SEC Company Response from LIGAND PHARMACEUTICALS INC (LGND, LGNDZ, LGNXZ, LGNYZ, LGNZZ) (CIK 0000886163) (LGND) — Aug 25, 2004
LIGAND PHARMACEUTICALS INC (LGND, LGNDZ, LGNXZ, LGNYZ, LGNZZ) (CIK 0000886163)
Date: Aug. 25, 2004 · CIK: 0000886163 · Accession: 0000936392-04-000836
AI Filing Summary & Sentiment
File numbers found in text: 000-20720
Referenced dates: August 23, 2004
Letter
August 25, 2004 VIA EDGAR Sasha Parikh Staff Accountant United States Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Washington, D.C. 20549
Re: Ligand Pharmaceuticals Incorporated File No. 000-20720 FORM 8-K, FILED AUGUST 3, 2004
Dear Ms. Parikh:
We are in receipt of your letter dated August 23, 2004 with respect to the above-referenced Form 8-K. Simultaneously with the filing of this letter, Ligand is submitting (by EDGAR) Amendment No. 1 (the "Amendment") to Form 8-K, which incorporates the responses to your comments.
Ligand's responses set forth in this letter are numbered to correspond to the numbered comments in your letter. For ease of reference, we have set forth your comments and Ligand's responses below.
COMMENTS:
1. THE EFFECTIVE DATE OF THE DELOITTE & TOUCHE LLP RESIGNATION SHOULD BE CLARIFIED THROUGHOUT THE FILING (E.G. THE FILING DATE OF THE JUNE 30, 2004 FORM 10-Q).
Ligand Response: Ligand has revised the Amendment in accordance with the Staff's comment.
2. FILE AN UPDATED LETTER FROM YOUR FORMER ACCOUNTANT COVERING THE CHANGES MADE IN RESPONSE TO THE ABOVE COMMENT. FILE THAT LETTER AS EXHIBIT 16 TO THE AMENDED FORM 8-K, OR IF NOT AVAILABLE AT THE TIME OF FILING, FILE ANOTHER
<PAGE>
AMENDED FORM 8-K WITHIN TEN BUSINESS DAYS OR WITHIN TWO DAYS OF RECEIPT, WHICHEVER IS EARLIER. SEE RULES 304(A)(3) AND 601(B)(16) OF REGULATION S-K.
Ligand Response: Ligand has filed with the Amendment an updated letter from its former accountant in accordance with the Staff's comment.
3. WHEN YOU FILE YOUR AMENDMENT, ENSURE THAT THE EDGAR HEADER PROPERLY LISTS THE FILING AS AN ITEM 4 FORM 8-K.
Ligand Response: Ligand has filed the Amendment with the appropriate EDGAR header in accordance with the Staff's comment.
* * *
In connection with responding to the Staff's comments to Ligand's Form 8-K filed August 3, 2004, Ligand hereby acknowledges:
1. Ligand is responsible for the adequacy and accuracy of the disclosure in the filings;
2. Staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and
3. Ligand 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.
Thank you for your assistance in this matter. If you have any questions or comments regarding the foregoing, please do not hesitate to contact the undersigned at (858) 550-7830.
Very truly yours,
/s/ Warner R. Broaddus
Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
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<FILENAME>a01513c1corresp.txt
<DESCRIPTION>CORRESPONDENCE
<TEXT>
<PAGE>
[LIGAND LETTERHEAD]
August 25, 2004
VIA EDGAR
Sasha Parikh
Staff Accountant
United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Ligand Pharmaceuticals Incorporated
File No. 000-20720
FORM 8-K, FILED AUGUST 3, 2004
Dear Ms. Parikh:
We are in receipt of your letter dated August 23, 2004 with respect to the
above-referenced Form 8-K. Simultaneously with the filing of this letter, Ligand
is submitting (by EDGAR) Amendment No. 1 (the "Amendment") to Form 8-K, which
incorporates the responses to your comments.
Ligand's responses set forth in this letter are numbered to correspond to
the numbered comments in your letter. For ease of reference, we have set forth
your comments and Ligand's responses below.
COMMENTS:
1. THE EFFECTIVE DATE OF THE DELOITTE & TOUCHE LLP RESIGNATION SHOULD BE
CLARIFIED THROUGHOUT THE FILING (E.G. THE FILING DATE OF THE JUNE 30, 2004 FORM
10-Q).
Ligand Response: Ligand has revised the Amendment in accordance with the
Staff's comment.
2. FILE AN UPDATED LETTER FROM YOUR FORMER ACCOUNTANT COVERING THE CHANGES
MADE IN RESPONSE TO THE ABOVE COMMENT. FILE THAT LETTER AS EXHIBIT 16 TO THE
AMENDED FORM 8-K, OR IF NOT AVAILABLE AT THE TIME OF FILING, FILE ANOTHER
<PAGE>
AMENDED FORM 8-K WITHIN TEN BUSINESS DAYS OR WITHIN TWO DAYS OF RECEIPT,
WHICHEVER IS EARLIER. SEE RULES 304(A)(3) AND 601(B)(16) OF REGULATION S-K.
Ligand Response: Ligand has filed with the Amendment an updated letter from
its former accountant in accordance with the Staff's comment.
3. WHEN YOU FILE YOUR AMENDMENT, ENSURE THAT THE EDGAR HEADER PROPERLY
LISTS THE FILING AS AN ITEM 4 FORM 8-K.
Ligand Response: Ligand has filed the Amendment with the appropriate EDGAR
header in accordance with the Staff's comment.
* * *
In connection with responding to the Staff's comments to Ligand's Form 8-K
filed August 3, 2004, Ligand hereby acknowledges:
1. Ligand is responsible for the adequacy and accuracy of the disclosure in
the filings;
2. Staff comments or changes to disclosure in response to staff comments in
the filings reviewed by the staff do not foreclose the Commission from taking
any action with respect to the filing; and
3. Ligand 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.
Thank you for your assistance in this matter. If you have any questions or
comments regarding the foregoing, please do not hesitate to contact the
undersigned at (858) 550-7830.
Very truly yours,
/s/ Warner R. Broaddus
Warner R. Broaddus
Vice President, General Counsel and Secretary
</TEXT>
</DOCUMENT>