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SEC Comment Letter for CURIS INC (CRIS) (CIK 0001108205) (CRIS) — Dec 7, 2005

CURIS INC (CRIS) (CIK 0001108205)
Date: Dec. 7, 2005 · CIK: 0001108205 · Accession: 0000000000-05-061141

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File numbers found in text: 000-30347

Referenced dates: November 18, 2005

Date
December 7, 2005
Author
Jim B. Rosenberg
Form
UPLOAD
Company
CURIS INC (CRIS) (CIK 0001108205)

Letter

December 7, 2005 Mr. Michael P. Gray Vice President of Finance and Chief Financial Officer Curis, Inc. 61 Moulton Street Cambridge, MA 02138 File No. 000-30347

Re: Curis, Inc. Form 10-K for Fiscal Year Ended December 31, 2004 Form 10-Q for Quarter Ended March 31, 2005

Dear Mr. Gray:

We have reviewed your November 23, 2005 response to our letter dated November 18, 2005, and have the following comments. In our comments, we ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.

Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the year ended December 31, 2003

Genentech Collaboration Accounting 1. Refer to our comment number 3 and your response. Please revise your proposed disclosure to clearly state that if one milestone is not considered substantive, then the remaining milestones would also not be considered substantive.

2. Refer to our comment number 4 and your response. We understood from previous discussions that the steering committee services were considered an obligation during the research and development period, but were considered a right after FDA approval. Please address the following in disclosure-type format:

* Clarify why the steering committee services would not be considered an obligation during the research and development stage for all products developed, not just the two initial products or revise your policy to account for all steering committee services consistently as a separate obligation and deliverable under the contract. * Clarify whether or not a change in estimate for your period of revenue recognition would be made if you entered into new product development which included participation on a steering committee. * Clarify why the steering committee services become a right after FDA approval. * Clarify the term of the steering committee services, any parameters relating to your participation in the steering committee, and whether or not your obligation or participation differs for the initial two products vs. any other products developed during the life of the agreement

* * * *

Please respond to the comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides the requested information. Detailed letters greatly facilitate our review. Please file your letter on EDGAR under the form type label CORRESP.

You may contact Joseph Roesler, Staff Accountant, at (202) 551- 3628 or Mary Mast, Senior Accountant, at (202) 551-3613 if you have questions regarding the 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
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Via Facsimile and U.S. Mail
Mail Stop 6010

December 7, 2005

Mr. Michael P. Gray
Vice President of Finance and
Chief Financial Officer
Curis, Inc.
61 Moulton Street
Cambridge, MA 02138

Re:	Curis, Inc.
		Form 10-K for Fiscal Year Ended December 31, 2004
		Form 10-Q for Quarter Ended March 31, 2005

	File No.  000-30347

Dear Mr. Gray:

	We have reviewed your November 23, 2005 response to our
letter
dated November 18, 2005, and have the following comments.  In our
comments, we ask you to provide us with information so we may
better
understand your disclosure.  After reviewing this information, we
may
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the year ended December 31, 2003

Genentech Collaboration Accounting
1. Refer to our comment number 3 and your response.  Please revise
your proposed disclosure to clearly state that if one milestone is
not considered substantive, then the remaining milestones would
also
not be considered substantive.

2. Refer to our comment number 4 and your response.  We understood
from previous discussions that the steering committee services
were
considered an obligation during the research and development
period,
but were considered a right after FDA approval.  Please address
the
following in disclosure-type format:

* Clarify why the steering committee services would not be
considered
an obligation during the research and development stage for all
products developed, not just the two initial products or revise
your
policy to account for all steering committee services consistently
as
a separate obligation and deliverable under the contract.
* Clarify whether or not a change in estimate for your period of
revenue recognition would be made if you entered into new product
development which included participation on a steering committee.
* Clarify why the steering committee services become a right after
FDA approval.
* Clarify the term of the steering committee services, any
parameters
relating to your participation in the steering committee, and
whether
or not your obligation or participation differs for the initial
two
products vs. any other products developed during the life of the
agreement

*    *    *    *

      	Please respond to the comments within 10 business days
or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides the
requested information.  Detailed letters greatly facilitate our
review.  Please file your letter on EDGAR under the form type
label
CORRESP.

	You may contact Joseph Roesler, Staff Accountant, at (202)
551-
3628 or Mary Mast, Senior Accountant, at (202) 551-3613 if you
have
questions regarding the comments. In this regard, do not hesitate
to
contact me, at (202) 551-3679.

								Sincerely,

								Jim B. Rosenberg
								Senior Assistant Chief
Accountant

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Michael P. Gray
Curis, Inc.
December 7, 2005
Page 2

</TEXT>
</DOCUMENT>