SEC Comment Letter for Jazz Pharmaceuticals plc (JAZZ) (CIK 0001232524) (JAZZ) — Nov 5, 2019
Jazz Pharmaceuticals plc (JAZZ) (CIK 0001232524)
Date: Nov. 5, 2019 · CIK: 0001232524 · Accession: 0000000000-19-015172
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33500
Letter
November 5, 2019 Bruce C. Cozadd Chairman and Chief Executive Officer Jazz Pharmaceuticals plc Fifth Floor, Waterloo Exchange Waterloo Road, Dublin 4 Ireland D04 E5W7 Re:Jazz Pharmaceuticals plc Form 10-K for the Fiscal Year Ended December 31, 2018 Filed February 26, 2019 Form 8-K dated August 6, 2019 File No. 001-33500 Dear Mr. Cozadd: We have limited our review of your filings to the financial statements and related disclosures and have the following comments. Please respond to the 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 the comment, we may have additional comments. Form 8-K dated August 6, 2019 Exhibit 99.1 Reconciliations of GAAP Reported to Non-GAAP Adjusted Information, page 12 1.Your adjustment for upfront and milestone payments does not appear to be consistent with Question 100.01 of the Non-GAAP Compliance and Disclosure Interpretations (C&DI) as such payments would appear to represent normal, recurring cash operating expenses. Please revise your future filings to remove this adjustment or explain to us why it does not violate the C&DI.
FirstName LastNameBruce C. Cozadd Comapany NameJazz Pharmaceuticals plc November 5, 2019 Page 2 FirstName LastName Bruce C. Cozadd Jazz Pharmaceuticals plc November 5, 2019 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 Mary Mast at 202-551-3613 or Angela Connell at 202-551-3426 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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November 5, 2019
Bruce C. Cozadd
Chairman and Chief Executive Officer
Jazz Pharmaceuticals plc
Fifth Floor, Waterloo Exchange
Waterloo Road, Dublin 4
Ireland D04 E5W7
Re:Jazz Pharmaceuticals plc
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed February 26, 2019
Form 8-K dated August 6, 2019
File No. 001-33500
Dear Mr. Cozadd:
We have limited our review of your filings to the financial statements and related
disclosures and have the following comments.
Please respond to the 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 the comment, we may have additional comments.
Form 8-K dated August 6, 2019
Exhibit 99.1
Reconciliations of GAAP Reported to Non-GAAP Adjusted Information, page 12
1.Your adjustment for upfront and milestone payments does not appear to be consistent with
Question 100.01 of the Non-GAAP Compliance and Disclosure Interpretations (C&DI) as
such payments would appear to represent normal, recurring cash operating expenses.
Please revise your future filings to remove this adjustment or explain to us why it does not
violate the C&DI.
FirstName LastNameBruce C. Cozadd
Comapany NameJazz Pharmaceuticals plc
November 5, 2019 Page 2
FirstName LastName
Bruce C. Cozadd
Jazz Pharmaceuticals plc
November 5, 2019
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 Mary Mast at 202-551-3613 or Angela Connell at 202-551-3426 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences