SEC Comment Letter for Alector, Inc. (ALEC) (CIK 0001653087) (ALEC) — Dec 4, 2018
Alector, Inc. (ALEC) (CIK 0001653087)
Date: Dec. 4, 2018 · CIK: 0001653087 · Accession: 0000000000-18-037148
AI Filing Summary & Sentiment
Letter
December 4, 2018 Arnon Rosenthal, Ph.D. Chief Executive Officer Alector, Inc. 151 Oyster Point Boulevard Suite 300 South San Francisco, CA 94080 Re:Alector, Inc. Amendment No. 1 to Draft Registration Statement on Form S-1 Filed November 16, 2018 CIK No. 0001653087 Dear Dr. Rosenthal: 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. Amended Draft Registration Statement Overview, page 1 1.We note your response to comment 3. Please provide context for the research and development pipeline table by including footnotes that set forth a concise but materially complete description of each program. Please also discuss the scope of the research phase and, given the placement of the arrows, the extent to which the programs listed are preparing to transition to the pre-clinical trial phase.
FirstName LastNameArnon Rosenthal, Ph.D. Comapany NameAlector, Inc. December 4, 2018 Page 2 FirstName LastName Arnon Rosenthal, Ph.D. Alector, Inc. December 4, 2018 Page 2 Our Pipeline Program Our PGRN Product Candidates Development Plan, page 104 2.We note your response to comment 1. Please remove the statement that your PGRN product candidates have "demonstrated efficacy in an animal disease model" or explain to us why this statement is appropriate in the context it is made. Notes to Consolidated Financial Statements 2. Summary of Significant Accounting Policies Revenue recognition, page F-10 3.Please refer to your response to comment 13 and disclose the following: •The duration over which the Phase 2 clinical trials are expected to be completed for each program (i.e. AL002, AL003), and •The amounts, by program, of AbbVie's exercise option and the aggregate approval milestones indicating the number of indications covered.. You may contact Keira Nakada at (202) 551-3659 or Jim Rosenberg, Senior Assistant Chief Accountant, at (202) 551-3679 if you have questions regarding comments on the financial statements and related matters. Please contact J. Nolan McWilliams, Attorney-Advisor, at (202) 551-3217 or Dietrich King, Attorney-Advisor, at (202) 551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance cc: Tony Jeffries
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December 4, 2018
Arnon Rosenthal, Ph.D.
Chief Executive Officer
Alector, Inc.
151 Oyster Point Boulevard
Suite 300
South San Francisco, CA 94080
Re:Alector, Inc.
Amendment No. 1 to
Draft Registration Statement on Form S-1
Filed November 16, 2018
CIK No. 0001653087
Dear Dr. Rosenthal:
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.
Amended Draft Registration Statement
Overview, page 1
1.We note your response to comment 3. Please provide context for the research and
development pipeline table by including footnotes that set forth a concise but materially
complete description of each program. Please also discuss the scope of the research phase
and, given the placement of the arrows, the extent to which the programs listed are
preparing to transition to the pre-clinical trial phase.
FirstName LastNameArnon Rosenthal, Ph.D.
Comapany NameAlector, Inc.
December 4, 2018 Page 2
FirstName LastName
Arnon Rosenthal, Ph.D.
Alector, Inc.
December 4, 2018
Page 2
Our Pipeline Program
Our PGRN Product Candidates Development Plan, page 104
2.We note your response to comment 1. Please remove the statement that your PGRN
product candidates have "demonstrated efficacy in an animal disease model" or explain to
us why this statement is appropriate in the context it is made.
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue recognition, page F-10
3.Please refer to your response to comment 13 and disclose the following:
•The duration over which the Phase 2 clinical trials are expected to be completed for
each program (i.e. AL002, AL003), and
•The amounts, by program, of AbbVie's exercise option and the aggregate approval
milestones indicating the number of indications covered..
You may contact Keira Nakada at (202) 551-3659 or Jim Rosenberg, Senior
Assistant Chief Accountant, at (202) 551-3679 if you have questions regarding comments on the
financial statements and related matters. Please contact J. Nolan McWilliams, Attorney-Advisor,
at (202) 551-3217 or Dietrich King, Attorney-Advisor, at (202) 551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Tony Jeffries