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United States securities and exchange commission logo
December 8, 2022
Lesley Ann Calhoun
Chief Financial Officer
Aligos Therapeutics, Inc.
One Corporate Drive, 2nd Floor
South San Francisco, California
Re: Aligos
Therapeutics, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2021
Filed March 10,
2022
File No. 001-39617
Dear Lesley Ann Calhoun:
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 Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Components of Our Results of Operations
Research and Development Expenses, page 107
1. Considering the
significant research and development expenses you have historically
incurred and expect to
continue to incur, in future filings, please expand your disclosures
to include more
disaggregated disclosures for your research and development expenses,
for example by product
candidates, by program, and or by nature of costs. Please also
disclose whether you
track external costs by product candidates and or by program, and if
not, please disclose
that fact in future filings as well.
Lesley Ann Calhoun
FirstName LastNameLesley
Aligos Therapeutics, Inc. Ann Calhoun
Comapany8,
December NameAligos
2022 Therapeutics, Inc.
December
Page 2 8, 2022 Page 2
FirstName LastName
Consolidated Financial Statements
Note 11. License and Collaboration Agreements
Agreement with Merck, page 140
2. Please address the following comments with regard to your accounting
and disclosures for
the License and Research Collaboration Agreement with Merck & Co.
Please expand your future filings to describe all material
terms of the agreement,
including the specific amount for the upfront payments, and the
development and
commercilaiton milestone payments. For the tiered royalty
arrangement, please
disclose the royalty term and quantification of the royalty rate,
or a range no greater
than 10 percentage points per tier.
Please provide us an analysis, and revise your future filings
if necessary, of the
components you have identified under this agreement that would
fall under ASC 808
Collaborative Arrangements and the components under ASC 606
Revenue from
Contracts with Customers. In your analysis, tell us how you have
considered the unit
of account guidance under ASC 808-10-15-5B.
Please tell us and revise in future filings the specific
milestone payments achieved in
2021 and 2022. In that regard, you repeatedly disclose that the
revenues you have
recognized so far are from milestone payments.
Please provide us an analysis of your revenue recognition under
ASC 606, including
your determination of the performance obligations, the
transaction price, and your
revenue recognition method (i.e. over time or point in time) for
each performance
obligation. In that regard, please note that the percentage of
completion is not referred
to as a revenue recognition method under ASC 606.
Lastly, please revise your future filings to include a roll
forward of your deferred
revenue with the movements agreeing to the payments received and
revenue
recognized during the period to meet the disclosure requirement
under ASC 606-10-
50-8.
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 Li Xiao at 202-551-4391 or Daniel Gordon at 202-551-3486
with any
questions.
Sincerely,
Division of
Corporation Finance
Office of Life
Sciences