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Correspondence 0001104659-23-071744 from Monster Beverage Corp (MNST) (CIK 0000865752) (MNST)

Monster Beverage Corp (MNST) (CIK 0000865752)
Date: June 15, 2023 · CIK: 0000865752 · Accession: 0001104659-23-071744

AI Filing Summary & Sentiment

File numbers found in text: 001-18761

Referenced dates: June 8, 2023

Date
June 15, 2023
Author
/s/ Thomas Kelly
Form
CORRESP
Company
Monster Beverage Corp (MNST) (CIK 0000865752)

Letter

VIA EDGAR Division of Corporation Finance Office of Manufacturing Attention: Mr. Dale Welcome Re: Monster Beverage Corp. Form 10-K for the Fiscal Year Ended December 31, 2022 Filed March 1, 2023 File No. 001-18761

Dear Mr. Welcome and Ms. McConnell:

This letter is being furnished on behalf of Monster Beverage Corporation (the “Company”) in response to the comment received from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) by letter dated June 8, 2023, regarding the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2022 that was filed with the Commission on March 1, 2023 (File No. 001-18761).

For your convenience, the text of the Staff’s comment has been included in bold and italics, and we have set forth the Company’s response immediately below the numbered comment.

Form 10-K for the Fiscal Year Ended December 31, 2022

Management's Discussion and Analysis of Financial Condition and Results of Operations

Inflation, page 58

1. You disclose here, and in your quarterly filing, that inflation has negatively impacted your results of operations, leading to increased cost of sales and operating expenses. In future filings, please quantify and disclose the impact of the inflationary pressures you are experiencing on cost of sales, gross margins and operating expenses. For example, based on the material decline in gross profit as a percentage of net sales from 56.1% for the year ended December 31, 2021 to 50.3% for the year ended December 31, 2022, specifically quantify the impacts of increased freight rates and fuel costs, including costs relating to the importation of aluminum cans, increased ingredient and other input costs, including secondary packaging materials, increased aluminum can costs attributable to higher aluminum commodity pricing, increased co-packing fees, production inefficiencies, and geographical sales mix.

Response:

In response to the Staff’s comment, the Company advises the Staff that, in future filings, if applicable, the Company will quantify and disclose, to the extent possible, the impact of inflationary pressures on the Company’s cost of sales, gross margins and operating expenses.

We appreciate the Staff’s time and attention, and we hope that the foregoing has been responsive to the Staff’s comment. If you have any further questions or need any additional information, please feel free to contact the undersigned at (951) 739-6200 at your convenience.

Sincerely,
/s/ Thomas Kelly

Show Raw Text
CORRESP
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June 15, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Mr. Dale Welcome

    Ms. Anne McConnell

    Re:
    Monster Beverage Corp.

    Form 10-K for the Fiscal Year Ended December 31, 2022

    Filed March 1, 2023

    File No. 001-18761

 Dear Mr. Welcome and Ms. McConnell:

This letter is being furnished
on behalf of Monster Beverage Corporation (the “Company”) in response to the comment received from the staff
of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
by letter dated June 8, 2023, regarding the Company’s Annual Report on Form 10-K for the fiscal year ended December 31,
2022 that was filed with the Commission on March 1, 2023 (File No. 001-18761).

For your convenience, the
text of the Staff’s comment has been included in bold and italics, and we have set forth the Company’s response immediately
below the numbered comment.

Form 10-K for the Fiscal Year Ended
December 31, 2022

Management's Discussion and Analysis of Financial Condition
and Results of Operations

Inflation, page 58

 1. You disclose here, and in your quarterly filing, that inflation has negatively impacted your results
of operations, leading to increased cost of sales and operating expenses. In future filings, please quantify and disclose the impact of
the inflationary pressures you are experiencing on cost of sales, gross margins and operating expenses. For example, based on the material
decline in gross profit as a percentage of net sales from 56.1% for the year ended December 31, 2021 to 50.3% for the year ended
December 31, 2022, specifically quantify the impacts of increased freight rates and fuel costs, including costs relating to the importation
of aluminum cans, increased ingredient and other input costs, including secondary packaging materials, increased aluminum can costs attributable
to higher aluminum commodity pricing, increased co-packing fees, production inefficiencies, and geographical sales mix.

Response:

In response to the
Staff’s comment, the Company advises the Staff that, in future filings, if applicable, the Company will quantify and disclose, to
the extent possible, the impact of inflationary pressures on the Company’s cost of sales, gross margins and operating expenses.

We appreciate the Staff’s
time and attention, and we hope that the foregoing has been responsive to the Staff’s comment.  If you have any further questions
or need any additional information, please feel free to contact the undersigned at (951) 739-6200 at your convenience.

    Sincerely,

    /s/ Thomas Kelly

    Thomas Kelly

    Chief Financial Officer

cc: Farzad F. Damania

Katten Muchin Rosenman LLP