June 11, 2025
David R. Bailey
President and Chief Executive Officer
Orthopediatrics Corp
2850 Frontier Drive
Warsaw, Indiana 46582
Re: Orthopediatrics Corp
Form 10-K for the Fiscal Year Ended December 31, 2024
Response Dated June 2, 2025
File No. 001-38242
Dear David R. Bailey:
We have reviewed your 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.
Form 10-K for the Fiscal Year Ended December 31, 2024
Critical Accounting Policies and Significant Judgements and Estimates
Inventory Valuation, page 84
1. We note your response to comment 1. Given the substantial amount of
inventory held
on consignment, please include in future filings your accounting policy
for the
consigned inventory, similarly as provided in your response. Your
disclosure should
include a description of the nature and the expected life of the
consigned inventory,
how its value may or may not be affected by physical deterioration or
obsolescence,
and the process used to evaluate it for obsolescence. In addition,
discuss your long
sale cycle and your business growth in determination of its
classification. Lastly,
consider providing a detailed analysis in Management's Discussion and
Analysis of
the revenue recognized in each period from sales of consigned inventory.
If
substantially all of your sales are made through consignment, disclose
that fact
clearly.
June 11, 2025
Page 2
Please contact Christie Wong at 202-551-3684 or Li Xiao at 202-551-4391
if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of
Corporation Finance
Office of Industrial
Applications and
Services