SEC Comment Letter for GLAUKOS Corp (GKOS) (CIK 0001192448) (GKOS) — Apr 13, 2020
GLAUKOS Corp (GKOS) (CIK 0001192448)
Date: April 13, 2020 · CIK: 0001192448 · Accession: 0000000000-20-003153
AI Filing Summary & Sentiment
File numbers found in text: 001-37463
Letter
April 13, 2020 Joseph Gilliam Chief Financial Officer Glaukos Corporation 229 Avenida Fabricante San Clemente, CA 92672 Re:Glaukos Corporation Form 10-K for the Fiscal Year Ended December 31, 2019 Filed March 2, 2020 File No. 001-37463 Dear Mr. Gilliam: We have reviewed your filing 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 this 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 this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2019 Comparison of Years Ended December 31, 2019 and December 31, 2018 Research and Development Expenses, page 35 1.We note on page 69 that the merger with Avedro was intended to expand your portfolio of pipeline products and on page 4 that you expect your research and development expenses and clinical expenditures to increase. Please revise future filings to provide more detail for your research and development expenses for each period presented, including but not limited to, by product candidates and/or by indications, as well as by the nature of the expenses. To the extent that you do not track expenses by product candidate, please disclose as such. 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.
FirstName LastNameJoseph Gilliam Comapany NameGlaukos Corporation April 13, 2020 Page 2 FirstName LastName Joseph Gilliam Glaukos Corporation April 13, 2020 Page 2 You may contact Tara Harkins at (202) 551-3639 or or Kevin Kuhar, Accounting Branch Chief, at (202) 551-3662 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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April 13, 2020
Joseph Gilliam
Chief Financial Officer
Glaukos Corporation
229 Avenida Fabricante
San Clemente, CA 92672
Re:Glaukos Corporation
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed March 2, 2020
File No. 001-37463
Dear Mr. Gilliam:
We have reviewed your filing 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 this 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 this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Comparison of Years Ended December 31, 2019 and December 31, 2018
Research and Development Expenses, page 35
1.We note on page 69 that the merger with Avedro was intended to expand your portfolio of
pipeline products and on page 4 that you expect your research and development expenses
and clinical expenditures to increase. Please revise future filings to provide more detail for
your research and development expenses for each period presented, including but not
limited to, by product candidates and/or by indications, as well as by the nature of the
expenses. To the extent that you do not track expenses by product candidate, please
disclose as such.
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.
FirstName LastNameJoseph Gilliam
Comapany NameGlaukos Corporation
April 13, 2020 Page 2
FirstName LastName
Joseph Gilliam
Glaukos Corporation
April 13, 2020
Page 2
You may contact Tara Harkins at (202) 551-3639 or or Kevin Kuhar, Accounting Branch
Chief, at (202) 551-3662 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences