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UPLOAD Filing

Alvotech
Date: July 21, 2025 · CIK: 0001898416 · Accession: 0000000000-25-007656

Revenue Recognition Financial Reporting Regulatory Compliance

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File numbers found in text: 001-41421

Date
July 21, 2025
Author
Division of
Form
UPLOAD
Company
Alvotech

Letter

Re: Alvotech Form 20-F for Fiscal Year Ended December 31, 2024 File No. 001-41421 Dear Linda Jonsdottir:

July 21, 2025

Linda Jonsdottir Chief Financial Officer Alvotech 9, Rue de Bitbourg L- 1273 Luxembourg Grand Duchy of Luxembourg

We have limited our review of your filing to the financial statements and related disclosures 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 20-F for Fiscal Year Ended December 31, 2024 Note 2.6 Revenue recognition, page F-14

1. We note your disclosure on pages 74-79 of your commercial partnerships that include licensing and other components. Please revise the notes to your financial statements in future filings to disclose the material terms of each of these arrangements, including your obligations under the agreements in accordance with IFRS 15. July 21, 2025 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.

Please contact Tara Harkins at 202-551-3639 or Lynn Dicker at 202-551-3616 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Life
Sciences

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 21, 2025

Linda Jonsdottir
Chief Financial Officer
Alvotech
9, Rue de Bitbourg
L- 1273 Luxembourg
Grand Duchy of Luxembourg

 Re: Alvotech
 Form 20-F for Fiscal Year Ended December 31, 2024
 File No. 001-41421
Dear Linda Jonsdottir:

 We have limited our review of your filing to the financial statements
and related
disclosures 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 20-F for Fiscal Year Ended December 31, 2024
Note 2.6 Revenue recognition, page F-14

1. We note your disclosure on pages 74-79 of your commercial partnerships
that include
 licensing and other components. Please revise the notes to your
financial statements in
 future filings to disclose the material terms of each of these
arrangements, including
 your obligations under the agreements in accordance with IFRS 15.
 July 21, 2025
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.

 Please contact Tara Harkins at 202-551-3639 or Lynn Dicker at
202-551-3616 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
</TEXT>
</DOCUMENT>