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SEC Comment Letter for TARO PHARMACEUTICAL INDUSTRIES LTD (CIK 0000906338) — Mar 3, 2020

TARO PHARMACEUTICAL INDUSTRIES LTD (CIK 0000906338)
Date: March 3, 2020 · CIK: 0000906338 · Accession: 0000000000-20-001939

AI Filing Summary & Sentiment

File numbers found in text: 001-35463

Date
March 3, 2020
Author
Not clearly detected
Form
UPLOAD
Company
TARO PHARMACEUTICAL INDUSTRIES LTD (CIK 0000906338)

Letter

March 3, 2020 William Coote Interim Chief Financial Officer TARO PHARMACEUTICAL INDUSTRIES LTD 3 Skyline Drive Hawthorne, New York 10532 Re:TARO PHARMACEUTICAL INDUSTRIES LTD Form 20-F for Fiscal Year Ended March 31, 2019 Filed June 20, 2019 File No. 001-35463 Response Dated February 20, 2020 Dear Mr. Coote: We have reviewed your February 20, 2020 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 this comment 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 this comment, we may have additional comments. Form 20-F for Fiscal Year Ended March 31, 2019 Note 2: - Significant Accounting Policies b. Financial statements in U.S. dollars, page F-12 1.Please address each indicator identified in ASC 830-10-55-5 and tell us whether it suggested CAD or USD as your functional currency for your initial assessment versus the assessment adopted on April 1, 2019, and how each indicator was weighted. Clarify the significant changed economic facts and circumstances underlying each changed indicator. You may contact Tracey Houser at (202) 551-3736, or Jeanne Baker at (202) 551-3691, if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance

FirstName LastNameWilliam Coote Comapany NameTARO PHARMACEUTICAL INDUSTRIES LTD March 3, 2020 Page 2 FirstName LastName William Coote TARO PHARMACEUTICAL INDUSTRIES LTD March 3, 2020 Page 2 Office of Life Sciences

Show Raw Text
March 3, 2020
William Coote
Interim Chief Financial Officer
TARO PHARMACEUTICAL INDUSTRIES LTD
3 Skyline Drive
Hawthorne, New York 10532
Re:TARO PHARMACEUTICAL INDUSTRIES LTD
Form 20-F for Fiscal Year Ended March 31, 2019
Filed June 20, 2019
File No. 001-35463
Response Dated February 20, 2020
Dear Mr. Coote:
            We have reviewed your February 20, 2020 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 this comment 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 this comment, we may have additional
comments.
Form 20-F for Fiscal Year Ended March 31, 2019
Note 2: - Significant Accounting Policies
b. Financial statements in U.S. dollars, page F-12
1.Please address each indicator identified in ASC 830-10-55-5 and tell us whether it
suggested CAD or USD as your functional currency for your initial assessment versus the
assessment adopted on April 1, 2019, and how each indicator was weighted. Clarify the
significant changed economic facts and circumstances underlying each changed indicator.
            You may contact Tracey Houser at (202) 551-3736, or Jeanne Baker at (202) 551-3691, if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance

 FirstName LastNameWilliam Coote
 Comapany NameTARO PHARMACEUTICAL INDUSTRIES LTD
 March 3, 2020 Page 2
 FirstName LastName
William Coote
TARO PHARMACEUTICAL INDUSTRIES LTD
March 3, 2020
Page 2
Office of Life Sciences