SEC Comment Letter for Liminal BioSciences Inc. (CIK 0001351172) — Apr 24, 2020
Liminal BioSciences Inc. (CIK 0001351172)
Date: April 24, 2020 · CIK: 0001351172 · Accession: 0000000000-20-003524
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File numbers found in text: 001-39131
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April 24, 2020
Murielle Lortie
Chief Financial Officer
Liminal BioSciences Inc.
440 Armand-Frappier Boulevard, Suite 300
Laval, Qu bec
Canada
H7V 4B4
Re: Liminal BioSciences Inc.
Form 20-F for Fiscal Year Ended December 31, 2019
Filed March 20, 2020
File No. 001-39131
Dear Ms. Lortie:
We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.
After reviewing your response to these comments, we may have additional
comments.
Form 20-F for Fiscal Year Ended December 31, 2019
Independent Auditor's Report, page F-4
1. We note that Ernst & Young LLP conducted their audit of the Company's
consolidated
financial statements for the year ended December 31, 2017 in accordance
with Canadian
generally accepted auditing standards. With reference to Instruction 2 of
Item 8.A.2,
please explain why the audit was not conducted in accordance with the
standards of the
Public Company Accounting Oversight Board (United States).
Note 22- Revenues from Continuing Operations, page F-53
2. We note that you recognized licensing revenues of $19,724 in the third
quarter of 2017
related to an agreement with a third party in China. You terminated this
agreement in
March 2018 due to the third party not remitting funds within the
specified payment terms
Murielle Lortie
Liminal BioSciences Inc.
April 24, 2020
Page 2
and you wrote-off the associated accounts receivable as of December
31, 2017.
With reference to the specific terms of the license agreement and the
appropriate
accounting literature, tell us your basis for recognizing all of
associated revenues in the
third quarter of 2017, including how you determined collection of
consideration was
reasonably assured. If known, tell us why the third party chose not to
remit funds.
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 Tracie Mariner, Staff Accountant, at (202) 551-3744, or
Jeanne Baker,
Staff Accountant, at (202) 551-3691, if you have questions regarding comments
on the financial
statements and related matters.
FirstName LastNameMurielle Lortie Sincerely,
Comapany NameLiminal BioSciences Inc.
Division of
Corporation Finance
April 24, 2020 Page 2 Office of Life
Sciences
FirstName LastName
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