SEC Comment Letter 0000000000-22-013736 to ImmunityBio, Inc. (IBRX) (CIK 0001326110) (IBRX)
ImmunityBio, Inc. (IBRX) (CIK 0001326110)
Date: Dec. 20, 2022 · CIK: 0001326110 · Accession: 0000000000-22-013736
AI Filing Summary & Sentiment
File numbers found in text: 001-37507
Letter
United States securities and exchange commission logo December 20, 2022 David Sachs Chief Financial Officer ImmunityBio, Inc. 3530 John Hopkins Court San Diego, CA 92121 Re:ImmunityBio, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed March 1, 2022 File No. 001-37507 Dear David Sachs: We have limited our review of your filing to the financial statements and related disclosures 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, 2021 Management's Discussion and Analysis of Financial Conditions and Results of Operations Discussion of Results of Operations Research and Development Expense, page 120 1.You disclose on page 118 that you track outsourced development costs by product candidate or development program, but you do not allocate personnel costs, other internal costs or external consultant costs to specific product candidates or development programs. Please revise your future filings to quantify the research and development costs tracked separately during each period presented for each of your key research and development projects. For example, based on your disclosures on page 120, it appears that you track external costs related to your Anktiva and COVID-19 programs separately. For all other research and development expenses, provide other quantitative or qualitative disclosure that provides more transparency as to the type of research and development expenses incurred (i.e. quantify by nature or type of expense). The total of costs broken
FirstName LastNameDavid Sachs Comapany NameImmunityBio, Inc. December 20, 2022 Page 2 FirstName LastName David Sachs ImmunityBio, Inc. December 20, 2022 Page 2 out should reconcile to total research and development expense on the Statements of Operations. 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 Vanessa Robertson at 202-551-3649 or Kevin Vaughn at 202-551-3494 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
Show Raw Text
United States securities and exchange commission logo
December 20, 2022
David Sachs
Chief Financial Officer
ImmunityBio, Inc.
3530 John Hopkins Court
San Diego, CA 92121
Re:ImmunityBio, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed March 1, 2022
File No. 001-37507
Dear David Sachs:
We have limited our review of your filing to the financial statements and related
disclosures 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, 2021
Management's Discussion and Analysis of Financial Conditions and Results of Operations
Discussion of Results of Operations
Research and Development Expense, page 120
1.You disclose on page 118 that you track outsourced development costs by product
candidate or development program, but you do not allocate personnel costs, other internal
costs or external consultant costs to specific product candidates or development
programs. Please revise your future filings to quantify the research and development costs
tracked separately during each period presented for each of your key research and
development projects. For example, based on your disclosures on page 120, it appears that
you track external costs related to your Anktiva and COVID-19 programs separately. For
all other research and development expenses, provide other quantitative or qualitative
disclosure that provides more transparency as to the type of research and development
expenses incurred (i.e. quantify by nature or type of expense). The total of costs broken
FirstName LastNameDavid Sachs
Comapany NameImmunityBio, Inc.
December 20, 2022 Page 2
FirstName LastName
David Sachs
ImmunityBio, Inc.
December 20, 2022
Page 2
out should reconcile to total research and development expense on the Statements of
Operations.
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 Vanessa Robertson at 202-551-3649 or Kevin Vaughn at 202-551-3494
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences