SEC Company Response from INSMED Inc (INSM) (CIK 0001104506) (INSM) — Dec 30, 2020
INSMED Inc (INSM) (CIK 0001104506)
Date: Dec. 30, 2020 · CIK: 0001104506 · Accession: 0001104659-20-140559
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File numbers found in text: 000-30739
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CORRESP
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Via EDGAR
December 30, 2020
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn:
Ms. Jeanne Baker
Mr. Terence O’Brien, Branch Chief
Re:
INSMED Inc
Form 10-K filed February 25, 2020
File No. 000-30739
Ladies and Gentlemen:
Insmed Incorporated (the “Company”)
respectfully submits this letter in response to a letter, dated December 21, 2020, from the staff of the Securities and Exchange
Commission (the “Staff”) commenting on the Company’s Annual Report on Form 10-K filed with the Commission on
February 25, 2020. To facilitate the Staff’s review, we have included in this letter the caption and comment from the Staff’s
letter in bold text and the Company’s response immediately thereafter.
Form 10-K for the fiscal year ended December 31, 2019
Financial Statements
Consolidated Statements of Comprehensive Loss, page 77
1. Please note that since you report amortization of intangible assets outside of cost of product revenue, it is not appropriate
to present a separate caption for gross margin. Refer to SAB Topic 11:B and revise your presentation to either reclassify the applicable
amortization to cost of product revenues or remove the caption gross margin.
Response:
The Company respectfully acknowledges the
Staff’s comment. In response to the Staff’s comment, in future filings, the Company will no longer present a gross
margin caption in its consolidated statements of comprehensive loss.
We acknowledge that we are responsible for
the adequacy and accuracy of the Company’s disclosures, notwithstanding any review, comments, action or absence of action
by the Staff.
700
US Highway 202/206 | Bridgewater, NJ 08807 | Phone: 908-977-9900 | Fax: 908-526-4026
www.insmed.com
Correspondence regarding this letter may
be directed to the attention of the undersigned at sara.bonstein@insmed.com. In addition, you may contact me at (732) 487-7513
or Christine Pellizzari at (732) 487-7366.
Sincerely,
INSMED INCORPORATED
/s/ Sara M. Bonstein
Sara M. Bonstein
Chief Financial Officer
cc: Christine Pellizzari, Insmed Incorporated
Michael J. Riella, Covington & Burling
LLP
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