SEC Comment Letter for PHARMION CORP (CIK 0001203866) — Apr 6, 2005
PHARMION CORP (CIK 0001203866)
Date: April 6, 2005 · CIK: 0001203866 · Accession: 0000000000-05-016610
AI Filing Summary & Sentiment
Letter
March 30, 2005 Via U.S. Mail Patrick J. Mahaffy Chief Executive Officer Pharmion Corporation 2525 28th Street, Suite 200 Boulder, Colorado 80301
RE: Pharmion Corporation Form 10-K for the fiscal year ended December 31, 2004 File No. 0-50447
Dear Mr. Mahaffy:
We have limited our review of your Form 10-K to disclosures relating to your contacts with countries that have been identified as state sponsors of terrorism, and will make no further review of the Form 10-K. Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. At this juncture, we are asking you to provide us with supplemental information, so that we may better understand your disclosure. Please be as detailed as necessary in your response. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filings. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
General -
We note that on page 14 of your 10-K you state that your products are marketed in Syria through a third party distribution network. In light of the fact that Syria has been identified by the U.S. State Department as a state sponsor of terrorism, and is subject to economic sanctions administered by the U.S. Treasury Department`s Office of Foreign Assets Control, please describe for us the extent of the sales and marketing activity with respect to your products in Syria, including the dollar amount of such sales; the materiality to the Company of the sale and marketing of Company products in Syria; and your view as to whether the fact that your products are sold and marketed in Syria pursuant to your agreements with third party distributors constitutes a material investment risk for your security holders. In preparing your response please consider that evaluations of materiality should not be based solely on quantitative factors, but should include consideration of all factors, including the potential impact of corporate activities upon a company`s reputation and share value, that a reasonable investor would deem important in making an investment decision.
Closing
Please understand that we may have additional comments after we review your response to our comment. Please contact Jack Guggenheim at (202) 942-7896 if you have any questions about the comment or our review. You may also contact me at (202) 942-7817.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
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<TEXT>
March 30, 2005
Via U.S. Mail
Patrick J. Mahaffy
Chief Executive Officer
Pharmion Corporation
2525 28th Street, Suite 200
Boulder, Colorado 80301
RE: Pharmion Corporation
Form 10-K for the fiscal year ended December 31, 2004
File No. 0-50447
Dear Mr. Mahaffy:
We have limited our review of your Form 10-K to disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and will make no further review of
the
Form 10-K. Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues. At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure. Please be as detailed as necessary in your response.
After reviewing this information, we may or may not raise
additional
comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
General -
We note that on page 14 of your 10-K you state that your products
are
marketed in Syria through a third party distribution network. In
light of the fact that Syria has been identified by the U.S. State
Department as a state sponsor of terrorism, and is subject to
economic sanctions administered by the U.S. Treasury Department`s
Office of Foreign Assets Control, please describe for us the
extent
of the sales and marketing activity with respect to your products
in
Syria, including the dollar amount of such sales; the materiality
to
the Company of the sale and marketing of Company products in
Syria;
and your view as to whether the fact that your products are sold
and
marketed in Syria pursuant to your agreements with third party
distributors constitutes a material investment risk for your
security
holders. In preparing your response please consider that
evaluations
of materiality should not be based solely on quantitative factors,
but should include consideration of all factors, including the
potential impact of corporate activities upon a company`s
reputation
and share value, that a reasonable investor would deem important
in
making an investment decision.
Closing
Please understand that we may have additional comments after
we
review your response to our comment. Please contact Jack
Guggenheim
at (202) 942-7896 if you have any questions about the comment or
our
review. You may also contact me at (202) 942-7817.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
cc: Jeffrey Riedler
Assistant Director
Division of Corporation Finance
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Patrick J. Mahaffy
Pharmion Corporation
March 30, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0507
DIVISION OF
CORPORATION FINANCE
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