700 US Highway 202/206
Bridgewater, New Jersey 08807
Phone: (908) 977-9900
www.insmed.com
VIA EDGAR
January 21, 2020
U.S. Securities and Exchange Commission (the “Commission”)
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Mr. Ameen Hamady
Ms. Jeanne Baker
Re: INSMED Inc
Form 10-K filed on February 22, 2019
Form 8-K filed on October 30, 2019
File no. 000-30739
Ladies and Gentlemen:
Insmed Incorporated (the “Company”) respectfully submits this letter in response to a letter, dated January 14, 2020, from the staff of the Commission (the “Staff”) commenting on the Company’s Current Report on Form 8-K filed with the Commission on October 30, 2019. To facilitate the Staff’s review, we have included in this letter the caption and comment from the Staff’s letter in bold text and the Company’s response immediately thereafter.
Form 8-K filed on October 30, 2019
Exhibit 99.1
Non-GAAP Financial Measures, page 3
1. We note your response to our comment from our letter dated December 4, 2019. In order to distinguish your Arikayce milestone payments from your other more typical milestone payments, please expand your disclosures to highlight the nature of your research funding arrangement with the Cystic Fibrosis Foundation and how the arrangement differs from your other license agreements.
Response:
The Company acknowledges the Staff’s comment and intends to expand its future disclosure to highlight the nature of its research funding arrangement with Cystic Fibrosis Foundation Therapeutics, Inc. and how it differs from the Company’s license agreements.
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Correspondence regarding this letter may be directed to the attention of the undersigned at john.goll@insmed.com. In addition, you may contact me at (732) 487-7395 or Christine Pellizzari at (732) 487-7366.
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Sincerely, |
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INSMED INCORPORATED |
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/s/ John Goll |
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John Goll |
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Chief Accounting Officer |
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cc: Christine Pellizzari, Insmed Incorporated
Michael J. Riella, Covington & Burling LLP