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SEC Comment Letter for CORCEPT THERAPEUTICS INC (CORT) (CIK 0001088856) (CORT) — Aug 2, 2010

CORCEPT THERAPEUTICS INC (CORT) (CIK 0001088856)
Date: Aug. 2, 2010 · CIK: 0001088856 · Accession: 0000000000-10-043514

Regulatory Compliance Internal Controls Financial Reporting

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
July 30, 2010
Author
Senior Assistant Chief Accountant
Form
UPLOAD
Company
CORCEPT THERAPEUTICS INC (CORT) (CIK 0001088856)

Letter

July 30, 2010 Joseph K. Belanoff Chief Executive Officer Corcept Therapeutics, Inc. 149 Commonwealth Drive Menlo Park, CA 94025

Re: Corcept Therapeutics, Inc. Form 10-K for the Fiscal Year Ended December 31, 2009 Filed March 26, 2010 File No. 0-50679

Dear Mr. Belanoff: We have reviewed your filing and have the following comments. In our comments, we ask you to provide us with information so we may better underst and your disclosure. Please respond to this letter within te n business days by amending your filing or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not be lieve an amendment is appropriate, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your responses to our comments. After reviewing any amendment to your filing and the information you provide in response to these comments, we ma y have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2009

Intellectual Property, page 14

1. Please disclose the expiration date of each of the issued patents that you own. Exhibit 31.1 and 31.2

2. We note that you filed your Principal Executiv e Officer and Principal Financial Officer certification under Item 601(b)(31) of Regulation S-K. Please revise the certification to include the introductory language of paragraph 4 of Item 601(b)(31) of Regulation S-K to include reference to internal controls.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are

Joseph K. Belanoff Corcept Therapeutics, Inc. July 30, 2010 Page 2

in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provi de a written statement from the company acknowledging that: • the company is responsible for the adequacy an d accuracy of the disclo sure 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 under the federa l securities laws of the United States.

Please contact Mary Mast, Sta ff Accountant, at (202) 551-3613 or Joel Parker, Branch Chief, at (202) 551-3651 if you have any questions regarding the processing of your response as well as any questions regarding comments on the fi nancial statements and related matters. You may contact Sebastian Gomez Abero, Staff Attorn ey at (202) 551-3578 with questions on any of the other comments. In this regard, do not hesitate to contact me, at (202) 551-3679.

Sincerely, Jim B. Rosenberg
Senior Assistant Chief Accountant

Show Raw Text
July 30, 2010
 Joseph K. Belanoff Chief Executive Officer Corcept Therapeutics, Inc. 149 Commonwealth Drive
Menlo Park, CA  94025

Re: Corcept Therapeutics, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2009
Filed March 26, 2010 File No. 0-50679

Dear Mr. Belanoff:
 We have reviewed your filing and have the following comments.  In our comments, we
ask you to provide us with information so  we may better underst and your disclosure.
 Please respond to this letter within te n business days by amending your filing or by
advising us when you will provide the requested  response. If you do not believe our comments
apply to your facts and circumstances or do not be lieve an amendment is appropriate, please tell
us why in your response.
  Please furnish us a letter on EDGAR under the form type label
CORRESP that keys your responses to our comments.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
    Form 10-K for the Fiscal Year Ended December 31, 2009

 Intellectual Property, page 14

1. Please disclose the expiration date of each of the issued patents that you own.
 Exhibit 31.1 and 31.2

2. We note that you filed your Principal Executiv e Officer and Principal Financial Officer
certification under Item 601(b)(31)  of Regulation S-K.  Please revise the certification to
include the introductory language of paragraph 4 of Item 601(b)(31) of Regulation S-K to
include reference to internal controls.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are

 Joseph K. Belanoff Corcept Therapeutics, Inc. July 30, 2010 Page 2

in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure 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 under the federa l securities laws of  the United States.

Please contact Mary Mast, Sta ff Accountant, at (202) 551-3613 or Joel Parker, Branch
Chief, at (202) 551-3651 if you have any questions  regarding the processing of your response as
well as any questions regarding comments on the fi nancial statements and related matters.  You
may contact Sebastian Gomez Abero, Staff Attorn ey at (202) 551-3578 with  questions on any of
the other comments.  In this regard, do not  hesitate to contact me, at (202) 551-3679.

Sincerely,    Jim B. Rosenberg
Senior Assistant Chief Accountant