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United States securities and exchange commission logo
June 11, 2020
Michael A. Doyle
Chief Financial Officer
Forrester Research, Inc.
60 Acorn Park Drive
Cambridge, Massachusetts 02140
Re: Forrester Research,
Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2019
Filed March 13,
2020
Form 8-K Filed May
7, 2020
File No. 0-21433
Dear Mr. Doyle:
We have limited our review of your filings to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 8-K Filed May 7, 2020
Exhibit 99.1
1. You refer to pro forma
amounts throughout your Form 8-K. Your use of the term pro
forma implies these
amounts were determined and presented pursuant to Article 11 of
Regulation S-X. Please
consider using a different description of these amounts given it
does not appear that
they are determined or presented pursuant to Article 11 of Regulation
S-X, or explain the
basis for your presentation.
2. We refer to the
acquisition-related deferred revenue fair value adjustment made to arrive
at non-GAAP measures.
Please provide us a brief description of the transactions that gave
rise to the deferred
revenues and why management believes that performance measures
excluding the effects
of purchase accounting are useful to an investor. Please tell us how
you considered question
100.04 of the Non-GAAP Compliance and Disclosure
Michael A. Doyle
Forrester Research, Inc.
June 11, 2020
Page 2
Interpretations and Rule 100(b) of Regulation G.
3. Please tell us how your presentation of pro forma net income complies
with the
reconciliation requirement of Regulation G and Item 10(e) of Regulation
S-K.
In closing, 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.
You may contact Ta Tanisha Meadows at (202) 551-3322 or Donna Di Silvio
at (202)
551-3202 with any questions.
Sincerely,
FirstName LastNameMichael A. Doyle
Division of
Corporation Finance
Comapany NameForrester Research, Inc.
Office of Trade &
Services
June 11, 2020 Page 2
cc: Scott R. Chouinard, Chief Accounting Officer
FirstName LastName