SEC Comment Letter 0000000000-23-011770 to Armata Pharmaceuticals, Inc. (ARMP)
Armata Pharmaceuticals, Inc.
Date: Oct. 26, 2023 · CIK: 0000921114 · Accession: 0000000000-23-011770
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File numbers found in text: 001-37544
Letter
United States securities and exchange commission logo October 26, 2023 Richard Rychlik VP, Corporate Controller Armata Pharmaceuticals, Inc. 5005 McConnell Avenue Los Angeles, CA 90066 Re:Armata Pharmaceuticals, Inc. Form 10-K for the fiscal year ended December 31, 2022 Form 10-Q for the quarterly period ended June 30, 2023 File No. 001-37544 Dear Richard Rychlik: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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. 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 78 1.Given the significance of your research and development (R&D) expenses for the periods presented, please revise your future disclosures to quantify such expenses by product candidate and provide a detailed analysis of the changes therein. To the extent you are unable to track such costs at that level, revise to disclose that fact and identify the reasons why. For all amounts that are not allocated by product candidate, provide a breakdown by type or nature of expense, such that the total reconciles to the research and development line item on the face of your statement of operations.
FirstName LastNameRichard Rychlik Comapany NameArmata Pharmaceuticals, Inc. October 26, 2023 Page 2 FirstName LastName Richard Rychlik Armata Pharmaceuticals, Inc. October 26, 2023 Page 2 Form 10-Q for the quarterly period ended June 30, 2023 Controls and Procedures, page 31 2.You disclose that you did not identify any change in your internal control over financial reporting that occurred during your latest fiscal quarter that has materially affected, or is reasonably likely to materially affect, your internal control over financial reporting, but that because your "evaluation is ongoing and because of its ongoing nature, there can be no assurance that we will not identify any change that would materially affect, or be reasonably likely to materially affect, our internal control over financial reporting." We note this same qualifying language is included in the Form 10-Q for the quarter ended March 31, 2023. Please revise your future disclosures to comply with the the requirements of Item 308(c) of Regulation S-K by providing a clear positive or negative conclusion that omits similar such qualifying language and to clearly disclose any material changes identified. 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. Please contact Jenn Do at 202-551-3743 or Kevin Vaughn at 202-551-3494 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
October 26, 2023
Richard Rychlik
VP, Corporate Controller
Armata Pharmaceuticals, Inc.
5005 McConnell Avenue
Los Angeles, CA 90066
Re:Armata Pharmaceuticals, Inc.
Form 10-K for the fiscal year ended December 31, 2022
Form 10-Q for the quarterly period ended June 30, 2023
File No. 001-37544
Dear Richard Rychlik:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
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.
Form 10-K for the fiscal year ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
74
Results of Operations, page 78
1.Given the significance of your research and development (R&D) expenses for the periods
presented, please revise your future disclosures to quantify such expenses by product
candidate and provide a detailed analysis of the changes therein. To the extent you are
unable to track such costs at that level, revise to disclose that fact and identify the reasons
why. For all amounts that are not allocated by product candidate, provide a breakdown by
type or nature of expense, such that the total reconciles to the research and development
line item on the face of your statement of operations.
FirstName LastNameRichard Rychlik
Comapany NameArmata Pharmaceuticals, Inc.
October 26, 2023 Page 2
FirstName LastName
Richard Rychlik
Armata Pharmaceuticals, Inc.
October 26, 2023
Page 2
Form 10-Q for the quarterly period ended June 30, 2023
Controls and Procedures, page 31
2.You disclose that you did not identify any change in your internal control over financial
reporting that occurred during your latest fiscal quarter that has materially affected, or is
reasonably likely to materially affect, your internal control over financial reporting, but
that because your "evaluation is ongoing and because of its ongoing nature, there can be
no assurance that we will not identify any change that would materially affect, or be
reasonably likely to materially affect, our internal control over financial reporting." We
note this same qualifying language is included in the Form 10-Q for the quarter ended
March 31, 2023. Please revise your future disclosures to comply with the the requirements
of Item 308(c) of Regulation S-K by providing a clear positive or negative conclusion that
omits similar such qualifying language and to clearly disclose any material changes
identified.
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.
Please contact Jenn Do at 202-551-3743 or Kevin Vaughn at 202-551-3494 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences