Correspondence 0001104659-23-115268 from Armata Pharmaceuticals, Inc. (ARMP)
Armata Pharmaceuticals, Inc.
Date: Nov. 7, 2023 · CIK: 0000921114 · Accession: 0001104659-23-115268
AI Filing Summary & Sentiment
File numbers found in text: 001-37544
Referenced dates: October 26, 2023
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November 7, 2023
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences
100 F Street NE
Washington, D.C. 20549
Attn: Jenn Do and Kevin Vaughn
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 Jenn Do and Kevin Vaughn:
On
behalf of Armata Pharmaceuticals, Inc. (the “Company”), this letter is being submitted in response to the comment letter
dated October 26, 2023 from the staff (the “Staff”) of the Division of Corporation Finance of the Securities &
Exchange Commission, relating to the Company’s Annual Report on Form 10-K for the Fiscal Year Ended December 31,
2022 and Quarterly Report on Form 10-Q for the period ended June 30, 2023.
For your convenience, the
Staff’s comments are repeated below in bold and are followed by the Company’s responses.
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.
Response:
The Company respectfully acknowledges the Staff’s comment and advises the Staff that it plans to provide information about
external R&D expenses, which are allocated by development program, in its future SEC filings in accordance with the
Staff’s comment. Currently the Company does not allocate internal R&D expenses, including personnel related and facilities
and overheads by program, however, the Company will continue to refine allocations with future filings, including personnel and manufacturing costs.
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 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.
Response:
The Company respectfully acknowledges the Staff’s comment and advises the Staff that it plans to make its future disclosures in
accordance with the Staff’s comment to provide a clear positive or negative conclusion that omits any qualifying language, and to
clearly disclose any material changes in the Company’s internal controls over financial reporting identified for each reporting
period.
Thank you for your assistance
in this matter. Please do not hesitate to contact me at 310-665-2928 with any questions or comments regarding this letter.
Sincerely,
/s/ Richard Rychlik
Richard Rychlik
Corporate Controller
(Principal Financial Officer)
cc: Jared Fertman, Willkie Farr & Gallagher LLP
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