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SEC Company Response from VERTEX PHARMACEUTICALS (VRTX) — Jul 21, 2009

VERTEX PHARMACEUTICALS INC / MA (VRTX) (CIK 0000875320)
Date: July 21, 2009 · CIK: 0000875320 · Accession: 0001104659-09-044128

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File numbers found in text: 000-19319

Date
July 21, 2009
Author
Kenneth S. Boger
Form
CORRESP
Company
VERTEX PHARMACEUTICALS INC / MA (VRTX) (CIK 0000875320)

Letter

VERTEX PHARMACEUTICALS INCORPORATED

WAVERLY STREET · CAMBRIDGE, MA 02139-4242

TEL. 617.444.6100 · FAX 617.444-6483

http://www.vrtx.com

July 21,

Delivered by EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attn:

Keira Ino, Staff Accountant

Mike Rosenthall, Staff Attorney

Re:

Vertex Pharmaceuticals Incorporated

Form 10-K for the Period Ended December 31, 2008

Form 10-Q for the Quarterly Period Ended March 31, 2009

Definitive Proxy Statement on Schedule 14A filed April 8, 2009

File No. 000-19319

Ladies and Gentlemen:

This letter relates to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to Vertex Pharmaceuticals Incorporated (the “Company”) set forth in the Staff’s letter to the Company, dated July 8, 2009 (the “Comment Letter”), regarding the above referenced Company filings. The Company hereby confirms that the Company has (i) received the Comment Letter and (ii) will file its response to the Comment Letter via EDGAR on or before August 31, 2009. The Company believes that the additional time for the response will ensure that the legal and finance personnel responsible for responding to the Comment Letter, who are also responsible for a number of important Company activities and initiatives during the 30-day period immediately following receipt of the Comment Letter, including a meeting of the Company’s Board of Directors, several ongoing potential transactions and preparation of the Company’s quarterly report on Form 10-Q for the three months ended June 30, 2009 (which is due on August 10, 2009 and will include additional disclosure regarding the Company’s acquisition of ViroChem Pharma, Inc.), will be able to give optimal attention to the Company’s response to the Comment Letter.

In addition, the Company acknowledges that:

1) The Company is responsible for the adequacy and accuracy of the disclosure in its filings;

2) 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

3) 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 me at 617-444-6417 in the event that you have any questions or concerns with respect to this matter. In the event that I am not available, please contact my colleague, Omar White, at 617-444-6396.

Very
truly yours,
/s/
Kenneth S. Boger

Show Raw Text
CORRESP
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filename1.htm

  VERTEX
  PHARMACEUTICALS INCORPORATED

  130
  WAVERLY STREET ·
  CAMBRIDGE, MA 02139-4242

  TEL.
  617.444.6100 · FAX
  617.444-6483

  http://www.vrtx.com

July 21,
2009

Delivered
by EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100 F Street, N.E.

Washington,
DC 20549

  Attn:

  Keira
  Ino, Staff Accountant

  Mike
  Rosenthall, Staff Attorney

  Re:

  Vertex Pharmaceuticals Incorporated

  Form 10-K for the Period Ended December 31, 2008

  Form 10-Q for the Quarterly Period Ended
  March 31, 2009

  Definitive Proxy Statement on Schedule 14A filed
  April 8, 2009

  File
  No. 000-19319

Ladies
and Gentlemen:

This
letter relates to comments from the staff (the “Staff”) of the
Securities and Exchange Commission (the “Commission”) to Vertex
Pharmaceuticals Incorporated (the “Company”) set forth in the Staff’s letter
to the Company, dated July 8, 2009 (the “Comment Letter”),
regarding the above referenced Company filings.
The Company hereby confirms that the Company has (i) received the
Comment Letter and (ii) will file its response to the Comment Letter via
EDGAR on or before August 31, 2009.
The Company believes that the additional time for the response will
ensure that the legal and finance personnel responsible for responding to the
Comment Letter, who are also responsible for a number of important Company
activities and initiatives during the 30-day period immediately following
receipt of the Comment Letter, including a meeting of the Company’s Board of
Directors, several ongoing potential transactions and preparation of the
Company’s quarterly report on Form 10-Q for the three months ended June 30,
2009 (which is due on August 10, 2009 and will include additional
disclosure regarding the Company’s acquisition of ViroChem Pharma, Inc.),
will be able to give optimal attention to the Company’s response to the Comment
Letter.

In
addition, the Company acknowledges that:

1)  The Company is responsible for the adequacy
and accuracy of the disclosure in its filings;

2)  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

3)  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 me at 617-444-6417 in the event that you have any questions or concerns
with respect to this matter.  In the
event that I am not available, please contact my colleague, Omar White, at
617-444-6396.

  Very
  truly yours,

  /s/
  Kenneth S. Boger

  Kenneth
  S. Boger

  Senior
  Vice President and General Counsel

  cc:

  Jim
  B. Rosenberg, Senior Assistant Chief Accountant

  Mark
  Brunhofer, Senior Staff Accountant

  Jennifer
  Riegel, Staff Attorney

2