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SEC Comment Letter for Evolus, Inc. (EOLS) (CIK 0001570562) (EOLS) — Aug 6, 2019

Evolus, Inc. (EOLS) (CIK 0001570562)
Date: Aug. 6, 2019 · CIK: 0001570562 · Accession: 0000000000-19-012060

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File numbers found in text: 001-38381

Date
August 5, 2019
Author
Rolf Sundwall
Form
UPLOAD
Company
Evolus, Inc. (EOLS) (CIK 0001570562)

Letter

August 5, 2019 Lauren Silvernail Chief Financial Officer Evolus, Inc. 520 Newport Center Drive Suite 1200 Newport Beach, CA Re:Evolus, Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed March 20, 2019 File No. 001-38381 Dear Ms. Silvernail: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the comment 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 the comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2018 Item 15. Exhibits, Financial Statement Schedules, page 134 1.Please amend your filing to provide new certifications filed as Exhibits 31.1 and 31.2 to conform exactly to that provided in Item 601(b)(31) of Regulation S-K as it relates to internal controls over financial reporting (ICFR). In this regard, the introductory sentence in paragraph 4 should refer to ICFR as defined in the Exchange Act and certification 4(b) should discuss your obligations related to ICFR. Similarly, please amend the 10-Q for the quarterly period ended March 31, 2019.

FirstName LastNameLauren Silvernail Comapany NameEvolus, Inc. August 5, 2019 Page 2 FirstName LastName Lauren Silvernail Evolus, Inc. August 5, 2019 Page 2 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. You may contact Rolf Sundwall at 202-551-3105 or Christine Torney at 202-551-3652 with any questions. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance

Show Raw Text
August 5, 2019
Lauren Silvernail
Chief Financial Officer
Evolus, Inc.
520 Newport Center Drive
Suite 1200
Newport Beach, CA
92660
Re:Evolus, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed March 20, 2019
File No. 001-38381
Dear Ms. Silvernail:
            We have reviewed your filing and have the following comment.  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
            Please respond to the comment 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 the comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2018
Item 15. Exhibits, Financial Statement Schedules, page 134
1.Please amend your filing to provide new certifications filed as Exhibits 31.1 and 31.2 to
conform exactly to that provided in Item 601(b)(31) of Regulation S-K as it relates to
internal controls over financial reporting (ICFR). In this regard, the introductory
sentence in paragraph 4 should refer to ICFR as defined in the Exchange Act and
certification 4(b) should discuss your obligations related to ICFR. Similarly, please amend
the 10-Q for the quarterly period ended March 31, 2019.

 FirstName LastNameLauren Silvernail
 Comapany NameEvolus, Inc.
 August 5, 2019 Page 2
 FirstName LastName
Lauren Silvernail
Evolus, Inc.
August 5, 2019
Page 2
            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.
            You may contact Rolf Sundwall at 202-551-3105 or Christine Torney at 202-551-3652
with any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance