United States securities and exchange commission logo
December 7, 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 October 2, 2020 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
September 21, 2020 letter.
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 have carefully
considered your response to prior comment 1 and your revised
disclosures that
gross sales represent the recognition of deferred revenue and amounts
invoiced to customers,
net of cash discounts and returns. Based on this clarification, it
appears that gross
sales is more akin to a billings-type metric. Accordingly, please
revise the title of
this metric so as not to imply that it represents GAAP sales or revenue
and comply with the
metrics guidance set forth in SEC Release No. 33-10751. Please also
clarify for us how the
amount of deferred revenue included in Gross Sales is determined.
In your response,
please include your proposed revisions, including your discussion of this
metric in MD&A.
Hilton Schlosberg
Monster Beverage Corp.
December 7, 2020
Page 2
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
December 7, 2020 Page 2 Office of Manufacturing
FirstName LastName