SEC Company Response from Alector, Inc. (ALEC) (CIK 0001653087) (ALEC) — Jan 7, 2019
Alector, Inc. (ALEC) (CIK 0001653087)
Date: Jan. 7, 2019 · CIK: 0001653087 · Accession: 0001193125-19-003779
AI Filing Summary & Sentiment
Referenced dates: December 20, 2018
Letter
650 Page Mill Road
Palo Alto, CA 94304-1050
PHONE 650.493.9300
FAX 650.493.6811
www.wsgr.com
January 7, 2019
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Office of Healthcare & Insurance
100 F Street, N.E.
Washington, D.C. 20549-3720
Attention: J. Nolan McWilliams
Dietrich King
Keira Nakada
Jim Rosenberg
Re: Alector, Inc.
Draft Registration Statement on Form S-1
Response Dated December 17, 2018
CIK No. 0001653087
Ladies and Gentlemen:
On behalf of our client, Alector, Inc. (the “Company”), we submit this letter in response to a comment from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in its letter dated December 20, 2018 (the “Comment Letter”), relating to proposed disclosure in the Company’s Draft Registration Statement on Form S-1 (the “Registration Statement”). We are concurrently submitting via EDGAR this letter and a revised draft of the Registration Statement. For the Staff’s reference, we have included both a clean copy of the Registration Statement and a copy marked to show all changes from the version confidentially submitted on November 16, 2018.
In this letter, we have recited the comment from the Staff in italicized, bold type and have followed the comment with the Company’s response. Except for the page references contained in the comment of the Staff, or as otherwise specifically indicated, page references herein correspond to the page of the revised draft of the Registration Statement.
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.
AUSTIN BEIJING BOSTON BRUSSELS HONG KONG LONDON LOS ANGELES NEW YORK PALO ALTO
SAN DIEGO SAN FRANCISCO SEATTLE SHANGHAI WASHINGTON, DC WILMINGTON, DE
Securities and Exchange Commission
January 7, 2019
Page
The Company acknowledges the Staff’s comments and advises the Staff that in response to the Staff’s comments, the Company has revised the disclosure on pages F-10 and F-31 of the Registration Statement.
* * * *
Securities and Exchange Commission
January 7, 2019
Page
Please direct any questions with respect to this confidential submission to me at (650) 849-3223 or tjeffries@wsgr.com.
Sincerely,
WILSON SONSINI GOODRICH & ROSATI
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CORRESP 1 filename1.htm CORRESP 650 Page Mill Road Palo Alto, CA 94304-1050 PHONE 650.493.9300 FAX 650.493.6811 www.wsgr.com January 7, 2019 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Healthcare & Insurance 100 F Street, N.E. Washington, D.C. 20549-3720 Attention: J. Nolan McWilliams Dietrich King Keira Nakada Jim Rosenberg Re: Alector, Inc. Draft Registration Statement on Form S-1 Response Dated December 17, 2018 CIK No. 0001653087 Ladies and Gentlemen: On behalf of our client, Alector, Inc. (the “Company”), we submit this letter in response to a comment from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in its letter dated December 20, 2018 (the “Comment Letter”), relating to proposed disclosure in the Company’s Draft Registration Statement on Form S-1 (the “Registration Statement”). We are concurrently submitting via EDGAR this letter and a revised draft of the Registration Statement. For the Staff’s reference, we have included both a clean copy of the Registration Statement and a copy marked to show all changes from the version confidentially submitted on November 16, 2018. In this letter, we have recited the comment from the Staff in italicized, bold type and have followed the comment with the Company’s response. Except for the page references contained in the comment of the Staff, or as otherwise specifically indicated, page references herein correspond to the page of the revised draft of the Registration Statement. 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. AUSTIN BEIJING BOSTON BRUSSELS HONG KONG LONDON LOS ANGELES NEW YORK PALO ALTO SAN DIEGO SAN FRANCISCO SEATTLE SHANGHAI WASHINGTON, DC WILMINGTON, DE Securities and Exchange Commission January 7, 2019 Page 2 The Company acknowledges the Staff’s comments and advises the Staff that in response to the Staff’s comments, the Company has revised the disclosure on pages F-10 and F-31 of the Registration Statement. * * * * Securities and Exchange Commission January 7, 2019 Page 3 Please direct any questions with respect to this confidential submission to me at (650) 849-3223 or tjeffries@wsgr.com. Sincerely, WILSON SONSINI GOODRICH & ROSATI Professional Corporation /s/ Tony Jeffries Tony Jeffries cc: Arnon Rosenthal, Ph.D., Alector, Inc. Sabah Oney, Ph.D., Alector, Inc. Stephanie Yonker, Ph.D., Alector, Inc. Michael Coke, Wilson Sonsini Goodrich & Rosati, Professional Corporation Alan F. Denenberg, Davis Polk & Wardwell LLP Stephen Salmon, Davis Polk & Wardwell LLP