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UPLOAD Filing

MANNKIND CORP
Date: June 18, 2025 · CIK: 0000899460 · Accession: 0000000000-25-006437

Revenue Recognition Financial Reporting Regulatory Compliance

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File numbers found in text: 000-50865

Date
June 18, 2025
Author
Division of
Form
UPLOAD
Company
MANNKIND CORP

Letter

Re: MannKind Corporation Form 10-K for the Fiscal Year Ended December 31, 2024 Filed February 26, 2025 File No. 000-50865 Dear Christopher Prentiss:

June 18, 2025

Christopher Prentiss Chief Financial Officer MannKind Corporation 1 Casper Street Danbury, Connecticut 06810

We have reviewed your June 5, 2025 response to our comment letter and have the following comment.

Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our May 16, 2025 letter.

Form 10-K for the Fiscal Year Ended December 31, 2024 Notes to Consolidated Financial Statements 11. Collaborations, Licensing and Other Arrangements, page 94

1. We note your responses to prior comments one and two. Please address the following as it relates to collaboration and services revenue earned under your CSA with UT: Quantify, for each period presented, the portion of revenues earned from product sales to UT on a cost plus margin basis as well as the portion of previously deferred revenue recognized for pre-production activities under the CSA. Describe and quantify the key factors underlying the increase in product sales to UT, including changes in production cost, margin and facility utilization expense and any other variables as referenced in the CSA. Provide a rollforward of your deferred revenue balance, similar to the disclosure provided on page 94, for each performance obligation. June 18, 2025 Page 2

Explain your consideration of providing the disclosures required by ASC 606-10- 50-13 for each of your remaining performance obligations. Disclosure in your December 31, 2023 Form 10-K indicates that the significant increase in deferred revenue during 2023 was primarily related to the capital improvements for the expansion of your manufacturing facility and that you determined that the revenue recognition associated with the capital improvements should be combined with the manufacturing services performance obligation. Clarify how this additional deferred revenue was determined. For example, did UT fund the cost of your facility expansion and if so, how much of your deferred revenue balance relates to such expansion? Provide us with an unredacted copy of the CSA, as amended. Please discuss with staff how to submit such materials.

Please contact Frank Wyman at 202-551-3660 or Angela Connell at 202-551-3426 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Life
Sciences

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<TEXT>
 June 18, 2025

Christopher Prentiss
Chief Financial Officer
MannKind Corporation
1 Casper Street
Danbury, Connecticut 06810

 Re: MannKind Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Filed February 26, 2025
 File No. 000-50865
Dear Christopher Prentiss:

 We have reviewed your June 5, 2025 response to our comment letter and
have the
following comment.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our May 16,
2025 letter.

Form 10-K for the Fiscal Year Ended December 31, 2024
Notes to Consolidated Financial Statements
11. Collaborations, Licensing and Other Arrangements, page 94

1. We note your responses to prior comments one and two. Please address the
following
 as it relates to collaboration and services revenue earned under your
CSA with UT:
 Quantify, for each period presented, the portion of revenues earned
from product
 sales to UT on a cost plus margin basis as well as the portion of
previously
 deferred revenue recognized for pre-production activities under the
CSA.
 Describe and quantify the key factors underlying the increase in
product sales to
 UT, including changes in production cost, margin and facility
utilization expense
 and any other variables as referenced in the CSA.
 Provide a rollforward of your deferred revenue balance, similar to
the disclosure
 provided on page 94, for each performance obligation.
 June 18, 2025
Page 2

 Explain your consideration of providing the disclosures required
by ASC 606-10-
 50-13 for each of your remaining performance obligations.
 Disclosure in your December 31, 2023 Form 10-K indicates that the
significant
 increase in deferred revenue during 2023 was primarily related to
the capital
 improvements for the expansion of your manufacturing facility and
that you
 determined that the revenue recognition associated with the capital
improvements
 should be combined with the manufacturing services performance
obligation.
 Clarify how this additional deferred revenue was determined. For
example, did
 UT fund the cost of your facility expansion and if so, how much of
your deferred
 revenue balance relates to such expansion?
 Provide us with an unredacted copy of the CSA, as amended. Please
discuss with
 staff how to submit such materials.

 Please contact Frank Wyman at 202-551-3660 or Angela Connell at
202-551-3426 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
</TEXT>
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