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UPLOAD Filing

ADMA BIOLOGICS, INC.
Date: July 30, 2025 · CIK: 0001368514 · Accession: 0000000000-25-008020

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File numbers found in text: 001-36728

Date
July 30, 2025
Author
Division of
Form
UPLOAD
Company
ADMA BIOLOGICS, INC.

Letter

Re: ADMA Biologics, Inc. Form 10-K for the fiscal year ended December 31, 2024 Filed March 18, 2025 File No. 001-36728 Dear Brad Tade:

July 30, 2025

Brad Tade Chief Financial Officer & Treasurer ADMA Biologics, Inc. 465 State Route 17 Ramsey, New Jersey 07446

We have reviewed your July 23, 2025 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 our 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 July 23, 2025 letter.

Form 10-K for the fiscal year ended December 31, 2024 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 68 Results of Operations, page 70

1. Please address the following regarding your response to comment one. From your recent earnings calls, it appears there has been a shift in the mix of your three Immune Globulin (IG) products over the last eight quarters. During these investor calls, you have been able to provide quantification of the shift between these respective IG products, the shift of which appears to be of significant interest to the investing community, especially leading up to and since the yield enhancement. As you noted in your response, for the years ended December 31, 2024, 2023 and 2022, the three IG Products represented 94%, 92% and 89%, respectively, of your total revenue. Accordingly, a breakout that presents all three IG products as a single unit, may not be July 30, 2025 Page 2

as informative as one that separately quantifies each of them. Tell us how you specifically considered the guidance in Item 303(b)(2)(i) and (ii) of Regulation S-K in your analysis, since your IG products as a whole constitute substantially all of your revenue and there may be sales trends for each IG product within that group that warrant disclosure as seem to be referenced in your earnings calls. Further, in applying the guidance of ASC 280-10-50-40, an enterprise with a relatively narrow product line may not consider two products to be similar, while an enterprise with a broad product line may consider those same two products to be similar. Please amplify your discussion of your application of ASC 280-10-50- 40 to explain how you considered whether the concentration of substantially all your revenues being from only three IG products would warrant further disaggregation. As part of your response, please provide us with a sample breakdown of revenue from the three IG products for recent periods.

Please contact Jenn Do at 202-551-3743 or Kevin Vaughn at 202-551-3494 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Life
Sciences

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 July 30, 2025

Brad Tade
Chief Financial Officer & Treasurer
ADMA Biologics, Inc.
465 State Route 17
Ramsey, New Jersey 07446

 Re: ADMA Biologics, Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 Filed March 18, 2025
 File No. 001-36728
Dear Brad Tade:

 We have reviewed your July 23, 2025 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
our 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 July 23,
2025 letter.

Form 10-K for the fiscal year ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations,
page 68
Results of Operations, page 70

1. Please address the following regarding your response to comment one.
From your
 recent earnings calls, it appears there has been a shift in the mix of
your three Immune
 Globulin (IG) products over the last eight quarters. During these
investor calls, you
 have been able to provide quantification of the shift between these
respective IG
 products, the shift of which appears to be of significant interest to
the investing
 community, especially leading up to and since the yield enhancement. As
you noted
 in your response, for the years ended December 31, 2024, 2023 and 2022,
the three IG
 Products represented 94%, 92% and 89%, respectively, of your total
revenue.
 Accordingly, a breakout that presents all three IG products as a single
unit, may not be
 July 30, 2025
Page 2

 as informative as one that separately quantifies each of them.
 Tell us how you specifically considered the guidance in Item
303(b)(2)(i) and (ii)
 of Regulation S-K in your analysis, since your IG products as a
whole constitute
 substantially all of your revenue and there may be sales trends for
each IG product
 within that group that warrant disclosure as seem to be referenced
in your
 earnings calls.
 Further, in applying the guidance of ASC 280-10-50-40, an enterprise
with a
 relatively narrow product line may not consider two products to be
similar, while
 an enterprise with a broad product line may consider those same two
products to
 be similar. Please amplify your discussion of your application of
ASC 280-10-50-
 40 to explain how you considered whether the concentration of
substantially all
 your revenues being from only three IG products would warrant
further
 disaggregation.
 As part of your response, please provide us with a sample breakdown
of revenue
 from the three IG products for recent periods.

 Please contact Jenn Do at 202-551-3743 or Kevin Vaughn at 202-551-3494
if you
have questions regarding comments on the financial statements and related
matters.

 Sincerely,

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