United States securities and exchange commission logo
May 23, 2024
Matthew Walsh
Chief Financial Officer
Organon & Co.
30 Hudson Street, Floor 33
Jersey City, New Jersey 07302
Re: Organon & Co.
Form 10-K for
Fiscal Year Ended December 31, 2023
Form 8-K filed May
2, 2024
Response dated May
14, 2024
File No. 001-40235
Dear Matthew Walsh:
We have reviewed your May 14, 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 30,
2024 letter.
Matthew Walsh
FirstName
Organon &LastNameMatthew Walsh
Co.
Comapany
May NameOrganon & Co.
23, 2024
May 23,
Page 2 2024 Page 2
FirstName LastName
Form 8-K filed May 2, 2024
Exhibits
1. We note your response to prior comment 2 and the updated presentation
included within
Table 4 of Exhibit 99.1 from the Form 8-K dated May 2, 2024. However,
the updated
presentation continues to include most of the line items and subtotals
found in your GAAP
income statement and adds a measure of gross profit not found in your
Form 10-Q. As
previously requested, please remove this presentation from future
filings or alternatively
explain to us in detail how this presentation complies with the
guidance in Question
102.10(a) and (c) of the C&DIs for Non-GAAP Financial Measures.
Please contact Gary Newberry at 202-551-3761 or Tara Harkins at
202-551-3639 if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of
Corporation Finance
Office of Life
Sciences