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May 13, 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 8, 2024
File No. 000-18592
Dear Raul Parra:
We have reviewed your May 8, 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 April 10,
2024 letter.
Form 8-K Filed February 28, 2024
Exhibit 99.1
1. We note your responses
to comments 1 and 3. Please further explain to us the specific
nature of the
consulting costs incurred for the corporate transformation initiative for each
of the years presented
addressing why these costs are not related to your operations,
revenue generating
activities and business strategy and thus represent normal,
recurring operating
expenses. In this regard, we note your statement that the purpose of
the initiative is to
drive value creation inclusive of optimizing certain commercial
processes such as
product life cycle management and pricing optimization, strengthening
and enhancing the
operating model and organizational structure, enhancing global
manufacturing and
supply chain processes through network consolidation and other
Raul Parra
MERIT MEDICAL SYSTEMS INC
May 13, 2024
Page 2
manufacturing initiatives along with your statement that these costs
do not represent
restructuring activities. We further note your disclosure in your Form
10-Q for the first
quarter of fiscal year 2024 that on February 28, 2024, you introduced
your Continued
Growth Initiatives Program and related financial targets for the
three-year period ending
December 31, 2026, for which you recognized consulting costs of $1
million. Refer
to Question 100.01 of the Non-GAAP Financial Measures Compliance and
Disclosure
Interpretations for guidance.
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
May 13, 2024 Page 2 Services
FirstName LastName