SEC Comment Letter for VERTEX PHARMACEUTICALS (VRTX) — May 13, 2016
VERTEX PHARMACEUTICALS INC / MA (VRTX) (CIK 0000875320)
Date: May 13, 2016 · CIK: 0000875320 · Accession: 0000000000-16-076290
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-19319
Letter
Mail Stop 4720 May 13 , 2016 VIA E -mail Dr. Jeffrey M. Leiden , M.D., Ph.D. Chairman of the Board, Presid ent and Chief Executive Officer Vertex Pharmaceuticals Incorporated 50 Northern Avenue , Boston, Massachusetts 02210
Re: Vertex Pharmaceuticals Incorporated Form 10-K for Fis cal Year Ended December 31, 2015 Filed February 16 , 2016 File No. 000-19319
Dear Dr. Leiden :
We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within 10 business days by providin g the requ ested information or advise us as soon as possible when you will respond . If you do not believe the comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments .
Notes to Consolidated Financial Statements B. Collaborative Arrangements Variable Interest Entities (VIE) Parion Sciences, Inc., page F -19
1. Please provide us with your detailed analysis as to the application of ASC 810 -10 that resulted in your consolidation of Parion. Include in your response the unredacted agreement with Parion and references to the specific paragraphs of the agreement that result in your consolidation of Parion.
Dr. Jeffrey M. Leiden Vertex Pharmaceuticals Incorporated May 13 , 2016 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 include s the information the Securities Exchange Act of 1934 and all applicable Exchange 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 disclosures they have made.
In responding to our comment, 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 comment or changes to disclosure in response to staff comment do not foreclose the Commission from taking any action with respect to the filing s; and the company may not assert staff comment as a defense in any proceeding initiated by the Commission or any person under the f ederal securities laws of the United States.
You may contact Bonnie Baynes, Staff Accountant, at (202) 551 -4924 if you have any questions regarding the comment . In this regard, do not hesitate to contact me at (202) 551 -3679.
Sincerely,
/s/ Jim B. Rosenberg
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Mail Stop 4720 May 13 , 2016 VIA E -mail Dr. Jeffrey M. Leiden , M.D., Ph.D. Chairman of the Board, Presid ent and Chief Executive Officer Vertex Pharmaceuticals Incorporated 50 Northern Avenue , Boston, Massachusetts 02210 Re: Vertex Pharmaceuticals Incorporated Form 10-K for Fis cal Year Ended December 31, 2015 Filed February 16 , 2016 File No. 000-19319 Dear Dr. Leiden : We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within 10 business days by providin g the requ ested information or advise us as soon as possible when you will respond . If you do not believe the comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments . Notes to Consolidated Financial Statements B. Collaborative Arrangements Variable Interest Entities (VIE) Parion Sciences, Inc., page F -19 1. Please provide us with your detailed analysis as to the application of ASC 810 -10 that resulted in your consolidation of Parion. Include in your response the unredacted agreement with Parion and references to the specific paragraphs of the agreement that result in your consolidation of Parion. Dr. Jeffrey M. Leiden Vertex Pharmaceuticals Incorporated May 13 , 2016 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 include s the information the Securities Exchange Act of 1934 and all applicable Exchange 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 disclosures they have made. In responding to our comment, 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 comment or changes to disclosure in response to staff comment do not foreclose the Commission from taking any action with respect to the filing s; and the company may not assert staff comment as a defense in any proceeding initiated by the Commission or any person under the f ederal securities laws of the United States. You may contact Bonnie Baynes, Staff Accountant, at (202) 551 -4924 if you have any questions regarding the comment . 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 Office of Healthcare and Insurance