SEC Comment Letter for ALNYLAM PHARMACEUTICALS, INC. (ALNY) (CIK 0001178670) (ALNY) — Jan 10, 2018
ALNYLAM PHARMACEUTICALS, INC. (ALNY) (CIK 0001178670)
Date: Jan. 10, 2018 · CIK: 0001178670 · Accession: 0000000000-18-001027
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-36407
Letter
January 8, 2018 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 Fiscal Year Ended December 31, 2016 Filed February 15, 2017 File No. 001-36407 Dear Mr. Mason: We have reviewed your December 11, 2017 response to our comment letter 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. Notes to Consolidated Financial Statements 3. Significant Agreements, page 97 1.We acknowledge the information provided in your response to our prior comment 1 of our November 27, 2017 comment letter. As required by ASC 730-20-50-1b, please confirm to us that you will disclose herein the costs incurred for each of your significant agreements. We would expect the amount disclosed to include the costs you provided in your response and your reasonable estimate of other costs incurred albeit for which you may not track separately for each agreement. In this regard, it would appear that a reasonable estimate would be attainable, given that you track hours incurred for the purpose of billing your counterparties. Finally, we believe additional disclosure in your research and development expense discussion of your MD&A of the nature and amount of research and development costs incurred related to your agreements would be
FirstName LastNameMichael P. Mason Comapany NameAlnylam Pharmaceuticals, Inc. June 16, 2017 Page 2 FirstName LastName Michael P. Mason Alnylam Pharmaceuticals, Inc. January 8, 2018 Page 2 informative. 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
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January 8, 2018
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 Fiscal Year Ended December 31, 2016
Filed February 15, 2017
File No. 001-36407
Dear Mr. Mason:
We have reviewed your December 11, 2017 response to our comment letter 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.
Notes to Consolidated Financial Statements
3. Significant Agreements, page 97
1.We acknowledge the information provided in your response to our prior comment 1 of
our November 27, 2017 comment letter. As required by ASC 730-20-50-1b, please
confirm to us that you will disclose herein the costs incurred for each of your significant
agreements. We would expect the amount disclosed to include the costs you provided in
your response and your reasonable estimate of other costs incurred albeit for which you
may not track separately for each agreement. In this regard, it would appear that a
reasonable estimate would be attainable, given that you track hours incurred for the
purpose of billing your counterparties. Finally, we believe additional disclosure in your
research and development expense discussion of your MD&A of the nature and amount
of research and development costs incurred related to your agreements would be
FirstName LastNameMichael P. Mason
Comapany NameAlnylam Pharmaceuticals, Inc.
June 16, 2017 Page 2
FirstName LastName
Michael P. Mason
Alnylam Pharmaceuticals, Inc.
January 8, 2018
Page 2
informative.
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