View:
United States securities and exchange commission logo
May 6, 2024
James Kehoe
Chief Financial Officer
Fidelity National Information Services, Inc.
347 Riverside Avenue
Jacksonville, FL 32202
Re: Fidelity National
Information Services, Inc.
Form 10-K for the
fiscal Year Ended December 31, 2023
Form 8-K furnished
February 26, 2024
File No. 001-16427
Dear James Kehoe:
We have reviewed your
filings and have the following comments.
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.
Form 8-K furnished February 26, 2024
Constant currency revenue, page 4
1. Please provide a clear
description of the process for calculating the constant currency
amounts. Refer to
Question 104.06 of the Non-GAAP Financial Measures Compliance
and Disclosure
Interpretations..
Free cash flow, page 9
2. Please revise the title
of your free cash flow measure to adjusted free cash flow or a
similar description as
your calculation differs from the typical calculation of cash flows
from operating
activities less capital expenditures. Refer to Question 102.07 of the Non-
GAAP Financial Measures
Compliance and Disclosure Interpretations.
James Kehoe
FirstName LastNameJames Kehoe
Fidelity National Information Services, Inc.
Comapany
May 6, 2024NameFidelity National Information Services, Inc.
May 6,
Page 2 2024 Page 2
FirstName LastName
Notes to Unaudited - Supplemental GAAP to Non-GAAP Reconciliations for the
three months
and years ended December 31, 2023 and 2022.
Exhibit H, page 13
3. We note your adjustment for acquisition, integration and other costs
includes Enterprise
transformation, including Future Forward and platform modernization.
Please tell us the
nature of these costs, your consideration of Question 100.01 of the
Non-GAAP Financial
Measures Compliance and Disclosure Interpretations, including why they
are not related
to normal, recurring, cash operating expenses and explain why this
adjustment is deemed
non-operational.
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.
Please contact Scott Stringer at 202-551-3272 or Joel Parker at
202-551-3651 if you have
questions regarding our comments.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services