SEC Comment Letter for ORTHOPEDIATRICS CORP (KIDS) (CIK 0001425450) (KIDS) — Sep 15, 2017
ORTHOPEDIATRICS CORP (KIDS) (CIK 0001425450)
Date: Sept. 15, 2017 · CIK: 0001425450 · Accession: 0000000000-17-032839
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Letter
Mail Stop 3030 September 15, 2017 Via E -mail Mark C. Throdahl Chief Executive Officer OrthoPediatrics Corp. 2850 Frontier Drive Warsaw, IN 46582
Re: OrthoPediatrics Corp. Amendment No. 2 to Registration Statement on Form S -1 Filed September 8, 2017 File No. 333 -212076
Dear Mr. Throdahl :
We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do no t believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 31, 2017 letter .
Consolidated Statement of Operations, page F -4
1. We note the presentations of the foreign currency translation adjustment and comprehensive loss on pa ge F-5 for the six months ended June 30, 2017. Revise the filing to provide a consolidated statement of comprehensive income as required by ASC 220 - 10-45.
Mark C. Throdahl OrthoPediatrics Corp. September 15 , 2017 Page 2
Note 2. Significant Accounting Policies
Inventories, net page F -10
2. We note on page F -9 that yo u consign inventory to your customers. Please revise the filing to disclose the amount of consigned inventory held at each reporting period end as required by Question 2 paragraph 4 of SAB Topic 13A(2).
You may contact Tara Harkins at (202) 551 -3639 or Kevin Kuhar , Accounting Branch Chief , at (202) 551 -3662 if you have questions regarding comments on the financial s tatements and related matters. Please contact Heather Percival at (202) 551 -3498 or Geoff Kruczek, Special Counsel, at (202) 551 -3641 with any other questions.
Sincerely,
/s/ Kevin J. Kuhar for
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Mail Stop 3030 September 15, 2017 Via E -mail Mark C. Throdahl Chief Executive Officer OrthoPediatrics Corp. 2850 Frontier Drive Warsaw, IN 46582 Re: OrthoPediatrics Corp. Amendment No. 2 to Registration Statement on Form S -1 Filed September 8, 2017 File No. 333 -212076 Dear Mr. Throdahl : We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do no t believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 31, 2017 letter . Consolidated Statement of Operations, page F -4 1. We note the presentations of the foreign currency translation adjustment and comprehensive loss on pa ge F-5 for the six months ended June 30, 2017. Revise the filing to provide a consolidated statement of comprehensive income as required by ASC 220 - 10-45. Mark C. Throdahl OrthoPediatrics Corp. September 15 , 2017 Page 2 Note 2. Significant Accounting Policies Inventories, net page F -10 2. We note on page F -9 that yo u consign inventory to your customers. Please revise the filing to disclose the amount of consigned inventory held at each reporting period end as required by Question 2 paragraph 4 of SAB Topic 13A(2). You may contact Tara Harkins at (202) 551 -3639 or Kevin Kuhar , Accounting Branch Chief , at (202) 551 -3662 if you have questions regarding comments on the financial s tatements and related matters. Please contact Heather Percival at (202) 551 -3498 or Geoff Kruczek, Special Counsel, at (202) 551 -3641 with any other questions. Sincerely, /s/ Kevin J. Kuhar for Amanda Ravitz Assistant Director Office of Electronics and Machinery cc: Charles K. Ruck, Esq. Latham & Watkins LLP