July 17, 2024
Julie Andrews
Chief Financial Officer
Orthofix Medical Inc.
3451 Plano Parkway
Lewisville, Texas 75056
Re: Orthofix Medical Inc.
Form 10-K For the fiscal year ended December 31, 2023
Filed March 5, 2024
File No. 000-19961
Dear Julie Andrews:
We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.
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.
Form 10-K For the fiscal year ended December 31, 2023
Consolidated Financial Statements
16. Business Segment Information, page F-31
1. Please remove your non-GAAP measure Consolidated adjusted EBITDA from
your
segment footnote, and provide a reconciliation that complies with ASC
280-10-50-
30(b), in future filings. In this regard, please provide a total of your
two reportable
segments' measures of profit and loss and reconcile it to your loss
before income taxes.
Also refer to Rule 10(e)(1)(ii)(C) of Regulation S-K.
2. As a related matter, please remove your non-GAAP measure from the
Segment Review
section in MD&A. In addition, if you elect to present your non-GAAP
measure
Consolidated adjusted EBITDA in your filing, please start your
reconciliation with loss
before income taxes, the GAAP measure, and end the reconciliation with
Consolidated
adjusted EBITDA. Refer to Non-GAAP Financial Measures Compliance &
Disclosure
Interpretations Question 102.10(a).
July 17, 2024
Page 2
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 Michael Fay at 202-551-3812 or Li Xiao at 202-551-4391
with any
questions.
Sincerely,
Division of
Corporation Finance
Office of Industrial
Applications and
Services