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UPLOAD Filing

ALNYLAM PHARMACEUTICALS, INC.
Date: May 9, 2025 · CIK: 0001178670 · Accession: 0000000000-25-004975

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File numbers found in text: 001-36407

Date
May 9, 2025
Author
Division of
Form
UPLOAD
Company
ALNYLAM PHARMACEUTICALS, INC.

Letter

Re: Alnylam Pharmaceuticals, Inc. Form 10-K for the fiscal year ended December 31, 2024 Filed February 13, 2025 File No. 001-36407 Dear Gisele Dion:

May 9, 2025

Gisele Dion Chief Accounting Officer Alnylam Pharmaceuticals, Inc. 675 West Kendall Street Henri A. Termeer Square Cambridge, MA 02142

We have limited our review of your filing to the financial statements and related disclosures and have the following comment.

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, 2024 Notes to Consolidated Financial Statements 4. Net Revenues from Collaborations Regeneron Pharmaceuticals, Inc., page 105

1. Please link revenue recognized under the Regeneron collaboration and associated deferred revenue on page 108 to corresponding amounts reported in the financial statements for each period presented. Revise your disclosure accordingly. In addition, provide the following information related to your accounting treatment for the June 2024 Amendment. Explain why the transaction price allocated to the new C5 Monotherapy Obligation was recognized at a point in time, while the transaction price allocated to the legacy C5 License Obligation is recognized over time, given your apparent continuing obligations to support these two licenses. Describe and quantify key assumptions underlying your determination of May 9, 2025 Page 2

standalone selling price of $322,000 for the C5 Monotherapy Obligation, including discount rates, forecasted earnings, duration of the commercial period and adjustments for probability of success. Explain how you determined revenue recognized in 2024 for the Research Services Obligation and C5 License Obligation, particularly expected performance periods, and why no revenue was recognized for the Regeneron Technology Transfer Obligation. Demonstrate that the cumulative catch up adjustment for the remaining Research Services Obligation and C5 License Obligation was not significant.

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 Daniel Gordon at 202-551-3486 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Life
Sciences

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<TEXT>
 May 9, 2025

Gisele Dion
Chief Accounting Officer
Alnylam Pharmaceuticals, Inc.
675 West Kendall Street
Henri A. Termeer Square
Cambridge, MA 02142

 Re: Alnylam Pharmaceuticals, Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 Filed February 13, 2025
 File No. 001-36407
Dear Gisele Dion:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

 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, 2024
Notes to Consolidated Financial Statements
4. Net Revenues from Collaborations
Regeneron Pharmaceuticals, Inc., page 105

1. Please link revenue recognized under the Regeneron collaboration and
associated
 deferred revenue on page 108 to corresponding amounts reported in the
financial
 statements for each period presented. Revise your disclosure
accordingly. In addition,
 provide the following information related to your accounting treatment
for the June
 2024 Amendment.
 Explain why the transaction price allocated to the new C5
Monotherapy
 Obligation was recognized at a point in time, while the transaction
price allocated
 to the legacy C5 License Obligation is recognized over time, given
your apparent
 continuing obligations to support these two licenses.
 Describe and quantify key assumptions underlying your determination
of
 May 9, 2025
Page 2

 standalone selling price of $322,000 for the C5 Monotherapy
Obligation,
 including discount rates, forecasted earnings, duration of the
commercial
 period and adjustments for probability of success.
 Explain how you determined revenue recognized in 2024 for the
Research
 Services Obligation and C5 License Obligation, particularly expected
 performance periods, and why no revenue was recognized for the
Regeneron
 Technology Transfer Obligation.
 Demonstrate that the cumulative catch up adjustment for the
remaining Research
 Services Obligation and C5 License Obligation was not significant.

 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 Daniel Gordon at
202-551-3486
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
</TEXT>
</DOCUMENT>