SEC Comment Letter 0000000000-24-006630 to MERIT MEDICAL SYSTEMS INC (MMSI) (CIK 0000856982) (MMSI)
MERIT MEDICAL SYSTEMS INC (MMSI) (CIK 0000856982)
Date: June 10, 2024 · CIK: 0000856982 · Accession: 0000000000-24-006630
AI Filing Summary & Sentiment
File numbers found in text: 000-18592
Referenced dates: May 24, 2024
Letter
United States securities and exchange commission logo June 10, 2024 Raul Parra Chief Financial Officer and Treasurer MERIT MEDICAL SYSTEMS INC 1600 West Merit Parkway South Jordan , Utah 84095 Re:MERIT MEDICAL SYSTEMS INC Form 10-K for Fiscal Year Ended December 31, 2023 Filed February 28, 2024 Form 8-K Filed February 28, 2024 Response Letter Dated May 24, 2024 File No. 000-18592 Dear Raul Parra: We have reviewed your May 24, 2024 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our May 13, 2024 letter. Form 8-K Filed February 28, 2024 Exhibit 99.1 1.We note your response to our comment letter. Please provide us with a more detailed, specific description about the nature of the activities performed by the consultants who provided services related to your Foundations for Growth Program. As part of your detailed description of the activities performed by the consultants, address why expenses incurred to optimize your commercial and manufacturing processes are not related to your operations and revenue generating activities. In addition, explain why your use of consultants for certain capabilities that you did not maintain internally supports the corporate transformation and restructuring adjustments to your non-GAAP performance measures. In this regard, Question 100.01 of the Non-GAAP Financial Measures
FirstName LastNameRaul Parra Comapany NameMERIT MEDICAL SYSTEMS INC June 10, 2024 Page 2 FirstName LastName Raul Parra MERIT MEDICAL SYSTEMS INC June 10, 2024 Page 2 Compliance and Disclosure Interpretations states, in part, "[w]hen evaluating what is a normal, operating expense, the staff considers the nature and effect of the non-GAAP adjustment and how it relates to the company’s operations, revenue generating activities, business strategy, industry and regulatory environment." Please contact Tracey Houser at 202-551-3736 or Al Pavot at 202-551-3738 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
June 10, 2024
Raul Parra
Chief Financial Officer and Treasurer
MERIT MEDICAL SYSTEMS INC
1600 West Merit Parkway
South Jordan , Utah 84095
Re:MERIT MEDICAL SYSTEMS INC
Form 10-K for Fiscal Year Ended December 31, 2023
Filed February 28, 2024
Form 8-K Filed February 28, 2024
Response Letter Dated May 24, 2024
File No. 000-18592
Dear Raul Parra:
We have reviewed your May 24, 2024 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our May 13, 2024
letter.
Form 8-K Filed February 28, 2024
Exhibit 99.1
1.We note your response to our comment letter. Please provide us with a more detailed,
specific description about the nature of the activities performed by the consultants who
provided services related to your Foundations for Growth Program. As part of your
detailed description of the activities performed by the consultants, address why expenses
incurred to optimize your commercial and manufacturing processes are not related to your
operations and revenue generating activities. In addition, explain why your use of
consultants for certain capabilities that you did not maintain internally supports the
corporate transformation and restructuring adjustments to your non-GAAP performance
measures. In this regard, Question 100.01 of the Non-GAAP Financial Measures
FirstName LastNameRaul Parra
Comapany NameMERIT MEDICAL SYSTEMS INC
June 10, 2024 Page 2
FirstName LastName
Raul Parra
MERIT MEDICAL SYSTEMS INC
June 10, 2024
Page 2
Compliance and Disclosure Interpretations states, in part, "[w]hen evaluating what is a
normal, operating expense, the staff considers the nature and effect of the non-GAAP
adjustment and how it relates to the company’s operations, revenue generating
activities, business strategy, industry and regulatory environment."
Please contact Tracey Houser at 202-551-3736 or Al Pavot at 202-551-3738 if you have
questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services