SEC Comment Letter for VERTEX PHARMACEUTICALS (VRTX) — Oct 19, 2012
VERTEX PHARMACEUTICALS INC / MA (VRTX) (CIK 0000875320)
Date: Oct. 19, 2012 · CIK: 0000875320 · Accession: 0000000000-12-057763
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-19319
Letter
October 19 , 2012 Via E -mail Ian F. Smith Executive V ice President , And Chief Financial Officer Vertex Pharmaceuticals I ncorporated 130 Waverly Street Cambridge, Massachusetts 02139
Re: Vertex Pharmaceuticals Incorporated Form 10-K for the Fiscal Year Ended December 31 , 201 1 Filed February 22, 201 2 Form 10 -Q for the Quarterly Period Ended March 31, 2012 Filed May 10, 2012 File No. 000-19319
Dear Mr. Smith:
We have reviewed your September 17 , 2012 response to our August 20, 2012 letter and have the following comment.
Please respond to this letter within 10 business days by prov iding the requested information or by advising us when you will provide the requ ested response . If you do not believe the comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that key s your responses to our comment.
After reviewin g the information you provide in response to th is comment, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2011 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Results Of O perations Operating Costs and Expenses Cost of product revenues, page 63
1. We do not believe that you have demonstrated that costs incurred for commercial sale or possible commercial sale of product by you or your collaborative partners and not for use in your clinical trials represent research and development expense. In this regard, you have not demonstrated that these costs are excluded from those described in ASC 730 -10-
Ian F. Smith Executive Vice President , And Chief Financial Officer Vertex Pharmaceuticals Incorporated October 19 , 2012 Page 2
15-4.c nor have you demonstrated how these costs are identified with research and development activities described in ASC 730 -10-25-2. Please confirm to us that , in future filings, you will reclassify these costs out of research and development expenses for each period presented and tell us the line item within your statements of operations in which you will clas sify these costs, or tell us why you believe no reclassification is necessary.
Please contact James Peklenk, Staff Accountant, at (202) 551 -3661 or Lisa Vanjoske, Assistant Chief Accountant, at (202) 551 -3614 , if you have any questions regarding the comment s. In this regard, do not hesitate to contact me at (202) 551 -3679.
Sincerely,
/s/ Jim B. Rosenberg
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October 19 , 2012 Via E -mail Ian F. Smith Executive V ice President , And Chief Financial Officer Vertex Pharmaceuticals I ncorporated 130 Waverly Street Cambridge, Massachusetts 02139 Re: Vertex Pharmaceuticals Incorporated Form 10-K for the Fiscal Year Ended December 31 , 201 1 Filed February 22, 201 2 Form 10 -Q for the Quarterly Period Ended March 31, 2012 Filed May 10, 2012 File No. 000-19319 Dear Mr. Smith: We have reviewed your September 17 , 2012 response to our August 20, 2012 letter and have the following comment. Please respond to this letter within 10 business days by prov iding the requested information or by advising us when you will provide the requ ested response . If you do not believe the comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that key s your responses to our comment. After reviewin g the information you provide in response to th is comment, we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 2011 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Results Of O perations Operating Costs and Expenses Cost of product revenues, page 63 1. We do not believe that you have demonstrated that costs incurred for commercial sale or possible commercial sale of product by you or your collaborative partners and not for use in your clinical trials represent research and development expense. In this regard, you have not demonstrated that these costs are excluded from those described in ASC 730 -10- 5 Ian F. Smith Executive Vice President , And Chief Financial Officer Vertex Pharmaceuticals Incorporated October 19 , 2012 Page 2 15-4.c nor have you demonstrated how these costs are identified with research and development activities described in ASC 730 -10-25-2. Please confirm to us that , in future filings, you will reclassify these costs out of research and development expenses for each period presented and tell us the line item within your statements of operations in which you will clas sify these costs, or tell us why you believe no reclassification is necessary. Please contact James Peklenk, Staff Accountant, at (202) 551 -3661 or Lisa Vanjoske, Assistant Chief Accountant, at (202) 551 -3614 , if you have any questions regarding the comment s. In this regard, do not hesitate to contact me at (202) 551 -3679. Sincerely, /s/ Jim B. Rosenberg Jim B. Rosenberg Senior Assistant Chief Accountant