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UPLOAD Filing

ORTHOPEDIATRICS CORP
Date: June 11, 2025 · CIK: 0001425450 · Accession: 0000000000-25-006164

Financial Reporting Revenue Recognition Internal Controls

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File numbers found in text: 001-38242

Date
June 11, 2025
Author
Division of
Form
UPLOAD
Company
ORTHOPEDIATRICS CORP

Letter

Re: Orthopediatrics Corp Form 10-K for the Fiscal Year Ended December 31, 2024 Response Dated June 2, 2025 File No. 001-38242 Dear David R. Bailey:

June 11, 2025

David R. Bailey President and Chief Executive Officer Orthopediatrics Corp 2850 Frontier Drive Warsaw, Indiana 46582

We have reviewed your 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 a 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.

Form 10-K for the Fiscal Year Ended December 31, 2024 Critical Accounting Policies and Significant Judgements and Estimates Inventory Valuation, page 84

1. We note your response to comment 1. Given the substantial amount of inventory held on consignment, please include in future filings your accounting policy for the consigned inventory, similarly as provided in your response. Your disclosure should include a description of the nature and the expected life of the consigned inventory, how its value may or may not be affected by physical deterioration or obsolescence, and the process used to evaluate it for obsolescence. In addition, discuss your long sale cycle and your business growth in determination of its classification. Lastly, consider providing a detailed analysis in Management's Discussion and Analysis of the revenue recognized in each period from sales of consigned inventory. If substantially all of your sales are made through consignment, disclose that fact clearly. June 11, 2025 Page 2

Please contact Christie Wong at 202-551-3684 or Li Xiao at 202-551-4391 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Industrial
Applications and
Services

Show Raw Text
<DOCUMENT>
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<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 11, 2025

David R. Bailey
President and Chief Executive Officer
Orthopediatrics Corp
2850 Frontier Drive
Warsaw, Indiana 46582

 Re: Orthopediatrics Corp
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Response Dated June 2, 2025
 File No. 001-38242
Dear David R. Bailey:

 We have reviewed your 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 a
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.

Form 10-K for the Fiscal Year Ended December 31, 2024
Critical Accounting Policies and Significant Judgements and Estimates
Inventory Valuation, page 84

1. We note your response to comment 1. Given the substantial amount of
inventory held
 on consignment, please include in future filings your accounting policy
for the
 consigned inventory, similarly as provided in your response. Your
disclosure should
 include a description of the nature and the expected life of the
consigned inventory,
 how its value may or may not be affected by physical deterioration or
obsolescence,
 and the process used to evaluate it for obsolescence. In addition,
discuss your long
 sale cycle and your business growth in determination of its
classification. Lastly,
 consider providing a detailed analysis in Management's Discussion and
Analysis of
 the revenue recognized in each period from sales of consigned inventory.
If
 substantially all of your sales are made through consignment, disclose
that fact
 clearly.
 June 11, 2025
Page 2

 Please contact Christie Wong at 202-551-3684 or Li Xiao at 202-551-4391
if you
have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
</TEXT>
</DOCUMENT>