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United States securities and exchange commission logo
September 21, 2020
Hilton Schlosberg
President & Chief Financial Officer
Monster Beverage Corp.
1 Monster Way
Corona, CA 92879
Re: Monster Beverage
Corp.
Form 10-K for the
Year Ended December 31, 2019
Filed February 28,
2020
File No. 001-18761
Dear Mr. Schlosberg:
We have reviewed your filing 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.
Form 10-K for the Year Ended December 31, 2019
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Non-GAAP Financial Measures, page 48
1. We refer to your
presentation of Gross Sales and note it is not a measure recognized under
GAAP. Please help us
understand:
What Gross Sales
represents. For example, tell us if this amount represents: the
amount invoiced to
your customers, the full retail price of your products, or some
other value;
How you considered
Item 10(e) of Regulation S-K and Regulation G;
How you analyze
trends in the level of Promotional and Other Allowances, aside
from the amount as
percentage of gross sales as disclosed in your filing; and
How Gross Sales is
useful to investors given that gross sales may not be realized in
the form of cash
receipts due to the allowances given to your bottlers/distributors or
retail customers.
We remind you that the
company and its management are responsible for the accuracy
Hilton Schlosberg
Monster Beverage Corp.
September 21, 2020
Page 2
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
You may contact Dale Welcome at 202-551-3865 or Anne McConnell at
202-551-3709 if
you have questions.
FirstName LastNameHilton Schlosberg Sincerely,
Comapany NameMonster Beverage Corp.
Division of
Corporation Finance
September 21, 2020 Page 2 Office of
Manufacturing
FirstName LastName