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United States securities and exchange commission logo
June 6, 2024
Molly Henderson
Chief Financial Officer
Phathom Pharmaceuticals, Inc.
100 Campus Drive, Suite 102
Florham Park, New Jersey 07932
Re: Phathom
Pharmaceuticals, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2023
Form 10-Q for
Fiscal Quarter Ended March 31, 2024
File No. 001-39094
Dear Molly Henderson:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Results of operations
Research and development expenses, page 117
1. We note from the
pipeline table on page 9 that you are pursuing multiple indications with
separate clinical
trials. Please revise future filings to disclose the research and
development costs
incurred during each period presented for each of your
target indications. If
you do not track your research and development costs by indication,
please disclose that
fact. Also, revise to provide other quantitative and qualitative
disclosures that give
more transparency as to the type of research and development
expenses incurred
(i.e., by nature or type of expense) which should reconcile to total
research and
development expenses on your Statements of Operations.
Molly Henderson
Phathom Pharmaceuticals, Inc.
June 6, 2024
Page 2
Note 7. Revenue Interest Financing Liability , page F-21
2. Please revise future filings to disclose the effective interest rate
of your revenue interest
financing liability or tell us why the disclosure is not required.
Refer to ASC 835-30-50-1
and ASC 470-10-35-3.
Exhibit 31.1 and 31.2, page 168
3. We note the certifications provided in Exhibits 31.1 and 31.2 do not
include paragraph
4(b) and the introductory language in paragraph 4 referring to
internal control over
financial reporting after the end of the transition period that allows
these omissions. Please
provide corrected certifications in an amended filing that also
contains full Item 9A
disclosure as well as your financial statements. Amend your Form 10-Q
for the period
ended March 31, 2024 in a similar manner. Refer to the guidance of
Regulation S-K
Compliance and Disclosure Interpretations Question 246.13.
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.
Please contact Gary Newberry at 202-551-3761 or Kevin Kuhar at
202-551-3662 with
any questions.
FirstName LastNameMolly Henderson Sincerely,
Comapany NamePhathom Pharmaceuticals, Inc.
Division of
Corporation Finance
June 6, 2024 Page 2 Office of Life
Sciences
FirstName LastName