July 31, 2025
Via EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences
100 F Street, N.E.
Washington, D.C. 20549-3628
Attention: Tara Harkins
Lynn Dicker
Re: Alvotech
Form 20-F for Fiscal Year Ended December 31, 2024
File No. 001-41421
Ladies and Gentlemen:
This letter provides the response to the comment provided by the staff (the
Staff) of the Securities and Exchange Commission in its comment letter dated
July 21, 2025 (the Comment Letter) with respect to Form 20-F for Fiscal Year
Ended December 31, 2024, filed on March 27, 2025, of Alvotech (the Company).
The Staffs comment is repeated in bold and italics and is followed by the
Companys response.
Form 20-F for Fiscal Year Ended December 31, 2024
Note 2.6 Revenue recognition, page F-14
We note your disclosure on pages 74-79 of your commercial partnerships that
include licensing and other components. Please revise the notes to your
financial statements in future filings to disclose the material terms of each of
these arrangements, including your obligations under the agreements in
accordance with IFRS 15.
Response: The Company acknowledges the Staffs comment and will revise the notes
to its financial statements in future filings to disclose the material terms of
each of its material commercial partnership agreements, including the Companys
obligations under these agreements, in accordance with IFRS 15.
* * * *
Please do not hesitate to contact me at +354 825 8464 or via e-mail at
lindaj@alvotech.com if you have any questions.
Very truly yours,
_/s/__Linda Jonsdottir_____________
Linda Jonsdottir
Chief Financial Officer
cc: Robert Wessman, Alvotech
Tanya Zharov, Alvotech
Divakar Gupta, Cooley LLP
Katie Kazem, Cooley LLP