SEC Comment Letter 0000000000-23-009643 to Harmony Biosciences Holdings, Inc. (HRMY)
Harmony Biosciences Holdings, Inc.
Date: Aug. 31, 2023 · CIK: 0001802665 · Accession: 0000000000-23-009643
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File numbers found in text: 001-39450
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United States securities and exchange commission logo
August 31, 2023
Sandip Kapadia
Chief Financial Officer
Harmony Biosciences Holdings, Inc.
630 W. Germantown Pike, Suite 215
Plymouth Meeting, PA 19462
Re:Harmony Biosciences Holdings, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed February 21, 2023
File No. 001-39450
Dear Sandip Kapadia:
We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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 apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations , page 81
1.We note that you attribute the 43.4% increase in product revenue to "the growth in the
average number of patients on WAKIX and price increases." Please revise future filings
to specifically describe the extent to which these changes are attributable to changes in
prices or to changes in sales volume. Refer to Item 303(b)(2)(iii) of Regulation S-K.
2.As a related matter, where you describe two or more factors that contributed to a material
change in a financial statement line item between periods, please quantify the extent to
which each factor contributed to the overall change in that line item. Refer to Item
303(b)(2) of Regulation S-K and SEC Release No. 33-8350 for guidance.
FirstName LastNameSandip Kapadia
Comapany NameHarmony Biosciences Holdings, Inc.
August 31, 2023 Page 2
FirstName LastName
Sandip Kapadia
Harmony Biosciences Holdings, Inc.
August 31, 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 Eric Atallah at (202) 551-3663 or Tara Harkins, Reviewing Accountant,
at (202) 551-3639 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences