SEC Comment Letter 0000000000-23-008975 to PERRIGO Co plc (PRGO) (CIK 0001585364) (PRGO)
PERRIGO Co plc (PRGO) (CIK 0001585364)
Date: Aug. 17, 2023 · CIK: 0001585364 · Accession: 0000000000-23-008975
AI Filing Summary & Sentiment
File numbers found in text: 001-36353
Letter
United States securities and exchange commission logo August 17, 2023 Eduardo Bezerra Chief Financial Officer PERRIGO Co plc The Sharp Building, Hogan Place Dublin 2 Ireland D02 TY74 Re:PERRIGO Co plc Form 10-K for the Year Ended December 31, 2022 Filed February 28, 2023 Form 8-K Filed August 8, 2023 File No. 001-36353 Dear Eduardo Bezerra: We have limited our review of your filing to the financial statements and related disclosures 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 8-K dated August 8, 2023 Reconciliation of Non-GAAP Measures, page 13 1.Your reconciliation of Non-GAAP measures includes several line items and subtotals from the Statement of Operations. Please address the following: •Tell us why you believe your presentation is consistent with C&DI 102.10(a) and 102.10(c). •Tell us the nature of the $10.0 million milestone payments received related to royalty rights adjustment and why you believe the adjustment is consistent with C&DI 100.01. •Tell us why the $10.0 million adjustment is added in the Interest and Other column but subtracted in the Income from Continuing Operations column.
FirstName LastNameEduardo Bezerra Comapany NamePERRIGO Co plc August 17, 2023 Page 2 FirstName LastName Eduardo Bezerra PERRIGO Co plc August 17, 2023 Page 2 In closing, 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 Mary Mast at (202) 551-3613 or Dan Gordon at (202) 551-3486 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
Show Raw Text
United States securities and exchange commission logo
August 17, 2023
Eduardo Bezerra
Chief Financial Officer
PERRIGO Co plc
The Sharp Building, Hogan Place
Dublin 2
Ireland D02 TY74
Re:PERRIGO Co plc
Form 10-K for the Year Ended December 31, 2022
Filed February 28, 2023
Form 8-K
Filed August 8, 2023
File No. 001-36353
Dear Eduardo Bezerra:
We have limited our review of your filing to the financial statements and related
disclosures 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 8-K dated August 8, 2023
Reconciliation of Non-GAAP Measures, page 13
1.Your reconciliation of Non-GAAP measures includes several line items and subtotals
from the Statement of Operations. Please address the following:
•Tell us why you believe your presentation is consistent with C&DI 102.10(a) and
102.10(c).
•Tell us the nature of the $10.0 million milestone payments received related to royalty
rights adjustment and why you believe the adjustment is consistent with C&DI
100.01.
•Tell us why the $10.0 million adjustment is added in the Interest and Other column
but subtracted in the Income from Continuing Operations column.
FirstName LastNameEduardo Bezerra
Comapany NamePERRIGO Co plc
August 17, 2023 Page 2
FirstName LastName
Eduardo Bezerra
PERRIGO Co plc
August 17, 2023
Page 2
In closing, 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 Mary Mast at (202) 551-3613 or Dan Gordon at (202) 551-3486 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences