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SEC Comment Letter for Innoviva, Inc. (INVA) (CIK 0001080014) (INVA) — Jul 15, 2015

Innoviva, Inc. (INVA) (CIK 0001080014)
Date: July 15, 2015 · CIK: 0001080014 · Accession: 0000000000-15-036914

AI Filing Summary & Sentiment

File numbers found in text: 000-30319

Date
July 15, 2015
Author
/s/ Daniel Greenspan for
Form
UPLOAD
Company
Innoviva, Inc. (INVA) (CIK 0001080014)

Letter

July 15, 2015 Via E -mail Eric d'Esparbes Senior Vice President & Chief Financial Officer Theravance, Inc. 951 Gateway Blvd. South San Francisco, CA 94080

Re: Theravance, Inc. Form 10-K Filed February 27, 2015 File No. 000-30319

Dear Mr. d'Esparbes :

We have reviewed your filing an d have the following comment . Please respond to this comment within ten busine ss days by providing the requested information or advis e 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.

Business Patents and Proprietary Rights, page 9

1. Please expand your patent related disclosure to provide the following information regarding your material patents:

 Specific products, product groups and technologies to which such patents relate;  Patent expiration da tes;  Identification of applicable jurisdictions outside the U.S.; and  Contested proceedings and/or third -party claims

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing inclu des the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequa cy of the disclosures they have made.

Eric d'Esparbes Theravance, Inc. July 15, 2015 Page 2

In responding to our comments, please provide a written statement from the company acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person u nder the federal securities laws of the United States.

Please contact Christina De Rosa at (202) 551 -3577, Daniel Greenspan at (202) 551 -3623 or me at (202) 551 -3715 with any other questions.

Sincerely,
/s/ Daniel Greenspan for

Show Raw Text
July 15, 2015

Via E -mail
Eric d'Esparbes
Senior Vice President & Chief Financial Officer
Theravance, Inc.
951 Gateway Blvd.
South San Francisco, CA  94080

Re: Theravance, Inc.
 Form 10-K
Filed February 27, 2015
File No. 000-30319

Dear Mr. d'Esparbes :

We have reviewed your filing an d have the following comment .  Please respond to this
comment  within ten busine ss days by providing the requested information or advis e 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.

Business
Patents and Proprietary Rights, page 9

1. Please expand your patent related disclosure to provide the following information
regarding your material patents:

 Specific products, product groups and technologies to which such patents relate;
 Patent expiration da tes;
 Identification of applicable jurisdictions outside the U.S.; and
 Contested proceedings and/or third -party claims

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing inclu des the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequa cy of the disclosures they have made.

Eric d'Esparbes
Theravance, Inc.
July 15, 2015
Page 2

  In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person u nder the federal securities laws of the United States.

Please contact Christina De Rosa at (202) 551 -3577, Daniel Greenspan at (202) 551 -3623
or me at (202) 551 -3715  with any other questions.

Sincerely,

 /s/ Daniel Greenspan for

 Jeffrey P. Riedler
Assistant Director

cc: Via E -mail
 Keith J. Scherer
 Gunderson Dettmer Stough Villeneuve Franklin & Hachigian, LLP
 One Marina Park Drive
 Suite 900
 Boston, MA 02210