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United States securities and exchange commission logo
June 15, 2022
Heather Pomerantz
Chief Financial Officer
Freshpet, Inc.
400 Plaza Drive, 1st Floor
Secaucus, New Jersey 07094
Re: Freshpet, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Response dated May
31, 2022
File No. 001-36729
Dear Ms. Pomerantz:
We have reviewed your May 31, 2022 response to our comment
letter 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
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this comment, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
May 16, 2022 letter.
Form 10-K for the Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Non-GAAP Financial Measures, page 33
1. We note your response
to comment 1. We continue to believe your non-GAAP
adjustments for
launch expenses and plant start-up expenses represent normal and
recurring operating
expenses necessary to operate your business and are inconsistent with
Question 100.01 of the
Non-GAAP Financial Measures Compliance and Disclosure
Interpretations. Please
revise to remove these adjustments.
Heather Pomerantz
Freshpet, Inc.
June 15, 2022
Page 2
You may contact Heather Clark at 202-551-3624 or Andrew Blume at
202-551-3254 with
any questions.
FirstName LastNameHeather Pomerantz Sincerely,
Comapany NameFreshpet, Inc.
Division of Corporation
Finance
June 15, 2022 Page 2 Office of Manufacturing
FirstName LastName