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SEC Comment Letter 0000000000-25-003716 to TEVA PHARMACEUTICAL INDUSTRIES LTD (TEVA)

TEVA PHARMACEUTICAL INDUSTRIES LTD
Date: April 7, 2025 · CIK: 0000818686 · Accession: 0000000000-25-003716

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File numbers found in text: 001-16174

Date
April 7, 2025
Author
Finance
Form
UPLOAD
Company
TEVA PHARMACEUTICAL INDUSTRIES LTD

Letter

Re: Teva Pharmaceutical Industries Limited Form 10-K for the Fiscal Year Ended December 31, 2024 Form 8-K dated January 29, 2025 File No. 001-16174 Dear Amir Weiss:

April 7, 2025

Amir Weiss SVP Finance, Chief Accounting Officer Teva Pharmaceutical Industries Limited 124 Dvora HaNevi'a Street Tel Aviv, Israel 6944020

We have limited our review of your filing to the financial statements and related disclosures and have the following comment.

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 dated January 29, 2025 Exhibit 99.1 2025 Outlook, page 1

1. Your 2025 outlook omits the comparable GAAP financial measures to non-GAAP operating income, adjusted EBITDA, non-GAAP diluted EPS and free cash flow. Please revise this presentation in future filings to include the corresponding GAAP financial measures with equal or greater prominence. Refer to Item 10(e)(1)(i) of Regulation S-K and Question 102.10(a) of the staff's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. 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. April 7, 2025 Page 2

Please contact Frank Wyman at 202-551-3660 or Angela Connell at 202-551-3426 with any questions.

Sincerely,
Division of Corporation
Finance
Office of Life Sciences

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<TEXT>
 April 7, 2025

Amir Weiss
SVP Finance, Chief Accounting 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, 2024
 Form 8-K dated January 29, 2025
 File No. 001-16174
Dear Amir Weiss:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

 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 dated January 29, 2025
Exhibit 99.1
2025 Outlook, page 1

1. Your 2025 outlook omits the comparable GAAP financial measures to
non-GAAP
 operating income, adjusted EBITDA, non-GAAP diluted EPS and free cash
flow.
 Please revise this presentation in future filings to include the
corresponding GAAP
 financial measures with equal or greater prominence. Refer to Item
10(e)(1)(i)
 of Regulation S-K and Question 102.10(a) of the staff's Compliance and
Disclosure
 Interpretations on Non-GAAP Financial Measures.
 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.
 April 7, 2025
Page 2

 Please contact Frank Wyman at 202-551-3660 or Angela Connell at
202-551-3426
with any questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Life Sciences
</TEXT>
</DOCUMENT>