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CORRESP Filing

Alvotech
Date: July 31, 2025 · CIK: 0001898416 · Accession: 0001898416-25-000006

Revenue Recognition Financial Reporting Regulatory Compliance

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File numbers found in text: 001-41421

Referenced dates: July 21, 2025

Date
July 31, 2025
Author
_/s/__Linda Jonsdottir_____________
Form
CORRESP
Company
Alvotech

Letter

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

July 31, 2025

Via EDGAR

Securities and Exchange Commission Division of Corporation Finance Office of Life Sciences 100 F Street, N.E. Washington, D.C. 20549-3628

Attention: Tara Harkins Lynn Dicker

Ladies and Gentlemen: This letter provides the response to the comment provided by the staff (the Staff) of the Securities and Exchange Commission in its comment letter dated July 21, 2025 (the Comment Letter) with respect to Form 20-F for Fiscal Year Ended December 31, 2024, filed on March 27, 2025, of Alvotech (the Company). The Staffs comment is repeated in bold and italics and is followed by the Companys response.

Form 20-F for Fiscal Year Ended December 31, 2024 Note 2.6 Revenue recognition, page F-14 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.

Response: The Company acknowledges the Staffs comment and will revise the notes to its financial statements in future filings to disclose the material terms of each of its material commercial partnership agreements, including the Companys obligations under these agreements, in accordance with IFRS 15.

* * * *

Please do not hesitate to contact me at +354 825 8464 or via e-mail at lindaj@alvotech.com if you have any questions.

Very truly yours,
_/s/__Linda Jonsdottir_____________

Show Raw Text
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July 31, 2025

Via EDGAR

Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences
100 F Street, N.E.
Washington, D.C. 20549-3628

Attention: Tara Harkins
 Lynn Dicker

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

Ladies and Gentlemen:
This letter provides the response to the comment provided by the staff (the
Staff) of the Securities and Exchange Commission in its comment letter dated
July 21, 2025 (the Comment Letter) with respect to Form 20-F for Fiscal Year
Ended December 31, 2024, filed on March 27, 2025, of Alvotech (the Company).
The Staffs comment is repeated in bold and italics and is followed by the
Companys response.

Form 20-F for Fiscal Year Ended December 31, 2024
Note 2.6 Revenue recognition, page F-14
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.

Response: The Company acknowledges the Staffs comment and will revise the notes
to its financial statements in future filings to disclose the material terms of
each of its material commercial partnership agreements, including the Companys
obligations under these agreements, in accordance with IFRS 15.

* * * *

 Please do not hesitate to contact me at +354 825 8464 or via e-mail at
lindaj@alvotech.com if you have any questions.

Very truly yours,

_/s/__Linda Jonsdottir_____________

Linda Jonsdottir
Chief Financial Officer

cc: Robert Wessman, Alvotech
Tanya Zharov, Alvotech
Divakar Gupta, Cooley LLP
Katie Kazem, Cooley LLP

</TEXT>
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