SEC Comment Letter for GSK (GSK) — Jan 12, 2011
GSK plc
Date: Jan. 12, 2011 · CIK: 0001131399 · Accession: 0000000000-11-002478
AI Filing Summary & Sentiment
Letter
January 1 2, 2011 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. H eslop : We have reviewed your December 3, 2010 response to our November 9, 2010 comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that key s your response to our comment . After reviewing the information provided, we may raise additional comments and/or request that you amend your filing.
Research and development, page 15 1. Please refer to prior comment one. We acknowledge the assertions provided in your response. However, we continue to believe that historical cost information for research and development projects is meaningful disclosure for investors. Please disclose this information for each of your key R&D projects for each period presented and to date. In addition, please reconcile the total of your key R&D projects costs to total R&D expenses for each period presented. In this regard, please disclose the amounts charged to expense for each period by therapeutic category, or other reasonable category, for all pipeli ne projects not considered key.
Mr. Julian Heslop GlaxoSmithKline plc January 12, 2011 Page 2
You may contact Frank Wyman , Staff Accountant at (202) 551- 3660, or Mark Brunhofer, Account ing Reviewer , at (202) 551- 3638 if you have questions regarding this comment. 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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January 1 2, 2011 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. H eslop : We have reviewed your December 3, 2010 response to our November 9, 2010 comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that key s your response to our comment . After reviewing the information provided, we may raise additional comments and/or request that you amend your filing. Research and development, page 15 1. Please refer to prior comment one. We acknowledge the assertions provided in your response. However, we continue to believe that historical cost information for research and development projects is meaningful disclosure for investors. Please disclose this information for each of your key R&D projects for each period presented and to date. In addition, please reconcile the total of your key R&D projects costs to total R&D expenses for each period presented. In this regard, please disclose the amounts charged to expense for each period by therapeutic category, or other reasonable category, for all pipeli ne projects not considered key. Mr. Julian Heslop GlaxoSmithKline plc January 12, 2011 Page 2 You may contact Frank Wyman , Staff Accountant at (202) 551- 3660, or Mark Brunhofer, Account ing Reviewer , at (202) 551- 3638 if you have questions regarding this comment. In this regard, do not hesitate to contact me, at ( 202) 551- 3679. Sincerely, Jim B. Rosenberg Senior Assistant Chief Accountant