SEC Comment Letter 0000000000-24-006517 to aTYR PHARMA INC (ATYR)
aTYR PHARMA INC
Date: June 6, 2024 · CIK: 0001339970 · Accession: 0000000000-24-006517
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File numbers found in text: 001-37378
Letter
United States securities and exchange commission logo June 6, 2024 Jill Broadfoot Chief Financial Officer aTYR PHARMA INC 10240 Sorrento Valley Road Suite 300 San Diego, CA 92014 Re:aTYR PHARMA INC Form 10-K for Fiscal Year Ended December 31, 2023 File No. 001-37378 Dear Jill Broadfoot: We have limited our review of your filings to the financial statements and related disclosures and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2023 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Research and development expenses, page 68 1.We note from the pipeline table on page 6 that you have multiple products in clinical development for several indications. Please revise future filings to disclose the costs incurred during each period presented for each of your key research and development product candidates. If you do not track your research and development costs by project, disclose that fact and explain why you do not maintain and evaluate research and development costs by project. Also, revise to provide other quantitative and qualitative disclosures that give more transparency as to the type of research and development expenses incurred (i.e., by nature or type of expense) which should reconcile to total research and development expenses on your Statements of Operations.
FirstName LastNameJill Broadfoot Comapany NameaTYR PHARMA INC June 6, 2024 Page 2 FirstName LastName Jill Broadfoot aTYR PHARMA INC June 6, 2024 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. Please contact Lynn Dicker at 202-551-3616 or Kevin Kuhar at 202-551-3662 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
June 6, 2024
Jill Broadfoot
Chief Financial Officer
aTYR PHARMA INC
10240 Sorrento Valley Road
Suite 300
San Diego, CA 92014
Re:aTYR PHARMA INC
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-37378
Dear Jill Broadfoot:
We have limited our review of your filings to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Research and development expenses, page 68
1.We note from the pipeline table on page 6 that you have multiple products in clinical
development for several indications. Please revise future filings to disclose the costs
incurred during each period presented for each of your key research and development
product candidates. If you do not track your research and development costs by project,
disclose that fact and explain why you do not maintain and evaluate research and
development costs by project. Also, revise to provide other quantitative and qualitative
disclosures that give more transparency as to the type of research and development
expenses incurred (i.e., by nature or type of expense) which should reconcile to total
research and development expenses on your Statements of Operations.
FirstName LastNameJill Broadfoot
Comapany NameaTYR PHARMA INC
June 6, 2024 Page 2
FirstName LastName
Jill Broadfoot
aTYR PHARMA INC
June 6, 2024
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.
Please contact Lynn Dicker at 202-551-3616 or Kevin Kuhar at 202-551-3662 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences