United States securities and exchange commission logo
July 27, 2022
Sanjeev Narula
Chief Financial Officer
Viatris Inc
1000 Mylan Boulevard
Canonsburg, PA 15317
Re: Viatris Inc
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed February 28,
2022
Form 10-Q for the
Quarterly Period ended March 31, 2022
Filed May 9, 2022
File No. 001-39695
Dear Mr. Narula:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment. In our comment, we may ask
you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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 our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 10-Q for the quarterly period ended March 31, 2022
Item 2. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Results of Operations
Total Revenues, page 48
1. You disclose that the
decrease in total revenues and net sales was primarily driven by a
decrease of
approximately $169.7 million in net sales from existing products as a result of
lower pricing and
volumes. Please provide us with proposed disclosure to be included in
future periodic reports
that quantifies the impact of price and volume separately.
Alternatively, we note
in your first quarter 2022 earnings presentation that you quantify
the decrease in net
sales due to competition on key US products and other base business
erosion separately.
Please refer to Item 303(a)(3)(iii) of Regulation S-K.
Sanjeev Narula
Viatris Inc
July 27, 2022
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.
You may contact Vanessa Robertson at 202-551-3649 or Kevin Vaughn at
202-551-3494
with any questions.
FirstName LastNameSanjeev Narula Sincerely,
Comapany NameViatris Inc
Division of
Corporation Finance
July 27, 2022 Page 2 Office of Life
Sciences
FirstName LastName