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United States securities and exchange commission logo
November 1, 2023
Anat Ashkenazi
Executive Vice President and Chief Financial Officer
Eli Lilly and Company
Lilly Corporate Center
Indianapolis, IN 46285
Re: Eli Lilly and
Company
Form 10-K for the
fiscal year ended December 31, 2022
Response dated
October 26, 2023
File No. 001-06351
Dear Anat Ashkenazi:
We have reviewed your October 26, 2023 response to our comment
letter and have the
following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our September 29, 2023
letter.
Response dated October 26, 2023
Management's Discussion and Analysis of Results of Operations and
Financial Condition, page
37
1. We note your response
to prior comment 1 and re-issue it in part. Please expand your
disclosure to address
how your reputation or brand could be affected by climate change
and the potential
response from investors, lenders, and customers.
2. We note your response
to prior comment 2 stating that you did not experience any
material impacts from
severe weather-related events and re-issue it in part.
Please quantify all
weather-related damages to your property or operations for each of the
years ended December
31, 2022, 2021, and 2020.
Anat Ashkenazi
FirstName LastNameAnat Ashkenazi
Eli Lilly and Company
Comapany 1,
November NameEli
2023 Lilly and Company
November
Page 2 1, 2023 Page 2
FirstName LastName
Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or
Karina
Dorin, Attorney-Adviser, at (202) 551-3763 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Life
Sciences
cc: Donald A. Zakrowski, Senior VP Finance & CAO