SEC Comment Letter 0000000000-23-004857 to INDIVIOR PLC (INDV) (CIK 0001625297) (INDV)
INDIVIOR PLC (INDV) (CIK 0001625297)
Date: May 9, 2023 · CIK: 0001625297 · Accession: 0000000000-23-004857
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United States securities and exchange commission logo May 9, 2023 Ryan Preblick Chief Financial Officer Indivior PLC 10710 Midlothian Turnpike, Suite 125 North Chesterfield, Virginia 23235 Re:Indivior PLC Amendment No. 4 to Draft Registration Statement on Form 20-F Submitted April 27, 2023 CIK No. 0001625297 Dear Ryan Preblick: We have reviewed your amended draft registration statement 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 letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 4 to Draft Registration Statement on Form 20-F, submitted April 27, 2023 Glossary, page 2 1.We note your response to comment one. Please refile the Resolution Agreement with Addendum A. OPTN004 - Drinabant Injection for Acute Cannbinoid Overdose ("ACO"), page 83 2.Please revise the royalty range to a ten point range or less and disclose the amounts paid to date, including any up front payments.
FirstName LastNameRyan Preblick Comapany NameIndivior PLC May 9, 2023 Page 2 FirstName LastName Ryan Preblick Indivior PLC May 9, 2023 Page 2 Notes to the Unaudited Condensed Consolidated Interim Financial Statements 16. Acquisition of Opiant, page F-20 3.We note that you accounted for the acquisition of Opiant Pharmaceuticals as an asset acquisition and recognized an intangible asset associated with OPNT003 for $126 million. Please provide us with an analysis supporting your determination that this acquired IPR&D met the definition of an intangible asset under IAS 38. Specifically, explain how you evaluated the technical feasibility of this development product in reaching your conclusion. You may contact Eric Atallah at 202-551-3663 or Angela Connell at 202-551-3426 if you have questions regarding comments on the financial statements and related matters. Please contact Joshua Gorsky at 202-551-7836 or Suzanne Hayes at 202-551-3675 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Michael Levitt, Esq.
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United States securities and exchange commission logo
May 9, 2023
Ryan Preblick
Chief Financial Officer
Indivior PLC
10710 Midlothian Turnpike, Suite 125
North Chesterfield, Virginia 23235
Re:Indivior PLC
Amendment No. 4 to Draft Registration Statement on Form 20-F
Submitted April 27, 2023
CIK No. 0001625297
Dear Ryan Preblick:
We have reviewed your amended draft registration statement 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 letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 4 to Draft Registration Statement on Form 20-F, submitted April 27, 2023
Glossary, page 2
1.We note your response to comment one. Please refile the Resolution Agreement with
Addendum A.
OPTN004 - Drinabant Injection for Acute Cannbinoid Overdose ("ACO"), page 83
2.Please revise the royalty range to a ten point range or less and disclose the amounts paid to
date, including any up front payments.
FirstName LastNameRyan Preblick
Comapany NameIndivior PLC
May 9, 2023 Page 2
FirstName LastName
Ryan Preblick
Indivior PLC
May 9, 2023
Page 2
Notes to the Unaudited Condensed Consolidated Interim Financial Statements
16. Acquisition of Opiant, page F-20
3.We note that you accounted for the acquisition of Opiant Pharmaceuticals as an asset
acquisition and recognized an intangible asset associated with OPNT003 for $126
million. Please provide us with an analysis supporting your determination that this
acquired IPR&D met the definition of an intangible asset under IAS 38. Specifically,
explain how you evaluated the technical feasibility of this development product in
reaching your conclusion.
You may contact Eric Atallah at 202-551-3663 or Angela Connell at 202-551-3426 if you
have questions regarding comments on the financial statements and related matters. Please
contact Joshua Gorsky at 202-551-7836 or Suzanne Hayes at 202-551-3675 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Michael Levitt, Esq.