SEC Comment Letter 0000000000-23-010287 to Ocugen, Inc. (OCGN) (CIK 0001372299) (OCGN)
Ocugen, Inc. (OCGN) (CIK 0001372299)
Date: Sept. 19, 2023 · CIK: 0001372299 · Accession: 0000000000-23-010287
AI Filing Summary & Sentiment
File numbers found in text: 001-36751
Letter
United States securities and exchange commission logo September 19, 2023 Shankar Musunuri Chief Executive Officer Ocugen, Inc. 11 Great Valley Parkway Malvern, Pa 19355 Re:Ocugen, Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Filed February 28, 2023 File No. 001-36751 Dear Shankar Musunuri: We have limited our review of your filing to the financial statements and related disclosures 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 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, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations. Research and development expense, page 93 1.We note the statement that you do not currently track research and development expenses on a program-by-program basis for indirect and overhead costs. Please revise future filings to disclose the costs incurred program-by-program for those costs that are tracked. Also revise to provide other quantitative disclosure that provides 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 expense on the Consolidated Statements of Operations for all periods presented.
FirstName LastNameShankar Musunuri Comapany NameOcugen, Inc. September 19, 2023 Page 2 FirstName LastName Shankar Musunuri Ocugen, Inc. September 19, 2023 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 Eric Atallah at (202) 551-3663 or Kevin Kuhar, Accounting Branch Chief, 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
September 19, 2023
Shankar Musunuri
Chief Executive Officer
Ocugen, Inc.
11 Great Valley Parkway
Malvern, Pa 19355
Re:Ocugen, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed February 28, 2023
File No. 001-36751
Dear Shankar Musunuri:
We have limited our review of your filing to the financial statements and related
disclosures 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 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, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations.
Research and development expense, page 93
1.We note the statement that you do not currently track research and development expenses
on a program-by-program basis for indirect and overhead costs. Please revise future
filings to disclose the costs incurred program-by-program for those costs that are tracked.
Also revise to provide other quantitative disclosure that provides 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 expense on the
Consolidated Statements of Operations for all periods presented.
FirstName LastNameShankar Musunuri
Comapany NameOcugen, Inc.
September 19, 2023 Page 2
FirstName LastName
Shankar Musunuri
Ocugen, Inc.
September 19, 2023
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 Eric Atallah at (202) 551-3663 or Kevin Kuhar, Accounting Branch Chief,
at (202) 551-3662 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences