SEC Comment Letter for Protalix BioTherapeutics, Inc. (PLX) (CIK 0001006281) (PLX) — Dec 4, 2018
Protalix BioTherapeutics, Inc. (PLX) (CIK 0001006281)
Date: Dec. 4, 2018 · CIK: 0001006281 · Accession: 0000000000-18-037154
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File numbers found in text: 001-33357
Letter
December 4, 2018 Yossi Maimon Chief Financial Officer Protalix BioTherapeutics, Inc. 2 Snunit Street Science Park POB 455 Carmiel, Israel 20100 Re:Protalix BioTherapeutics, Inc. Form 10-K for the Fiscal Year Ended December 31, 2017 Filed March 6, 2018 Form 10-Q for the Quarterly Period Ended September 30, 2018 Filed November 7, 2018 File No. 001-33357 Dear Mr. Maimon: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the 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 the comment, we may have additional comments. Form 10-Q for the Quarterly Period Ended September 30, 2018 Notes to the Consolidated Financial Statements d. Revenue Recognition, page 8 1.You state that the development and manufacturing services for the Chiesi agreements are viewed as a single performance obligation and therefore the upfront payments, future research and development reimbursement payments and any potential additional development milestone payments under each agreement will be deferred until the commencement of commercial manufacturing. Please address the following: •Identify for us each of the promised goods or services in these agreements including the transfers of licenses and explain how you determined that you only had a single
FirstName LastNameYossi Maimon Comapany NameProtalix BioTherapeutics, Inc. December 4, 2018 Page 2 FirstName LastName Yossi Maimon Protalix BioTherapeutics, Inc. December 4, 2018 Page 2 performance obligation under the guidance in ASC 606-10-25-14. •With reference to ASC 606-10-25-23 to 25-26, explain to us why revenue is deferred until commencement of commercial manufacturing and how you considered that you have already transferred the licenses and begun providing development services. •Explain to us whether you intend to recognize revenue over time or at a point in time, and why with reference to ASC 606-10-25-30 or 25-31, as applicable. 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 Mary Mast at (202) 551-3613 or Angela Connell at (202) 551- 3426 with any questions. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance
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December 4, 2018
Yossi Maimon
Chief Financial Officer
Protalix BioTherapeutics, Inc.
2 Snunit Street
Science Park
POB 455
Carmiel, Israel 20100
Re:Protalix BioTherapeutics, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed March 6, 2018
Form 10-Q for the Quarterly Period Ended September 30, 2018
Filed November 7, 2018
File No. 001-33357
Dear Mr. Maimon:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to the 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 the comment, we may have additional comments.
Form 10-Q for the Quarterly Period Ended September 30, 2018
Notes to the Consolidated Financial Statements
d. Revenue Recognition, page 8
1.You state that the development and manufacturing services for the Chiesi agreements
are viewed as a single performance obligation and therefore the upfront payments, future
research and development reimbursement payments and any potential additional
development milestone payments under each agreement will be deferred until the
commencement of commercial manufacturing. Please address the following:
•Identify for us each of the promised goods or services in these agreements including
the transfers of licenses and explain how you determined that you only had a single
FirstName LastNameYossi Maimon
Comapany NameProtalix BioTherapeutics, Inc.
December 4, 2018 Page 2
FirstName LastName
Yossi Maimon
Protalix BioTherapeutics, Inc.
December 4, 2018
Page 2
performance obligation under the guidance in ASC 606-10-25-14.
•With reference to ASC 606-10-25-23 to 25-26, explain to us why revenue is deferred
until commencement of commercial manufacturing and how you considered that you
have already transferred the licenses and begun providing development services.
•Explain to us whether you intend to recognize revenue over time or at a point in time,
and why with reference to ASC 606-10-25-30 or 25-31, as applicable.
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 Mary Mast at (202) 551-3613 or Angela Connell at (202) 551-
3426 with any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance