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SEC Comment Letter for ALNYLAM PHARMACEUTICALS, INC. (ALNY) (CIK 0001178670) (ALNY) — Nov 28, 2017

ALNYLAM PHARMACEUTICALS, INC. (ALNY) (CIK 0001178670)
Date: Nov. 28, 2017 · CIK: 0001178670 · Accession: 0000000000-17-041652

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File numbers found in text: 001-36407

Date
November 27, 2017
Author
Michael P. Mason
Form
UPLOAD
Company
ALNYLAM PHARMACEUTICALS, INC. (ALNY) (CIK 0001178670)

Letter

November 27, 2017 Michael P. Mason Vice President of Finance and Treasurer Alnylam Pharmaceuticals, Inc. 300 Third Street Cambridge, MA 02142 Re:ALNYLAM PHARMACEUTICALS, INC. Form 10-K for the Fiscal Year Ended December 31, 2016 Filed February 15, 2017 File No. 001-36407 Dear Mr. Mason: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 10-K for the Year Ended December 31, 2016 Notes to Consolidated Financial Statements 3. Significant Agreements , page 97 1.For each significant agreement, please provide us a schedule by type and amount of costs incurred included in research and development expenses for the years ended December 31, 2015 and 2016 and for the nine months ended September 30, 2017. Also provide us a similar schedule for general and administrative expenses or confirm that you have not incurred material general and administrative expenses related to your significant agreements. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or

FirstName LastNameMichael P. Mason Comapany NameAlnylam Pharmaceuticals, Inc. June 16, 2017 Page 2 FirstName LastName Michael P. Mason Alnylam Pharmaceuticals, Inc. November 27, 2017 Page 2 absence of action by the staff. You may contact Frank Wyman at 202-551-3660 or Jim Rosenberg at 202-551-3679 with any questions. Division of Corporation Finance Office of Healthcare & Insurance

Show Raw Text
November 27, 2017
Michael P. Mason
Vice President of Finance and Treasurer
Alnylam Pharmaceuticals, Inc.
300 Third Street
Cambridge, MA 02142
Re:ALNYLAM PHARMACEUTICALS, INC.
Form 10-K for the Fiscal Year Ended December 31, 2016
Filed February 15, 2017
File No. 001-36407
Dear Mr. Mason:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to the comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to the comment, we may have additional comments.
Form 10-K for the Year Ended December 31, 2016
Notes to Consolidated Financial Statements
3. Significant Agreements , page 97
1.For each significant agreement, please provide us a schedule by type and amount of costs
incurred included in research and development expenses for the years ended December
31, 2015 and 2016 and for the nine months ended September 30, 2017.  Also provide us a
similar schedule for general and administrative expenses or confirm that you have not
incurred material general and administrative expenses related to your significant
agreements.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or

 FirstName LastNameMichael P. Mason
 Comapany NameAlnylam Pharmaceuticals, Inc.
 June 16, 2017 Page 2
 FirstName LastName
Michael P. Mason
Alnylam Pharmaceuticals, Inc.
November 27, 2017
Page 2
absence of action by the staff.
            You may contact Frank Wyman at 202-551-3660 or Jim Rosenberg at 202-551-3679
with any questions.
Division of Corporation Finance
Office of Healthcare & Insurance