SEC Comment Letter 0000000000-23-003172 to GILEAD SCIENCES, INC. (GILD) (CIK 0000882095) (GILD)
GILEAD SCIENCES, INC. (GILD) (CIK 0000882095)
Date: March 29, 2023 · CIK: 0000882095 · Accession: 0000000000-23-003172
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo March 29, 2023 Andrew Dickinson Chief Financial Officer Gilead Sciences, Inc. 333 Lakeside Drive Foster City, CA 94404 Re:Gilead Sciences, Inc. Form 10-K for the fiscal year ended December 31, 2022 Filed February 22, 2023 File No. 0-19731 Dear Andrew Dickinson: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this comment 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 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. Form 10-K for the fiscal year ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations, page Results of Operations, page 36 1.We note your analysis of research and development expenses on page 38: "Research and development expenses increased by $376 million in 2022 compared to 2021, primarily due to higher clinical development spend related mostly to Trodelvy and the Arcus Biosciences, Inc. (“Arcus”) collaboration, as well as inflationary increases." Given the significance of research and development expenses for the periods presented, please revise your future filings to better disclose the drivers of the changes. As part of your response, disclose the costs incurred during each period presented for each of your key research and development projects. If you do not track your research and development costs by project, please disclose that fact and explain why you do not maintain and evaluate research and development costs by project. Provide other quantitative or qualitative disclosure that provides more transparency as to the type of research and development expenses incurred
FirstName LastNameAndrew Dickinson Comapany NameGilead Sciences, Inc. March 29, 2023 Page 2 FirstName LastName Andrew Dickinson Gilead Sciences, Inc. March 29, 2023 Page 2 (i.e., by nature or type of expense). We note, in this regard, the disclosures provided in your Form 10-K for the year ended December 31, 2020.
In closing, 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 Jenn Do at (202) 551-3743 or Daniel Gordon at (202) 551-3486 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
Show Raw Text
United States securities and exchange commission logo
March 29, 2023
Andrew Dickinson
Chief Financial Officer
Gilead Sciences, Inc.
333 Lakeside Drive
Foster City, CA 94404
Re:Gilead Sciences, Inc.
Form 10-K for the fiscal year ended December 31, 2022
Filed February 22, 2023
File No. 0-19731
Dear Andrew Dickinson:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this comment 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
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.
Form 10-K for the fiscal year ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
34
Results of Operations, page 36
1.We note your analysis of research and development expenses on page 38: "Research and
development expenses increased by $376 million in 2022 compared to 2021, primarily
due to higher clinical development spend related mostly to Trodelvy and the Arcus
Biosciences, Inc. (“Arcus”) collaboration, as well as inflationary increases." Given the
significance of research and development expenses for the periods presented, please revise
your future filings to better disclose the drivers of the changes. As part of your response,
disclose the costs incurred during each period presented for each of your key research and
development projects. If you do not track your research and development costs by project,
please disclose that fact and explain why you do not maintain and evaluate research and
development costs by project. Provide other quantitative or qualitative disclosure that
provides more transparency as to the type of research and development expenses incurred
FirstName LastNameAndrew Dickinson
Comapany NameGilead Sciences, Inc.
March 29, 2023 Page 2
FirstName LastName
Andrew Dickinson
Gilead Sciences, Inc.
March 29, 2023
Page 2
(i.e., by nature or type of expense). We note, in this regard, the disclosures provided in
your Form 10-K for the year ended December 31, 2020.
In closing, 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 Jenn Do at (202) 551-3743 or Daniel Gordon at (202) 551-3486 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences