SEC Comment Letter for Protalix BioTherapeutics, Inc. (PLX) (CIK 0001006281) (PLX) — Jun 23, 2022
Protalix BioTherapeutics, Inc. (PLX) (CIK 0001006281)
Date: June 23, 2022 · CIK: 0001006281 · Accession: 0000000000-22-006794
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File numbers found in text: 001-33357
Letter
United States securities and exchange commission logo June 23, 2022 Eyal Rubin Senior Vice President and Chief Financial Officer Protalix BioTherapeutics, Inc. 2 University Plaza, Suite 100 Hackensack, NJ 07601 Re:Protalix BioTherapeutics, Inc. Form 10-K for the Year Ended December 31, 2021 Filed March 31, 2022 File No. 001-33357 Dear Mr. Rubin: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Year Ended December 31, 2021 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 1.You disclose on page 64 that you currently do not record and maintain research and development costs per project. You also disclose on page 66 that the decrease in your research and development expense was primarily due to the completion of the three phase III clinical trials of PRX-102. Please revise your future filings to provide a quantified breakdown of research and development costs by nature of expense for each period presented. As part of your breakdown, separately identify the amount of cost reimbursement netted against such expenses. Please provide us with an example of your proposed disclosure in your response. 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
FirstName LastNameEyal Rubin Comapany NameProtalix BioTherapeutics, Inc. June 23, 2022 Page 2 FirstName LastName Eyal Rubin Protalix BioTherapeutics, Inc. June 23, 2022 Page 2 absence of action by the staff. You may contact Tracie Mariner, Staff Accountant, at (202) 551-3744 or Kevin Vaughn, Branch Chief, 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
June 23, 2022
Eyal Rubin
Senior Vice President and Chief Financial Officer
Protalix BioTherapeutics, Inc.
2 University Plaza, Suite 100
Hackensack, NJ 07601
Re:Protalix BioTherapeutics, Inc.
Form 10-K for the Year Ended December 31, 2021
Filed March 31, 2022
File No. 001-33357
Dear Mr. Rubin:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
60
1.You disclose on page 64 that you currently do not record and maintain research and
development costs per project. You also disclose on page 66 that the decrease in your
research and development expense was primarily due to the completion of the three phase
III clinical trials of PRX-102. Please revise your future filings to provide a quantified
breakdown of research and development costs by nature of expense for each period
presented. As part of your breakdown, separately identify the amount of cost
reimbursement netted against such expenses. Please provide us with an example of your
proposed disclosure in your response.
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
FirstName LastNameEyal Rubin
Comapany NameProtalix BioTherapeutics, Inc.
June 23, 2022 Page 2
FirstName LastName
Eyal Rubin
Protalix BioTherapeutics, Inc.
June 23, 2022
Page 2
absence of action by the staff.
You may contact Tracie Mariner, Staff Accountant, at (202) 551-3744 or Kevin Vaughn,
Branch Chief, at (202) 551-3494 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences