SEC Comment Letter for Jazz Pharmaceuticals plc (JAZZ) (CIK 0001232524) (JAZZ) — Nov 8, 2018
Jazz Pharmaceuticals plc (JAZZ) (CIK 0001232524)
Date: Nov. 8, 2018 · CIK: 0001232524 · Accession: 0000000000-18-034891
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File numbers found in text: 001-33500
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November 8, 2018
Bruce Cozadd
Chairman and Chief Executive Officer and Director
Jazz Pharmaceuticals plc
Fifth Floor, Waterloo Exchange
Waterloo Road, Dublin 4, Ireland
Re:Jazz Pharmaceuticals plc
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed February 27, 2018
Form 10-Q for the Quarterly Period Ended September 30, 2018
Filed November 6, 2018
File No. 001-33500
Dear Mr. Cozadd:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we 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-Q for the Quarterly Period Ended September 30, 2018
Notes to Condensed Consolidate Financial Statements
2. Disposition, page 11
1.Please provide us an analysis with reference to authoritative literature supporting your
determination of a $.5 million loss on sale to TerSera of the assets related to Prialt. In
particular, address how you considered the $30 million of payments subject to certain
conditions that may be received in the future and the literature upon which you relied.
FirstName LastNameBruce Cozadd
Comapany NameJazz Pharmaceuticals plc
November 8, 2018 Page 2
FirstName LastName
Bruce Cozadd
Jazz Pharmaceuticals plc
November 8, 2018
Page 2
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.
You may contact Keira Nakada at 202-551-3659 or Jim Rosenberg at 202-551-3679 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance