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SEC Comment Letter for PRECIGEN, INC. (PGEN) (CIK 0001356090) (PGEN) — Jun 30, 2015

PRECIGEN, INC. (PGEN) (CIK 0001356090)
Date: June 30, 2015 · CIK: 0001356090 · Accession: 0000000000-15-034236

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
June 30, 2015
Author
/s/ Jim B. Rosenberg for
Form
UPLOAD
Company
PRECIGEN, INC. (PGEN) (CIK 0001356090)

Letter

June 30, 2015 Via E -mail Randal J. Kirk Chief Executive Officer Intrexon Corp. 20374 Sen eca Meadows Parkway Germantown, MD 20876

Re: Intrexon Corp. Form 10-K for the Fiscal Year Ended December 31, 2014 Filed March 2 , 201 5 File No. 1-36042

Dear M r Kirk :

We have reviewed your filing and h ave 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 letter within 10 business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe the comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comment.

After reviewing the information you provide in response to the comment, we may have additional comments and/or request that you amend your filing.

Intellectual Property, page 14

1. We refer to your intellectual property disclosure on page 14. Please expa nd your patent disclosure to provide the following information separately for each of your material patents:  specific products, product groups and technologies to which the patent relates;  whether the patent is owned or licensed from third parties and if licensed, from whom;  type of patent protection such as composition of matter, use or process;  patent expiration date,  jurisdiction; and  contested proceedings and/or third -party claims.

Randal J. Kirk Intrexon Corp. June 30, 2015 Page 2

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the compan y and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In responding to our comment , please provide a written statement from the comp any acknowledging that:  the company is responsible for the adequacy and accuracy of the disclosure in the filing  staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to th e filing; and  the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact Tara Keating Brooks , Staff Attorney, at (202) 551 -8336 or Jeffrey Riedler, Assistant Director, at (202) 5 51-3715 with questions on the comment .

Sincerely,
/s/ Jim B. Rosenberg for

Show Raw Text
June 30, 2015

Via E -mail
Randal  J. Kirk
Chief Executive Officer
Intrexon Corp.
20374 Sen eca Meadows Parkway
Germantown, MD  20876

Re:  Intrexon Corp.
Form 10-K for the Fiscal Year Ended December 31, 2014
Filed March 2 , 201 5
  File No.  1-36042

Dear M r Kirk :

We have reviewed your filing and h ave 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 letter within 10 business days by providing the requested
information or by advising us when you will  provide the requested response.  If you do not
believe the  comment applies to your facts and circumstances, please tell us why in your
response.  Please furnish us a letter on EDGAR under the form type label CORRESP that keys
your response to our comment.

After reviewing the information you provide in response to the comment, we may have
additional comments and/or request that you amend your filing.

Intellectual Property, page 14

1. We refer to your intellectual property disclosure on page 14.  Please expa nd your patent
disclosure to provide the following information separately for each of your material
patents:
 specific products, product groups and technologies to which the patent relates;
 whether the patent is owned or licensed from third parties and if licensed, from
whom;
 type of patent protection such as composition of matter, use or process;
 patent expiration date,
 jurisdiction; and
 contested proceedings and/or third -party claims.

Randal  J. Kirk
Intrexon Corp.
June 30, 2015
Page 2

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing  include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the compan y and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In responding to our comment , please provide a written statement from the comp any
acknowledging that:
 the company is responsible for the adequacy and accuracy of the disclosure in the
filing
 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to th e filing; and
 the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.

Please contact Tara Keating Brooks , Staff Attorney, at (202) 551 -8336  or Jeffrey Riedler,
Assistant Director, at (202) 5 51-3715 with questions on  the comment .

Sincerely,

 /s/ Jim B. Rosenberg for

Jeffrey Riedler
Assistant Director