SEC Comment Letter for Synergy CHC Corp. (SNYR) (CIK 0001562733) (SNYRQ) — Nov 8, 2016
Synergy CHC Corp. (SNYR) (CIK 0001562733)
Date: Nov. 8, 2016 · CIK: 0001562733 · Accession: 0000000000-16-100128
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File numbers found in text: 000-55098
Letter
Mail Stop 4546 November 8, 2016 Jack Ross President and Chief Executive Officer Synergy CHC Corp. 865 Spring Street Westbrook, ME 04092
Re: Synergy CHC Corp. Form 10-K for Fiscal Year Ended December 31, 2015 Filed March 30, 2016 File No. 000-55098
Dear Mr. Ross :
We have reviewed your October 12, 2016 response and have the following comment. Please respond to this comment within ten busine ss days by providing the requested information or advis e 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.
Results of Operations for the Years ended December 31, 2015 and December 31, 2014, page 9
1. We refer to your response to prior comment five. Based on the notes to your financials contained on page F -27, it appears that your draft results of operations disclosure woul d aggregate material product acquisitions under a single “product category” and therefore not separately identify and quantify the FY2015 revenue increases resulting from your two material product introductions. Accordingly, please confirm that you will revise future results of operations disclosures, as applicable, to identify individual product acquisitions that have materially impacted results of operations for the fiscal year and quantify those amounts separately . Refer to Item 303(a)(3)(iii) of Regu lation S -K.
Jack Ross Synergy CHC Corp. November 8, 2016 Page 2
Please contact Irene Paik at (202) 551 -6553 or Joseph McCann at (202) 55 1-6262 with any questions .
Sincerely,
/s/ Joseph McCann for
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Mail Stop 4546 November 8, 2016 Jack Ross President and Chief Executive Officer Synergy CHC Corp. 865 Spring Street Westbrook, ME 04092 Re: Synergy CHC Corp. Form 10-K for Fiscal Year Ended December 31, 2015 Filed March 30, 2016 File No. 000-55098 Dear Mr. Ross : We have reviewed your October 12, 2016 response and have the following comment. Please respond to this comment within ten busine ss days by providing the requested information or advis e 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. Results of Operations for the Years ended December 31, 2015 and December 31, 2014, page 9 1. We refer to your response to prior comment five. Based on the notes to your financials contained on page F -27, it appears that your draft results of operations disclosure woul d aggregate material product acquisitions under a single “product category” and therefore not separately identify and quantify the FY2015 revenue increases resulting from your two material product introductions. Accordingly, please confirm that you will revise future results of operations disclosures, as applicable, to identify individual product acquisitions that have materially impacted results of operations for the fiscal year and quantify those amounts separately . Refer to Item 303(a)(3)(iii) of Regu lation S -K. Jack Ross Synergy CHC Corp. November 8, 2016 Page 2 Please contact Irene Paik at (202) 551 -6553 or Joseph McCann at (202) 55 1-6262 with any questions . Sincerely, /s/ Joseph McCann for Suzanne Hayes Assistant Director Office of Healthcare and Insurance cc: W. David Mannheim , Esq. Wyrick Robbins Yates & Ponton LLP