Form: UPLOAD

SEC-generated letter

February 2, 2021

Published on February 2, 2021

United States securities and exchange commission logo





February 2, 2021

Robert Rozek
Chief Financial Officer
Korn Ferry
1900 Avenue of the Stars, Suite 2600
Los Angeles, California 90067

Re: Korn Ferry
Form 10-K for the
Fiscal Year Ended April 30, 2020
Filed July 15, 2020
File No. 001-14505

Dear Mr. Rozek:

We have reviewed your filing and have the following comment. In
our comment, we
may ask you to provide us with information so we may better understand
your disclosure.

Please respond to the comment 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
comment applies to your facts and circumstances, please tell us why in
your response.

After reviewing your
response to the comment, we may have additional comments.

Form 10-K for the Fiscal Year Ended April 30, 2020

Consolidated Financial Statements
Note 11. Segments, page F-38

1. Please tell us your
basis for presenting three measures of each segment's profit (operating
income, EBITDA and
adjusted EBITDA) in the ASC 280 segment footnote. Also,
explain why EBITDA and
adjusted EBITDA are permitted to be disclosed in the ASC 280
segment footnote, when
the operating income measure appears to be most consistent with
GAAP. Refer to ASC
280-10-50-27 and 50-28.
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.
Robert Rozek
Korn Ferry
February 2, 2021
Page 2

You may contact Suying Li at (202) 551-3335 or Rufus Decker at (202)
551-3769 with
any questions.



FirstName LastNameRobert Rozek Sincerely,
Comapany NameKorn Ferry
Division of Corporation
Finance
February 2, 2021 Page 2 Office of Trade &
Services
FirstName LastName