SEC Comment Letter for AC Immune SA (ACIU) (CIK 0001651625) (ACIU) — Jan 6, 2020
AC Immune SA (ACIU) (CIK 0001651625)
Date: Jan. 6, 2020 · CIK: 0001651625 · Accession: 0000000000-20-000092
AI Filing Summary & Sentiment
File numbers found in text: 001-37891
Letter
January 6, 2020 Joerg Hornstein Chief Financial Officer AC Immune SA EPFL Innovation Park Building B 1015 Lausanne Switzerland Re:AC Immune SA Form 20-F for the Fiscal Year Ended December 31, 2018 Filed April 19, 2019 Form 6-K for the Quarterly Period Ended June 30, 2019 Filed August 14, 2019 File No. 001-37891 Dear Mr. Hornstein: We have reviewed your December 20, 2019 response to our comment letter and have the following comment. In our comment we may ask you to provide us with information so we may better understand your disclosure. Please respond to the 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 the comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 4, 2019 letter. Form 6-K dated August 14, 2019 Exhibit 99.1 Interim Condensed Financial Statements (Unaudited) Notes to Interim Condensed Financial Statements 3.1 Licensing and collaboration agreements, page 13 1.We acknowledge the information provided in your response to comment 1. Please revise your disclosure to include the significant judgments underlying your conclusion that the license granted to Lilly was distinct and represented a right-to-use, as addressed in IFRS
FirstName LastNameJoerg Hornstein Comapany NameAC Immune SA January 6, 2020 Page 2 FirstName LastName Joerg Hornstein AC Immune SA January 6, 2020 Page 2 15.123 and 125. In this regard, consider providing certain information on pages 2-5 of your response, as follows: •The nature of the license granted to Lilly with regard to its ongoing development and future commercialization activities, •The degree to which the Pre-clinical and Phase 1 development activities conducted by you “do not represent integrated services with the licensed IP” to Lilly and the absence of any impact of your R&D activities on the "form or functionality of the underlying IP" licensed to Lilly, •The purpose of Pre-clinical and Phase 1 development activities conducted by Lilly and the absence of any linkage between these activities and your development activities, other than through the joint steering committee and •The nature and frequency of the information-sharing process through the joint steering committee and how this process is expected to impact the future development activities to be independently conducted by you and Lilly. You may contact Ibolya Ignat at (202) 551-3636 or Franklin Wyman at (202) 551-3660 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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January 6, 2020
Joerg Hornstein
Chief Financial Officer
AC Immune SA
EPFL Innovation Park
Building B
1015 Lausanne
Switzerland
Re:AC Immune SA
Form 20-F for the Fiscal Year Ended December 31, 2018
Filed April 19, 2019
Form 6-K for the Quarterly Period Ended June 30, 2019
Filed August 14, 2019
File No. 001-37891
Dear Mr. Hornstein:
We have reviewed your December 20, 2019 response to our comment letter and have the
following comment. In our comment we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to the 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 the comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
December 4, 2019 letter.
Form 6-K dated August 14, 2019
Exhibit 99.1
Interim Condensed Financial Statements (Unaudited)
Notes to Interim Condensed Financial Statements
3.1 Licensing and collaboration agreements, page 13
1.We acknowledge the information provided in your response to comment 1. Please revise
your disclosure to include the significant judgments underlying your conclusion that the
license granted to Lilly was distinct and represented a right-to-use, as addressed in IFRS
FirstName LastNameJoerg Hornstein
Comapany NameAC Immune SA
January 6, 2020 Page 2
FirstName LastName
Joerg Hornstein
AC Immune SA
January 6, 2020
Page 2
15.123 and 125. In this regard, consider providing certain information on pages 2-5 of
your response, as follows:
•The nature of the license granted to Lilly with regard to its ongoing development and
future commercialization activities,
•The degree to which the Pre-clinical and Phase 1 development activities conducted
by you “do not represent integrated services with the licensed IP” to Lilly and the
absence of any impact of your R&D activities on the "form or functionality of the
underlying IP" licensed to Lilly,
•The purpose of Pre-clinical and Phase 1 development activities conducted by Lilly
and the absence of any linkage between these activities and your development
activities, other than through the joint steering committee and
•The nature and frequency of the information-sharing process through the joint
steering committee and how this process is expected to impact the future
development activities to be independently conducted by you and Lilly.
You may contact Ibolya Ignat at (202) 551-3636 or Franklin Wyman at (202) 551-3660
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences