CORRESP

The measures and reconciliations are presented in groupings that have been specifically requested from the Company’s investors and analysts. The totality of the presentation is meant to supplement the required reconciliations to provide additional detail on our adjustments to enhance investor understanding and be responsive to the requests that the Company receives from analysts and investors. In addition, the Company believes that by presenting the various reconciliations in the concise format that it has employed, it provides investors with all reconciliations in an integrated and clear presentation. As such, we believe this presentation is fully consistent with Staff guidance and SEC rules and regulations regarding the presentation of non-GAAP financial measures.

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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.

Response: The milestone payment relates to an agreement in 2006 pursuant to which Elan Pharmaceuticals sold the rights to Prialt^™ in Europe (prior to Elan’s acquisition by the Company in 2013). Prialt^™ is a non-opioid and non-NSAID analgesic agent used for the management of severe and chronic pain. The agreement provided for three potential milestone payments to Elan upon the achievement of certain net sales thresholds. One such milestone payment of $10.0 million was received in the three months ended July 1, 2023.

The Company exited the business related to this agreement in 2017. Accordingly, we do not consider this amount to be normal or recurring within the meaning of C&DI 100.01 or indicative of the Company’s ongoing operations. A previous milestone payment, which was reported in the fourth quarter of 2017, was similarly excluded from the Company’s adjusted net income in the relevant periods. Moreover, while a single remaining milestone payment under such agreement is possible, the receipt of such payment is uncertain and unlikely to be met, if at all, for many years. As such, we believe the exclusion of this non-recurring gain from adjusted net income to be consistent with Staff guidance, as well as our policy to treat income and gains consistently with expenses and losses when making non-GAAP adjustments.

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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

Response: The Prialt^™ milestone payment was recorded on the Company’s condensed consolidated statement of operations as Other (income) expense, net. In both this line item of the income statement and the corresponding column in Table I of the reconciliations, income is expressed as a negative number, as the net amount is subtracted from Operating Income in the calculation of Income from Continuing Operations. Accordingly, to exclude the milestone payment from adjusted net income, there was a negative adjustment to the Income from Continuing Operations column in Table I and a corresponding positive adjustment to the Interest and Other column. We believe showing this detail in our reconciliations is helpful to investors and enhances their ability to compare our performance over time.

We appreciate the opportunity to address the Staff’s comments. If you have any questions regarding our responses, please contact Eduardo Bezerra, Chief Financial Officer, at eduardo.bezerra@perrigo.com.

Very truly yours,

/s/ Eduardo Bezerra

Eduardo Bezerra

Chief Financial Officer