SEC Comment Letter 0000000000-22-012965 to TEVA PHARMACEUTICAL INDUSTRIES LTD (TEVA)
TEVA PHARMACEUTICAL INDUSTRIES LTD
Date: Dec. 1, 2022 · CIK: 0000818686 · Accession: 0000000000-22-012965
AI Filing Summary & Sentiment
File numbers found in text: 001-16174
Letter
United States securities and exchange commission logo December 1, 2022 Eli Kalif Executive Vice President, Chief Financial Officer Teva Pharmaceutical Industries Limited 124 Dvora HaNevi’a Street Tel Aviv, Israel 6944020 Re:Teva Pharmaceutical Industries Limited Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 9, 2022 Form 8-K Dated November 3, 2022 File No. 001-16174 Dear Eli Kalif: We have reviewed your October 26, 2022 response to our comment letter 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 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 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. Unless we note otherwise, our reference to prior comment is to the comment in our September 13, 2022 letter. Form 8-K Dated November 3, 2022 Exhibit 99.1 Teva Reports 2022 Third Quarter Financial Results Non-GAAP Financial Measures, page 19 1.We note your response to our prior comment and your proposed revisions to future earnings releases as presented in Exhibit B. As indicated in the non-GAAP headnote and reconciliation tables for the three and nine months ended September 30, 2022 and 2021, your revised non-GAAP presentation appears to include most of the major captions of the consolidated statements of income (loss), which continues to give undue prominence to your non-GAAP financial measures. Please further revise your presentation to comply with Question 102.10 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.
FirstName LastNameEli Kalif Comapany NameTeva Pharmaceutical Industries Limited December 1, 2022 Page 2 FirstName LastName Eli Kalif Teva Pharmaceutical Industries Limited December 1, 2022 Page 2 You may contact Li Xiao at 202-551-4391 or Frank Wyman at 202-551-3660 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
December 1, 2022
Eli Kalif
Executive Vice President, Chief Financial Officer
Teva Pharmaceutical Industries Limited
124 Dvora HaNevi’a Street
Tel Aviv, Israel 6944020
Re:Teva Pharmaceutical Industries Limited
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 9, 2022
Form 8-K Dated November 3, 2022
File No. 001-16174
Dear Eli Kalif:
We have reviewed your October 26, 2022 response to our comment letter 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 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
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.
Unless we note otherwise, our reference to prior comment is to the comment in our September
13, 2022 letter.
Form 8-K Dated November 3, 2022
Exhibit 99.1 Teva Reports 2022 Third Quarter Financial Results
Non-GAAP Financial Measures, page 19
1.We note your response to our prior comment and your proposed revisions to future
earnings releases as presented in Exhibit B. As indicated in the non-GAAP headnote and
reconciliation tables for the three and nine months ended September 30, 2022 and 2021,
your revised non-GAAP presentation appears to include most of the major captions of the
consolidated statements of income (loss), which continues to give undue prominence
to your non-GAAP financial measures. Please further revise your presentation to comply
with Question 102.10 of the Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures.
FirstName LastNameEli Kalif
Comapany NameTeva Pharmaceutical Industries Limited
December 1, 2022 Page 2
FirstName LastName
Eli Kalif
Teva Pharmaceutical Industries Limited
December 1, 2022
Page 2
You may contact Li Xiao at 202-551-4391 or Frank Wyman at 202-551-3660 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences