TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo August 17, 2023 Eduardo Bezerra Chief Financial Officer PERRIGO Co plc The Sharp Building, Hogan Place Dublin 2 Ireland D02 TY74 Re: PERRIGO Co plc Form 10-K for the Year Ended December 31, 2022 Filed February 28, 2023 Form 8-K Filed August 8, 2023 File No. 001-36353 Dear Eduardo Bezerra: 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 the 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 the comment, we may have additional comments. Form 8-K dated August 8, 2023 Reconciliation of Non-GAAP Measures, page 13 1. Your reconciliation of Non-GAAP measures includes several line items and subtotals from the Statement of Operations. Please address the following: Tell us why you believe your presentation is consistent with C&DI 102.10(a) and 102.10(c). Tell us the nature of the $10.0 million milestone payments received related to royalty rights adjustment and why you believe the adjustment is consistent with C&DI 100.01. Tell us why the $10.0 million adjustment is added in the Interest and Other column but subtracted in the Income from Continuing Operations column. Eduardo Bezerra PERRIGO Co plc August 17, 2023 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 Mary Mast at (202) 551-3613 or Dan Gordon at (202) 551-3486 with any questions. FirstName LastNameEduardo Bezerra Sincerely, Comapany NamePERRIGO Co plc Division of Corporation Finance August 17, 2023 Page 2 Office of Life Sciences FirstName LastName