SEC Comment Letter 0000000000-24-005864 to Jushi Holdings Inc. (JUSHF) (CIK 0001909747) (JUSHF)
Jushi Holdings Inc. (JUSHF) (CIK 0001909747)
Date: May 21, 2024 · CIK: 0001909747 · Accession: 0000000000-24-005864
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File numbers found in text: 000-56468
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United States securities and exchange commission logo
May 21, 2024
Michelle Mosier
Chief Financial Officer
Jushi Holdings Inc.
301 Yamato Road, Suite 3250
Boca Raton, FL 33431
Re:Jushi Holdings Inc.
Form 10-K for the Year Ended December 31, 2023
Filed April 1, 2024
File No. 000-56468
Dear Michelle Mosier:
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
the 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 10-K for the Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 62
1.Please revise your future filings to address the following, providing your proposed
disclosure in your response:
•Revise your discussion of the fluctuation in your line items to quantify the factors
you identified as the reasons for the changes pursuant to Item 303 of Regulation S-K.
•As part of your response, specifically quantify the factors cited for the changes in
your Revenues and Gross Profit.
•In light of the significant Inventory change adjustments identified in footnote (3) to
your Non-GAAP presentation on page 66, please revise footnote (3) as well as your
MD&A discussion of Gross Profit to quantify and explain each of the items identified
in footnote (3).
•In light of the adjustment for inventory recall reserves, provide us with a rollforward
of your inventory reserves for the periods presented in your Form 10-K, and tell us
FirstName LastNameMichelle Mosier
Comapany NameJushi Holdings Inc.
May 21, 2024 Page 2
FirstName LastName
Michelle Mosier
Jushi Holdings Inc.
May 21, 2024
Page 2
how you considered whether disclosure of such a rollforward was warranted.
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 Jenn Do at 202-551-3743 or Kevin Vaughn at 202-551-3494 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences