SEC Comment Letter for REGENERON PHARMACEUTICALS, INC. (REGN) (CIK 0000872589) (REGN) — Mar 23, 2015
REGENERON PHARMACEUTICALS, INC. (REGN) (CIK 0000872589)
Date: March 23, 2015 · CIK: 0000872589 · Accession: 0000000000-15-017174
AI Filing Summary & Sentiment
Letter
March 23 , 2015 Via E -mail Robert E. Landry Senior Vice President of Finance - Chief Financial Officer Regeneron Pharmaceuticals, Inc. 777 Old Saw Mill River Road Tarrytown, New York 10591
Re: Regeneron Pharmaceuticals, Inc. Preliminary Proxy Statement on Schedule 14A Filed March 16, 2015 File No. 000 -19034
Dear Mr. Landry :
We have limited our review of your proxy statement to the issue we have addressed in our comment. Please respond to this letter by amending your proxy statement and providing the requested information . Where you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your proxy statement or your response to our comment , we may have additional comments.
Proposal 4, page 73
1. We note that you have proposed to amend your c ertifica te of incorporation to i ncrease the number of authorized shares of capital stock and common stock . Please amend your proxy statement to disclose whether you have any current plans, arrangements, or understandings to issue any of the shares that would be newly available for issuance following the proposed increase to your authorized shares . If such plans exist, please disclose all material information. If no such plans exist, please revise your discl osure accordingly .
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclos ures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
Robert E. Landry Regeneron Pharmaceuticals , Inc. March 23 , 2015 Page 2
the company is responsible for the adequacy and accuracy of the disclosure in its filing;
staff comments or changes to disclos ures in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States .
Please contact Preston Brewer at (202) 551 -4325 or me at (202) 551 -3715 with any other questions.
Sincerely,
/s/ Bryan J. Pitko for
Show Raw Text
March 23 , 2015 Via E -mail Robert E. Landry Senior Vice President of Finance - Chief Financial Officer Regeneron Pharmaceuticals, Inc. 777 Old Saw Mill River Road Tarrytown, New York 10591 Re: Regeneron Pharmaceuticals, Inc. Preliminary Proxy Statement on Schedule 14A Filed March 16, 2015 File No. 000 -19034 Dear Mr. Landry : We have limited our review of your proxy statement to the issue we have addressed in our comment. Please respond to this letter by amending your proxy statement and providing the requested information . Where you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your proxy statement or your response to our comment , we may have additional comments. Proposal 4, page 73 1. We note that you have proposed to amend your c ertifica te of incorporation to i ncrease the number of authorized shares of capital stock and common stock . Please amend your proxy statement to disclose whether you have any current plans, arrangements, or understandings to issue any of the shares that would be newly available for issuance following the proposed increase to your authorized shares . If such plans exist, please disclose all material information. If no such plans exist, please revise your discl osure accordingly . We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclos ures they have made. In responding to our comments, please provide a written statement from the company acknowledging that: Robert E. Landry Regeneron Pharmaceuticals , Inc. March 23 , 2015 Page 2 the company is responsible for the adequacy and accuracy of the disclosure in its filing; staff comments or changes to disclos ures in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States . Please contact Preston Brewer at (202) 551 -4325 or me at (202) 551 -3715 with any other questions. Sincerely, /s/ Bryan J. Pitko for Jeffrey P. Riedler Assistant Director