SEC Comment Letter for SIGA TECHNOLOGIES (SIGA) — Jun 17, 2020
SIGA TECHNOLOGIES INC
Date: June 17, 2020 · CIK: 0001010086 · Accession: 0000000000-20-005422
AI Filing Summary & Sentiment
File numbers found in text: 001-38436
Letter
United States securities and exchange commission logo June 17, 2020 Daniel J. Luckshire Executive Vice President and Chief Financial Officer SIGA TECHNOLOGIES INC 31 East 62nd Street New York, NY 10065 Re:SIGA TECHNOLOGIES INC Form 10-K For the Year Ended December 31, 2019 File No. 001-38436 Dear Mr. Luckshire: 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 this 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 this comment, we may have additional comments. Notes to the Consolidated Financial Statements 3. Procurement Contract and Research Agreement, page 56 1.With regards to the various contracts with BARDA where revenue is recognized over time, please provide disclosures for the description of the input or output methods used in the revenue recognition calculation and how they are applied consistent with guidance under ASC 606-10-50-18. For example, we note disclosures stating "...the $3.3 million cumulative catch-up adjustment related to the conclusion of historical rate reconciliation in connection with the IV Formulation R&D Contract and changes in the projected amount of contract funding expected to be available under the IV Formulation R&D Contract, which impacts the progress-towards-completion calculation." The input or output method is however not clear, nor how the method is applied in the calculation. Please provide revised disclosures to be included in future periodic filings to address this matter.
FirstName LastNameDaniel J. Luckshire Comapany NameSIGA TECHNOLOGIES INC June 17, 2020 Page 2 FirstName LastName Daniel J. Luckshire SIGA TECHNOLOGIES INC June 17, 2020 Page 2
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 Christine Allen Torney at 202-551-3652 or Daniel Gordon at 202-551- 3486 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
June 17, 2020
Daniel J. Luckshire
Executive Vice President and Chief Financial Officer
SIGA TECHNOLOGIES INC
31 East 62nd Street
New York, NY 10065
Re:SIGA TECHNOLOGIES INC
Form 10-K
For the Year Ended December 31, 2019
File No. 001-38436
Dear Mr. Luckshire:
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 this 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 this comment, we may have additional comments.
Notes to the Consolidated Financial Statements
3. Procurement Contract and Research Agreement, page 56
1.With regards to the various contracts with BARDA where revenue is recognized over
time, please provide disclosures for the description of the input or output methods used in
the revenue recognition calculation and how they are applied consistent with guidance
under ASC 606-10-50-18. For example, we note disclosures stating "...the $3.3 million
cumulative catch-up adjustment related to the conclusion of historical rate
reconciliation in connection with the IV Formulation R&D Contract and changes in the
projected amount of contract funding expected to be available under the IV Formulation
R&D Contract, which impacts the progress-towards-completion calculation." The input or
output method is however not clear, nor how the method is applied in the calculation.
Please provide revised disclosures to be included in future periodic filings to address this
matter.
FirstName LastNameDaniel J. Luckshire
Comapany NameSIGA TECHNOLOGIES INC
June 17, 2020 Page 2
FirstName LastName
Daniel J. Luckshire
SIGA TECHNOLOGIES INC
June 17, 2020
Page 2
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 Christine Allen Torney at 202-551-3652 or Daniel Gordon at 202-551-
3486 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences