Correspondence 0000856982-24-000074 from MERIT MEDICAL SYSTEMS INC (MMSI) (CIK 0000856982) (MMSI)
MERIT MEDICAL SYSTEMS INC (MMSI) (CIK 0000856982)
Date: Aug. 1, 2024 · CIK: 0000856982 · Accession: 0000856982-24-000074
AI Filing Summary & Sentiment
File numbers found in text: 000-18592
Referenced dates: July 12, 2024, July 22, 2024
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CORRESP 1 filename1.htm August 1, 2024 Securities and Exchange Commission Division of Corporate Finance Office of Industrial Applications and Services 100 F Street, NE Washington, D.C. 20549 Attn: Tracey Houser and Al Pavot 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 July 12, 2024 File No. 000-18592 Dear Ms. Houser and Mr. Pavot: Merit Medical Systems, Inc. (the “Company”), is in receipt of a letter dated July 22, 2024 (the “Comment Letter”) from the staff of the Securities and Exchange Commission (the “Staff”) concerning the above-captioned filings. To facilitate the Staff’s review, we have reproduced the text of the Staff’s comment in italics below. Our response appears immediately below the comment. Form 8-K Filed February 28, 2024 Exhibit 99.1 Comment: 1. We note your response to our comment letter. Based on the information provided for the Foundations for Growth Program costs captured in the corporate transformation and restructuring non-GAAP adjustment, these costs appear to have been incurred in the normal course of your operations. With reference to Question 100.01 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures, please confirm that you will no longer exclude the corporate transformation costs from your non-GAAP measures. Response: Commencing with our Current Report on Form 8-K to be filed later today, financial information presented in earnings releases and other presentation materials which include non-GAAP financial measures will not exclude consulting costs associated with our Foundations for Growth Program from our non-GAAP measures. Prior period presentations of such information will be recast to conform with the current year presentation. August 1, 2024 Securities and Exchange Commission Division of Corporate Finance Office of Industrial Applications and Services Page 2 We appreciate your review of this response. Please feel free to contact me at (801) 316-4959 or through e-mail at rparra@merit.com for any additional questions or comments regarding the foregoing matter. Very truly yours, /s/ RAUL PARRA Chief Financial Officer and Treasurer Merit Medical Systems, Inc.