SEC Comment Letter for VERTEX PHARMACEUTICALS (VRTX) — Apr 28, 2015
VERTEX PHARMACEUTICALS INC / MA (VRTX) (CIK 0000875320)
Date: April 28, 2015 · CIK: 0000875320 · Accession: 0000000000-15-023574
AI Filing Summary & Sentiment
Reasoning
Letter
April 28 , 2015 Via E -mail Jeffrey M. Leiden President and Chief Executive Officer Vertex Pharmaceuticals Incorporated 50 Northern Avenue Boston, Massachusetts 02210
Re: Vertex Pharmaceuticals Incorprated Form 10-K for the Fiscal Year Ended December 31 , 2014 Filed February 13, 2015 File No. 000 -19319
Dear Mr. Leiden :
We have reviewed your filing an d have the following comment.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment apply to your facts and circumstances, please tell us why in your response.
After reviewing your response and any amendment you may file in response to this comment , we may have additional comments.
Business Collaborations, pages 7 -8
1. We note your disclosure regarding your 2014 collaboration agreements with BioAxone Biosciences, Inc. and Janssen Pharmaceuticals, Inc. These agreements appe ar material to your busines s. Accordingly, p lease file each of these agreements as exhibits to your annual report as required under Item 601(b)(10) of Regulation S -K.
Jeffrey M. Leiden Vertex Pharmaceuticals Incorporated April 28 , 2015 Page 2
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 Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management ar e in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that :
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure 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 Alla Berenshteyn at (202) 551 -4325 , Dan Greenspan at (202) 551 -3623 or me at (202) 551 -3715 with any quest ions.
Sincerely,
/s/ Daniel Greenspan for
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April 28 , 2015 Via E -mail Jeffrey M. Leiden President and Chief Executive Officer Vertex Pharmaceuticals Incorporated 50 Northern Avenue Boston, Massachusetts 02210 Re: Vertex Pharmaceuticals Incorprated Form 10-K for the Fiscal Year Ended December 31 , 2014 Filed February 13, 2015 File No. 000 -19319 Dear Mr. Leiden : We have reviewed your filing an d have the following comment. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment apply to your facts and circumstances, please tell us why in your response. After reviewing your response and any amendment you may file in response to this comment , we may have additional comments. Business Collaborations, pages 7 -8 1. We note your disclosure regarding your 2014 collaboration agreements with BioAxone Biosciences, Inc. and Janssen Pharmaceuticals, Inc. These agreements appe ar material to your busines s. Accordingly, p lease file each of these agreements as exhibits to your annual report as required under Item 601(b)(10) of Regulation S -K. Jeffrey M. Leiden Vertex Pharmaceuticals Incorporated April 28 , 2015 Page 2 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 Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management ar e in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledging that : the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure 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 Alla Berenshteyn at (202) 551 -4325 , Dan Greenspan at (202) 551 -3623 or me at (202) 551 -3715 with any quest ions. Sincerely, /s/ Daniel Greenspan for Jeffrey P. Riedler Assistant Director