SEC Comment Letter 0000000000-23-003685 to MeiraGTx Holdings plc (MGTX) (CIK 0001735438) (MGTX)
MeiraGTx Holdings plc (MGTX) (CIK 0001735438)
Date: April 13, 2023 · CIK: 0001735438 · Accession: 0000000000-23-003685
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File numbers found in text: 001-38520
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United States securities and exchange commission logo
April 13, 2023
Richard Giroux
Chief Financial Officer
MeiraGTx Holdings plc
450 East 29th Street, 14th Floor
New York, NY 10016
Re:MeiraGTx Holdings plc
Form 10-K for the fiscal year ended December 31, 2022
Filed March 14, 2023
File No. 001-38520
Dear Richard Giroux:
We have limited our review of your filing to the financial statements and related
disclosures 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 this 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
comments applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the fiscal year ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Research and Development Expenses, page 119
1.Please revise your future filings to disclose the costs incurred during each period
presented for each of your key research and development projects or key programs. If you
do not track your research and development costs by project or program, please disclose
that fact and explain why you do not maintain and evaluate research and development
costs by project or program. For amounts that are not tracked by project or program,
provide other quantitative or qualitative disclosure that provides more transparency as to
the type of research and development expenses incurred (i.e. by nature or type of expense)
which should reconcile to total research and development expense on the Statements of
Operations.
FirstName LastNameRichard Giroux
Comapany NameMeiraGTx Holdings plc
April 13, 2023 Page 2
FirstName LastName
Richard Giroux
MeiraGTx Holdings plc
April 13, 2023
Page 2
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.
You may contact Vanessa Robertson at 202-551-3649 or Kevin Vaughn at 202-551-3494
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences