SEC Comment Letter 0000000000-23-011981 to ELI LILLY & Co (LLY) (CIK 0000059478) (LLY)
ELI LILLY & Co (LLY) (CIK 0000059478)
Date: Nov. 1, 2023 · CIK: 0000059478 · Accession: 0000000000-23-011981
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File numbers found in text: 001-06351
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United States securities and exchange commission logo
November 1, 2023
Anat Ashkenazi
Executive Vice President and Chief Financial Officer
Eli Lilly and Company
Lilly Corporate Center
Indianapolis, IN 46285
Re:Eli Lilly and Company
Form 10-K for the fiscal year ended December 31, 2022
Response dated October 26, 2023
File No. 001-06351
Dear Anat Ashkenazi:
We have reviewed your October 26, 2023 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our September 29, 2023
letter.
Response dated October 26, 2023
Management's Discussion and Analysis of Results of Operations and Financial Condition, page
37
1.We note your response to prior comment 1 and re-issue it in part. Please expand your
disclosure to address how your reputation or brand could be affected by climate change
and the potential response from investors, lenders, and customers.
2.We note your response to prior comment 2 stating that you did not experience any
material impacts from severe weather-related events and re-issue it in part.
Please quantify all weather-related damages to your property or operations for each of the
years ended December 31, 2022, 2021, and 2020.
FirstName LastNameAnat Ashkenazi
Comapany NameEli Lilly and Company
November 1, 2023 Page 2
FirstName LastName
Anat Ashkenazi
Eli Lilly and Company
November 1, 2023
Page 2
Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or Karina
Dorin, Attorney-Adviser, at (202) 551-3763 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Donald A. Zakrowski, Senior VP Finance & CAO