SEC Comment Letter for REPLIGEN CORP (RGEN) (CIK 0000730272) (RGEN) — Feb 13, 2015
REPLIGEN CORP (RGEN) (CIK 0000730272)
Date: Feb. 13, 2015 · CIK: 0000730272 · Accession: 0000000000-15-009603
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 20, 2015
Letter
February 13, 2015 Via E -mail Mr. Jon Snodgres Chief Financial Officer Repligen Corporation 41 Seyon Street, Building 1, Suite 100 Waltham, MA 82453
Re: Repligen Corporation Form 10-K for Fiscal Year Ended December 31, 2013 Filed March 14, 2013 File No. 000 -14656
Dear Mr. Snodgres :
We have reviewed your respo nse letter dated January 20, 2015 and have the following comments. Please respond to this letter within ten busines s days by amending your filing or by advising us when you will provide the requested response. If you do not believe our comment s apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After rev iewing any amendment to your filing and the information you provide in response to these comment s, we may have additional comments.
Research and Development, page 4
1. We note your response to our prior comment 2. Notwithstanding your confiden tial treatment request for provisions and terms in the HDAC Agreement with BioMarin, we deem information regarding the parties’ rights and obligations, duration of the agreement and termination provisions to be material to investors. Accordingly, please e xpand your proposed disclosure to be included in future filing to provide the parties rights and obligations, duration of the agreement and termination provisions.
2. We note your response to our prior comment 3. Notwithstanding your confidential treatmen t request for cessation provisions of royalties, we deem information relating to the duration of the agreement to be material to investors. Accordingly, please expand your proposed disclosure to be included in future filings to provide the expiration date of the last to expire patent and the “predetermined time” referenced in your disclosure on which the payment of royalties is based.
Mr. Jon Snodgres Repligen Corporation February 13, 2015 Page 2
Patent, License and Proprietary Rights, page 6
3. We note your response to our prior comment 5. Please expand your prop osed disclosure to provide the expected expiration date if your HDAC inhibitors patent application is granted.
You may contact Johnny Gharib at (202) 551 -3170, John Krug at (202) 551 -3862 or me at (202) 551 -3715 with any questions.
Sincerely,
/s/ Bryan J. Pitko for
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February 13, 2015 Via E -mail Mr. Jon Snodgres Chief Financial Officer Repligen Corporation 41 Seyon Street, Building 1, Suite 100 Waltham, MA 82453 Re: Repligen Corporation Form 10-K for Fiscal Year Ended December 31, 2013 Filed March 14, 2013 File No. 000 -14656 Dear Mr. Snodgres : We have reviewed your respo nse letter dated January 20, 2015 and have the following comments. Please respond to this letter within ten busines s days by amending your filing or by advising us when you will provide the requested response. If you do not believe our comment s apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After rev iewing any amendment to your filing and the information you provide in response to these comment s, we may have additional comments. Research and Development, page 4 1. We note your response to our prior comment 2. Notwithstanding your confiden tial treatment request for provisions and terms in the HDAC Agreement with BioMarin, we deem information regarding the parties’ rights and obligations, duration of the agreement and termination provisions to be material to investors. Accordingly, please e xpand your proposed disclosure to be included in future filing to provide the parties rights and obligations, duration of the agreement and termination provisions. 2. We note your response to our prior comment 3. Notwithstanding your confidential treatmen t request for cessation provisions of royalties, we deem information relating to the duration of the agreement to be material to investors. Accordingly, please expand your proposed disclosure to be included in future filings to provide the expiration date of the last to expire patent and the “predetermined time” referenced in your disclosure on which the payment of royalties is based. Mr. Jon Snodgres Repligen Corporation February 13, 2015 Page 2 Patent, License and Proprietary Rights, page 6 3. We note your response to our prior comment 5. Please expand your prop osed disclosure to provide the expected expiration date if your HDAC inhibitors patent application is granted. You may contact Johnny Gharib at (202) 551 -3170, John Krug at (202) 551 -3862 or me at (202) 551 -3715 with any questions. Sincerely, /s/ Bryan J. Pitko for Jeffrey P. Riedler Assistant Director