Correspondence 0001558370-25-004629 from Harmony Biosciences Holdings, Inc. (HRMY)
Harmony Biosciences Holdings, Inc.
Date: April 9, 2025 · CIK: 0001802665 · Accession: 0001558370-25-004629
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-39450
Referenced dates: March 28, 2025
Letter
April 9, 2025 Eric Atallah United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 RE: Harmony Biosciences Holdings, Inc. Form 10-K for the Fiscal Year Ended December 31, 2024 Filed February 25, 2025 Form 8-K dated February 25, 2025 File No. 001-39450 Dear Mr. Atallah: Set forth below is the response of Harmony Biosciences Holdings, Inc. (the “Company”) to a comment received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) by letter, dated March 28, 2025 regarding the Company’s filings referenced above. The Company’s response is provided underneath your original comments below. SEC Comment Form 8-K Dated February 25, 2025 Exhibit 99.1 1. We note that your non-GAAP adjusted net income includes adjustments for upfront licensing fees, milestone payments and IPR&D charges incurred in connection with asset acquisitions. Please tell us how you determined that these adjustments do not represent normal, recurring, cash operating expenses necessary to operate your business. Refer to Question 100.01 of the Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. Company Response We respectfully acknowledge the Staff’s comment and advise the Staff that we will not include adjustments for upfront licensing fees, milestone payments and IPR&D charges incurred in connection with asset acquisitions in any future presentations of our non-GAAP measures. Harmony Biosciences Holdings, Inc. is committed to fully complying with the SEC’s disclosure requirements. Please do not hesitate to contact me at (484) 539-9750 if you have any questions or require further information. Sincerely, /s/ Sandip Kapadia Sandip Kapadia Chief Financial Officer
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CORRESP 1 filename1.htm April 9, 2025 Eric Atallah United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 RE: Harmony Biosciences Holdings, Inc. Form 10-K for the Fiscal Year Ended December 31, 2024 Filed February 25, 2025 Form 8-K dated February 25, 2025 File No. 001-39450 Dear Mr. Atallah: Set forth below is the response of Harmony Biosciences Holdings, Inc. (the “Company”) to a comment received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) by letter, dated March 28, 2025 regarding the Company’s filings referenced above. The Company’s response is provided underneath your original comments below. SEC Comment Form 8-K Dated February 25, 2025 Exhibit 99.1 1. We note that your non-GAAP adjusted net income includes adjustments for upfront licensing fees, milestone payments and IPR&D charges incurred in connection with asset acquisitions. Please tell us how you determined that these adjustments do not represent normal, recurring, cash operating expenses necessary to operate your business. Refer to Question 100.01 of the Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. Company Response We respectfully acknowledge the Staff’s comment and advise the Staff that we will not include adjustments for upfront licensing fees, milestone payments and IPR&D charges incurred in connection with asset acquisitions in any future presentations of our non-GAAP measures. Harmony Biosciences Holdings, Inc. is committed to fully complying with the SEC’s disclosure requirements. Please do not hesitate to contact me at (484) 539-9750 if you have any questions or require further information. Sincerely, /s/ Sandip Kapadia Sandip Kapadia Chief Financial Officer