SEC Comment Letter for ALNYLAM PHARMACEUTICALS, INC. (ALNY) (CIK 0001178670) (ALNY) — Feb 28, 2011
ALNYLAM PHARMACEUTICALS, INC. (ALNY) (CIK 0001178670)
Date: Feb. 28, 2011 · CIK: 0001178670 · Accession: 0000000000-11-012793
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-50743
Letter
Re: Alnylam Pharmaceuticals, Inc. Form 10-K Filed February 26, 2010 File No. 000-50743 Dear Mr. Maraganore: We have reviewed your response letter date d February 18, 2011 and have the following comment. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Proxy Statement on Schedule 14A, filed April 20, 2010
February 28, 2011
John M. Maraganore, Ph.D. Chief Executive Officer Alnylam Pharmaceuticals, Inc. 300 Third Street Cambridge, MA 02142
2009 Annual Incentive Program, page 26
1. We note your response to prior comment 4 a nd your disclosure that the company has not disclosed Ms. Allen’s pe rformance target with resp ect to specified internal operating expense levels under its annual operating plan because the company believes that this information constitutes confidential financial data, the disclosure of which would result in competitive harm to it. However, you have already disclosed your operating expenses in your 2010 10-K filed on February 18, 2011. Please revise your disclosure to include a di scussion of Ms. Allen’s perf ormance target with respect to specified internal operating expense le vels and compare them to the level of operating expenses incurred by the company.
John M. Maraganore, Ph.D. Alnylam Pharmaceuticals, Inc. February 28, 2011 Page 2
You may contact Johnny Gharib at (202) 551-3170 or me at (202) 551-3715 if you have any questions. Sincerely, Jeffrey Riedler Assistant Director
Show Raw Text
February 28, 2011
John M. Maraganore, Ph.D. Chief Executive Officer Alnylam Pharmaceuticals, Inc. 300 Third Street
Cambridge, MA 02142
Re: Alnylam Pharmaceuticals, Inc. Form 10-K
Filed February 26, 2010 File No. 000-50743
Dear Mr. Maraganore:
We have reviewed your response letter date d February 18, 2011 and have the following
comment.
Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to this comment, we may have
additional comments.
Proxy Statement on Schedule 14A, filed April 20, 2010
2009 Annual Incentive Program, page 26
1. We note your response to prior comment 4 a nd your disclosure that the company has
not disclosed Ms. Allen’s pe rformance target with resp ect to specified internal
operating expense levels under its annual operating plan because the company
believes that this information constitutes confidential financial data, the disclosure of which would result in competitive harm to it. However, you have already disclosed your operating expenses in your 2010 10-K filed on February 18, 2011. Please revise
your disclosure to include a di scussion of Ms. Allen’s perf ormance target with respect
to specified internal operating expense le vels and compare them to the level of
operating expenses incurred by the company.
John M. Maraganore, Ph.D. Alnylam Pharmaceuticals, Inc. February 28, 2011 Page 2
You may contact Johnny Gharib at (202) 551-3170 or me at (202) 551-3715 if you have
any questions.
Sincerely,
Jeffrey Riedler
Assistant Director