SEC Comment Letter for INCYTE CORP (INCY) (CIK 0000879169) (INCY) — Mar 25, 2020
INCYTE CORP (INCY) (CIK 0000879169)
Date: March 25, 2020 · CIK: 0000879169 · Accession: 0000000000-20-002622
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File numbers found in text: 001-12400
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March 25, 2020
Christiana Stamoulis
Chief Financial Officer
Incyte Corp
1801 Augustine Cut-Off
Wilmington, DE 19803
Re:Incyte Corp
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed February 13, 2020
File No. 001-12400
Dear Ms. Stamoulis:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Notes to the Consolidated Financial Statements
Note 1. Organization and Summary of Significant Accounting Policies
Milestones and Contract Revenues, page 85
1.Please describe how you recognize milestones earned under collaborative arrangements.
In this regard, tell us how you measure the amounts recognized and determine the period
of recognition. Help us understand your accounting by identifying the currently active
collaborative arrangements under which you may receive milestone payments and
describe your obligations.
Note 4. Concentrations of Credit Risk, page 92
2.We note that you have customers that accounted for at least 10% of total revenues. Please
tell us why you do not name these customers as required by Item 101(c)(1)(vii) of
Regulation S-K.
FirstName LastNameChristiana Stamoulis
Comapany NameIncyte Corp
March 25, 2020 Page 2
FirstName LastName
Christiana Stamoulis
Incyte Corp
March 25, 2020
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Keira Nakada at (202) 551-3659 or Linda Cvrkel at (202) 551-
3813 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services