SEC Comment Letter 0000000000-24-009192 to ALNYLAM PHARMACEUTICALS, INC. (ALNY)
ALNYLAM PHARMACEUTICALS, INC.
Date: Aug. 12, 2024 · CIK: 0001178670 · Accession: 0000000000-24-009192
AI Filing Summary & Sentiment
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File numbers found in text: 001-36407
Letter
August 12, 2024 Jeffrey Poulton Chief Financial Officer Alnylam Pharmaceuticals, Inc. 675 West Kendall Street Henri A. Termeer Square Cambridge, MA 20142 Re:Alnylam Pharmaceuticals, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 Filed February 15, 2024 File No. 001-36407 Dear Jeffrey Poulton: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2023 Notes to Consolidated Financial Statements 4. Net Revenues from Collaborations, page 107 1.We note your tabular disclosure at the bottom of page 107 that quantifies the research and development (R&D) expenses incurred by collaborator and type that are directly attributable to your collaboration agreements. Please explain to us how this disclosure relates to your net revenues from collaborations. Using the Roche collaboration as an example, your disclosure on page 110 indicates that you recognized collaboration revenue of $24 million during 2023 related to your Development Services Obligation. Please explain how this amount relates to the $44.6 million in total R&D expenses attributed to the Roche collaboration as disclosed on page 107. In addition, to the extent applicable, please explain how the $547 million additional variable consideration attributed to cost reimbursement from development and manufacturing services and technology transfer related to the Roche Performance Obligations was calculated.
August 12, 2024 Page 2 2.Please explain the circumstances that resulted in a reversal of revenue in the amount of $15.5 million related to your Regeneron C5 License Obligation during 2023 as disclosed on page 113. 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 absence of action by the staff. Please contact Frank Wyman at 202-551-3660 or Angela Connell at 202-551-3426 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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August 12, 2024
Jeffrey Poulton
Chief Financial Officer
Alnylam Pharmaceuticals, Inc.
675 West Kendall Street
Henri A. Termeer Square
Cambridge, MA 20142
Re:Alnylam Pharmaceuticals, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Filed February 15, 2024
File No. 001-36407
Dear Jeffrey Poulton:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Notes to Consolidated Financial Statements
4. Net Revenues from Collaborations, page 107
1.We note your tabular disclosure at the bottom of page 107 that quantifies the research and
development (R&D) expenses incurred by collaborator and type that are directly
attributable to your collaboration agreements. Please explain to us how this disclosure
relates to your net revenues from collaborations. Using the Roche collaboration as an
example, your disclosure on page 110 indicates that you recognized collaboration revenue
of $24 million during 2023 related to your Development Services Obligation. Please
explain how this amount relates to the $44.6 million in total R&D expenses attributed to
the Roche collaboration as disclosed on page 107. In addition, to the extent applicable,
please explain how the $547 million additional variable consideration attributed to cost
reimbursement from development and manufacturing services and technology transfer
related to the Roche Performance Obligations was calculated.
August 12, 2024
Page 2
2.Please explain the circumstances that resulted in a reversal of revenue in the amount of
$15.5 million related to your Regeneron C5 License Obligation during 2023 as disclosed
on page 113.
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
absence of action by the staff.
Please contact Frank Wyman at 202-551-3660 or Angela Connell at 202-551-3426 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences