SEC Comment Letter for Alector, Inc. (ALEC) (CIK 0001653087) (ALEC) — Dec 20, 2018
Alector, Inc. (ALEC) (CIK 0001653087)
Date: Dec. 20, 2018 · CIK: 0001653087 · Accession: 0000000000-18-038840
AI Filing Summary & Sentiment
Letter
December 20, 2018 Arnon Rosenthal, Ph.D. Chief Executive Officer Alector, Inc. 151 Oyster Point Boulevard Suite 300 South San Francisco, CA 94080 Re:Alector, Inc. Draft Registration Statement on Form S-1 Response Dated December 17, 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. Response Dated December 17, 2018 Notes to Consolidated Financial Statements 2. Summary of Significant Accounting Policies Revenue recognition, page F-10 1.Please revise the disclosure you proposed in response to comment 3 with respect to the $242.8 million of milestones per program to describe the triggering events and to state whether it includes multiple indications and, if so, the number of indications. 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
FirstName LastNameArnon Rosenthal, Ph.D. Comapany NameAlector, Inc. December 20, 2018 Page 2 FirstName LastName Arnon Rosenthal, Ph.D. Alector, Inc. December 20, 2018 Page 2 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 20, 2018
Arnon Rosenthal, Ph.D.
Chief Executive Officer
Alector, Inc.
151 Oyster Point Boulevard
Suite 300
South San Francisco, CA 94080
Re:Alector, Inc.
Draft Registration Statement on Form S-1
Response Dated December 17, 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.
Response Dated December 17, 2018
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue recognition, page F-10
1.Please revise the disclosure you proposed in response to comment 3 with respect to the
$242.8 million of milestones per program to describe the triggering events and to state
whether it includes multiple indications and, if so, the number of indications.
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
FirstName LastNameArnon Rosenthal, Ph.D.
Comapany NameAlector, Inc.
December 20, 2018 Page 2
FirstName LastName
Arnon Rosenthal, Ph.D.
Alector, Inc.
December 20, 2018
Page 2
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