Via EDGAR
December 30, 2020
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attn: | Ms. Jeanne Baker |
| Mr. Terence O’Brien, Branch Chief |
| Re: | INSMED Inc |
| Form 10-K filed February 25, 2020 | |
| File No. 000-30739 |
Ladies and Gentlemen:
Insmed Incorporated (the “Company”) respectfully submits this letter in response to a letter, dated December 21, 2020, from the staff of the Securities and Exchange Commission (the “Staff”) commenting on the Company’s Annual Report on Form 10-K filed with the Commission on February 25, 2020. 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 10-K for the fiscal year ended December 31, 2019
Financial Statements
Consolidated Statements of Comprehensive Loss, page 77
| 1. | Please note that since you report amortization of intangible assets outside of cost of product revenue, it is not appropriate to present a separate caption for gross margin. Refer to SAB Topic 11:B and revise your presentation to either reclassify the applicable amortization to cost of product revenues or remove the caption gross margin. |
Response:
The Company respectfully acknowledges the Staff’s comment. In response to the Staff’s comment, in future filings, the Company will no longer present a gross margin caption in its consolidated statements of comprehensive loss.
We acknowledge that we are responsible for the adequacy and accuracy of the Company’s disclosures, notwithstanding any review, comments, action or absence of action by the Staff.
| 700 US Highway 202/206 | Bridgewater, NJ 08807 | Phone: 908-977-9900 | Fax: 908-526-4026 |
www.insmed.com
Correspondence regarding this letter may be directed to the attention of the undersigned at sara.bonstein@insmed.com. In addition, you may contact me at (732) 487-7513 or Christine Pellizzari at (732) 487-7366.
Sincerely,
INSMED INCORPORATED
| /s/ Sara M. Bonstein | |
| Sara M. Bonstein | |
| Chief Financial Officer |
cc: Christine Pellizzari, Insmed Incorporated
Michael J. Riella, Covington & Burling LLP
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