SEC Comment Letter 0000000000-24-011069 to Paragon 28, Inc. (FNA) (CIK 0001531978)
Paragon 28, Inc. (FNA) (CIK 0001531978)
Date: Sept. 30, 2024 · CIK: 0001531978 · Accession: 0000000000-24-011069
AI Filing Summary & Sentiment
Letter
September 30, 2024 Albert DaCosta CEO Paragon 28, Inc. 14445 Grasslands Drive Englewood, CO 80112 Re:Paragon 28, Inc. Amendment No. 1 to Form 10-K for the fiscal year ended December 31, 2023 Dear Albert DaCosta: We have reviewed your filing 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. After reviewing your response to this letter, we may have additional comments. Amendment No. 1 to Form 10-K for the fiscal year ended December 31, 2023 Item 11. Executive Compensation., page 165 1.It appears that you have not provided your disclosure about your recovery analysis in an Interactive Data File in accordance with Rule 405 of Regulation S-T and the EDGAR Filer Manual. Please confirm that in future filings, where you conduct a recovery analysis, the interactive data will be included. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you have any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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September 30, 2024
Albert DaCosta
CEO
Paragon 28, Inc.
14445 Grasslands Drive
Englewood, CO 80112
Re:Paragon 28, Inc.
Amendment No. 1 to Form 10-K for the fiscal year ended December 31, 2023
Dear Albert DaCosta:
We have reviewed your filing 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. After reviewing your response to this letter, we may have
additional comments.
Amendment No. 1 to Form 10-K for the fiscal year ended December 31, 2023
Item 11. Executive Compensation., page 165
1.It appears that you have not provided your disclosure about your recovery analysis in an
Interactive Data File in accordance with Rule 405 of Regulation S-T and the EDGAR
Filer Manual. Please confirm that in future filings, where you conduct a recovery
analysis, the interactive data will be included.
We remind you that the company and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action or absence of action
by the staff. Please contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you
have any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services