SEC Comment Letter for GSK (GSK) — Nov 9, 2010
GSK plc
Date: Nov. 9, 2010 · CIK: 0001131399 · Accession: 0000000000-10-066952
AI Filing Summary & Sentiment
File numbers found in text: 001-15170
Letter
November 9, 2010 Mr. Julian Heslop Chief Financial Officer GlaxoSmithKline plc 980 Great West Road Brentford, TW8 9GS England
Re: GlaxoSmithKline plc Form 20-F for Fiscal Year Ended December 31, 2009 File No. 001-15170
Dear Mr. Heslop: We have reviewed your September 24, 2010 response to our August 13, 2010 letter and have the following comments. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide this information. Please furnish us a letter on EDGAR under the form type label CORRESP th at keys your responses to our comments. After reviewing the information provided, we may raise additional comments and/or request that you amend your filing.
Research and development, page 15
1. We acknowledge your response of our previo us comment two. Please address the following additional comments: • Please clarify for us whether the “key” proj ects listed in the table on pages 18 and 19 represent all your projects in phase III, registration or recently approved. If not, please provide us revised draft disclosure to clarify how you identify projects as “key” in order to provide context as to why you provide disclosure about these projects versus others. • Although you indicate for various reasons why you believe it may be potentially misleading to investors to provide forw ard-looking information regarding the “possible commercialization of any product,” we do not understand how the disclosure of historical costs incurre d on your significant projects would be speculative or potentially misleading to invest ors. As previously requested, please provide us revised draft di sclosure addressing projects discussed on pages 18 and 19 and pages 189 to 192 to disclose the cost s incurred on each significant project during each period presented and to date. Please incl ude in the draft disclosure a description
Mr. Julian Heslop GlaxoSmithKline plc November 9, 2010 Page 2 of your criteria for deeming a project to be significant. In add ition, for all pipeline projects not considered si gnificant, summarize in the draft disclosure the amounts charged to expense for each period by therapeutic category. • You indicate that you intend to highlight the risks and uncertainties in making estimates of future project costs and inform ation regarding potential future regulatory approval and cash flows by cross-referencing the reader to your risk factor disclosure. Please provide us your proposed revised di sclosure and ensure that you reference specific risk factors instead of pr oviding a general cross-reference. Notes to the financial statements
Note 2: Accounting principles and policies Revenue, page 101 2. We acknowledge your response to our previo us comment seven. Your reference to recognizing revenue when goods are “made ava ilable” to external customers implies the recognition of revenue on bill and hold cont racts. Please provide us revised draft disclosure of your policy to clearly indicate how goods “made available” meets the revenue recognition criteria in paragraph 14 of IAS 18 and paragraph 1 of the Appendix to IAS 18. You may contact Mark Brunhof er, Review Accountant, at (202) 551-3638 if you have questions regarding the comments a nd related matters. In this rega rd, do not hesitate to contact me at (202) 551-3679. Sincerely,
Jim B. Rosenberg Senior Assistant Chief Accountant
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November 9, 2010 Mr. Julian Heslop Chief Financial Officer GlaxoSmithKline plc 980 Great West Road Brentford, TW8 9GS England Re: GlaxoSmithKline plc Form 20-F for Fiscal Year Ended December 31, 2009 File No. 001-15170 Dear Mr. Heslop: We have reviewed your September 24, 2010 response to our August 13, 2010 letter and have the following comments. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide this information. Please furnish us a letter on EDGAR under the form type label CORRESP th at keys your responses to our comments. After reviewing the information provided, we may raise additional comments and/or request that you amend your filing. Research and development, page 15 1. We acknowledge your response of our previo us comment two. Please address the following additional comments: • Please clarify for us whether the “key” proj ects listed in the table on pages 18 and 19 represent all your projects in phase III, registration or recently approved. If not, please provide us revised draft disclosure to clarify how you identify projects as “key” in order to provide context as to why you provide disclosure about these projects versus others. • Although you indicate for various reasons why you believe it may be potentially misleading to investors to provide forw ard-looking information regarding the “possible commercialization of any product,” we do not understand how the disclosure of historical costs incurre d on your significant projects would be speculative or potentially misleading to invest ors. As previously requested, please provide us revised draft di sclosure addressing projects discussed on pages 18 and 19 and pages 189 to 192 to disclose the cost s incurred on each significant project during each period presented and to date. Please incl ude in the draft disclosure a description Mr. Julian Heslop GlaxoSmithKline plc November 9, 2010 Page 2 of your criteria for deeming a project to be significant. In add ition, for all pipeline projects not considered si gnificant, summarize in the draft disclosure the amounts charged to expense for each period by therapeutic category. • You indicate that you intend to highlight the risks and uncertainties in making estimates of future project costs and inform ation regarding potential future regulatory approval and cash flows by cross-referencing the reader to your risk factor disclosure. Please provide us your proposed revised di sclosure and ensure that you reference specific risk factors instead of pr oviding a general cross-reference. Notes to the financial statements Note 2: Accounting principles and policies Revenue, page 101 2. We acknowledge your response to our previo us comment seven. Your reference to recognizing revenue when goods are “made ava ilable” to external customers implies the recognition of revenue on bill and hold cont racts. Please provide us revised draft disclosure of your policy to clearly indicate how goods “made available” meets the revenue recognition criteria in paragraph 14 of IAS 18 and paragraph 1 of the Appendix to IAS 18. You may contact Mark Brunhof er, Review Accountant, at (202) 551-3638 if you have questions regarding the comments a nd related matters. In this rega rd, do not hesitate to contact me at (202) 551-3679. Sincerely, Jim B. Rosenberg Senior Assistant Chief Accountant