-10 and had revenues of [***] and an operating margin of [***] in 2017.
The Interpublic Group of Companies, Inc. respectfully requests that the information contained in this Request #4 be treated as confidential information and that the Commission provide timely notice to the individual noted on the Company's accompanying Rule 83 cover letter prior to disclosure of any such information.
As previously stated in the Company’s last response, 2017 actual results are in line with the trend towards convergence among the largest IAN operating units.

* * *

If you have any questions or require any additional information with respect to the above, please do not hesitate to contact me at (212) 704-1430.
Sincerely,
/s/ Christopher Carroll
Christopher Carroll
Senior Vice President,
Controller and Chief Accounting Officer



CONFIDENTIAL TREATMENT REQUEST BY THE INTERPUBLIC GROUP OF COMPANIES, INC.
THE INTERPUBLIC GROUP OF COMPANIES, INC. 3