SEC Comment Letter 0000000000-25-008045 to ZimVie Inc. (CIK 0001876588)
ZimVie Inc. (CIK 0001876588)
Date: July 30, 2025 · CIK: 0001876588 · Accession: 0000000000-25-008045
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-41242
Letter
Re: ZimVie Inc. Form 10-K for Fiscal Year Ended December 31, 2024 Form 8-K filed February 26, 2025 Response dated July 24, 2025 File No. 001-41242 Dear Richard Heppenstall:
July 30, 2025
Richard Heppenstall Executive Vice President, Chief Financial Officer and Treasurer ZimVie Inc. 4555 Riverside Drive Palm Beach Gardens, Florida 33410
We have reviewed your filings 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 8-K filed February 26, 2025 Exhibit 99.1, page 8
1. We note your response to comment 3. The adjustment that excludes step-up depreciation of property, plant and equipment associated with prior acquisitions for continuing operations results in the presentation of non-GAAP measures which reflect part, but not all, of an accounting concept. As such, the resulting non-GAAP measures substitute individually tailored recognition and measurement methods. Please revise your non-GAAP measures to remove this adjustment in future filings. Refer to Question 100.04 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures. 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 Tayyaba Shafique at 202-551-2110 or Tracey Houser at 202-551-3736 July 30, 2025 Page 2
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> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> July 30, 2025 Richard Heppenstall Executive Vice President, Chief Financial Officer and Treasurer ZimVie Inc. 4555 Riverside Drive Palm Beach Gardens, Florida 33410 Re: ZimVie Inc. Form 10-K for Fiscal Year Ended December 31, 2024 Form 8-K filed February 26, 2025 Response dated July 24, 2025 File No. 001-41242 Dear Richard Heppenstall: We have reviewed your filings 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 8-K filed February 26, 2025 Exhibit 99.1, page 8 1. We note your response to comment 3. The adjustment that excludes step-up depreciation of property, plant and equipment associated with prior acquisitions for continuing operations results in the presentation of non-GAAP measures which reflect part, but not all, of an accounting concept. As such, the resulting non-GAAP measures substitute individually tailored recognition and measurement methods. Please revise your non-GAAP measures to remove this adjustment in future filings. Refer to Question 100.04 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures. 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 Tayyaba Shafique at 202-551-2110 or Tracey Houser at 202-551-3736 July 30, 2025 Page 2 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>