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June 10, 2024
Raul Parra
Chief Financial Officer and Treasurer
MERIT MEDICAL SYSTEMS INC
1600 West Merit Parkway
South Jordan , Utah 84095
Re: MERIT MEDICAL
SYSTEMS INC
Form 10-K for
Fiscal Year Ended December 31, 2023
Filed February 28,
2024
Form 8-K Filed
February 28, 2024
Response Letter
Dated May 24, 2024
File No. 000-18592
Dear Raul Parra:
We have reviewed your May 24, 2024 response to our comment letter
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. Unless
we note otherwise, any references to prior comments are to comments in
our May 13, 2024
letter.
Form 8-K Filed February 28, 2024
Exhibit 99.1
1. We note your response
to our comment letter. Please provide us with a more detailed,
specific description
about the nature of the activities performed by the consultants who
provided services
related to your Foundations for Growth Program. As part of your
detailed description of
the activities performed by the consultants, address why expenses
incurred to optimize
your commercial and manufacturing processes are not related to your
operations and revenue
generating activities. In addition, explain why your use of
consultants for certain
capabilities that you did not maintain internally supports the
corporate
transformation and restructuring adjustments to your non-GAAP performance
measures. In this
regard, Question 100.01 of the Non-GAAP Financial Measures
Raul Parra
MERIT MEDICAL SYSTEMS INC
June 10, 2024
Page 2
Compliance and Disclosure Interpretations states, in part, "[w]hen
evaluating what is a
normal, operating expense, the staff considers the nature and effect
of the non-GAAP
adjustment and how it relates to the company s operations, revenue
generating
activities, business strategy, industry and regulatory environment."
Please contact Tracey Houser at 202-551-3736 or Al Pavot at 202-551-3738
if you have
questions regarding comments on the financial statements and related matters.
Sincerely,
FirstName LastNameRaul Parra
Division of
Corporation Finance
Comapany NameMERIT MEDICAL SYSTEMS INC
Office of
Industrial Applications and
June 10, 2024 Page 2 Services
FirstName LastName