Hill International, Inc.
One Commerce Square
2005 Market Street, 17th Floor
Philadelphia, PA 19103
February 15, 2022
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington D.C. 20549
Attention: Office of Trade & Services
Re: Hill International, Inc.
Form 10-K for Fiscal Year Ended December 31, 2020
Filed March 16, 2021
Item 2.02 Form 8-K filed November 8, 2021
Response dated January 10, 2022
File No. 001-33961
Ladies and Gentlemen:
Hill International, Inc. (the “Company”) submits the following responses to the comments raised in your letter dated February 1, 2022 with respect to the Company’s Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2020 and the Company’s Form 8-K filed on November 8, 2021. In order to facilitate your review, the Staff’s remaining comment is set forth in full below, followed by the Company’s response thereto.
Item 2.02 Form 8-K Filed November 8, 2021
Exhibit 99.1, page 1
1. We have reviewed your response to comment 2. If profit measures or other amounts are presented as a percentage of revenue here or in your Forms 10-K or 10-Q, they should be shown as a percentage of total revenue and not as a percentage of consulting fee revenue. In addition, your revenue discussions of dollar amounts should include total revenue and not consulting fee revenue in isolation.
COMPANY RESPONSE: The Company acknowledges the Staff’s comment and respectfully advises the Staff that, (i) if profit measures or other amounts are presented as a percentage of revenue in its future earnings releases or in its future Forms 10-K or 10-Q, the Company will show such profit measures or other amounts as a percentage of total revenue and not as a percentage of consulting fee revenue, and (ii) the Company’s revenue discussions of dollar amounts will, in the future, include total revenue and not consulting fee revenue in isolation.
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|Securities and Exchange Commission|
|February 15, 2022|
|Page 2 of 2|
If you or any other member of the staff have any questions or would like to discuss any of these matters further, please do not hesitate to contact the undersigned at (215) 309-7700.
|Very truly yours,|
|/s/ Todd Weintraub|
Senior Vice President and
Chief Financial Officer
cc: Raouf Ghali, Chief Executive Officer
Darrick M. Mix, Esq.