SEC Comment Letter 0000000000-24-010304 to Zentalis Pharmaceuticals, Inc. (ZNTL)
Zentalis Pharmaceuticals, Inc.
Date: Sept. 12, 2024 · CIK: 0001725160 · Accession: 0000000000-24-010304
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-39263
Letter
September 12, 2024 Cam Gallagher Interim Chief Financial Officer Zentalis Pharmaceuticals, Inc. 1359 Broadway Suite 801 New York, New York 10018 Re:Zentalis Pharmaceuticals, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 Filed February 27, 2024 File No. 001-39263 Dear Cam Gallagher: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-Q or the Fiscal Quarter Ended June 30, 2024 Notes to Condensed Consolidated Financial Statements 3. Significant Transactions, page 12 1.Please explain to us how you applied your revenue recognition policy to the elements of the license agreement you entered into with Immunome, Inc., including references to the paragraphs within ASC 606 that support your accounting. Please also confirm that you will disclose your revenue recognition policy in future filings and provide us with a draft of your intended disclosure revisions.
As a related matter, please revise your future filings to disclose the key terms of each of your license agreements and strategic collaborations, including your obligations under each agreement, the related financial provisions and your accounting treatment for each agreement. As an example, your accounting treatment for $4.2 million of excess proceeds received from the April 2022 direct offer to Pfizer as a reduction of research and 2.
September 12, 2024 Page 2 development expense over the term of the collaboration suggests that you are accounting for this agreement under ASC 808. Please confirm and revise your disclosure in future filings accordingly to clarify. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Ibolya Ignat at 202-551-3636 or Angela Connell at 202-551-3426 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
Show Raw Text
September 12, 2024
Cam Gallagher
Interim Chief Financial Officer
Zentalis Pharmaceuticals, Inc.
1359 Broadway
Suite 801
New York, New York 10018
Re:Zentalis Pharmaceuticals, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Filed February 27, 2024
File No. 001-39263
Dear Cam Gallagher:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-Q or the Fiscal Quarter Ended June 30, 2024
Notes to Condensed Consolidated Financial Statements
3. Significant Transactions, page 12
1.Please explain to us how you applied your revenue recognition policy to the elements of
the license agreement you entered into with Immunome, Inc., including references to the
paragraphs within ASC 606 that support your accounting. Please also confirm that you
will disclose your revenue recognition policy in future filings and provide us with a draft
of your intended disclosure revisions.
As a related matter, please revise your future filings to disclose the key terms of each of
your license agreements and strategic collaborations, including your obligations under
each agreement, the related financial provisions and your accounting treatment for each
agreement. As an example, your accounting treatment for $4.2 million of excess proceeds
received from the April 2022 direct offer to Pfizer as a reduction of research and 2.
September 12, 2024
Page 2
development expense over the term of the collaboration suggests that you are accounting
for this agreement under ASC 808. Please confirm and revise your disclosure in future
filings accordingly to clarify.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact Ibolya Ignat at 202-551-3636 or Angela Connell at 202-551-3426 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences