VERTEX PHARMACEUTICALS INC / MA (VRTX) – SEC staff letter
2026-03-18 · Re: Vertex Pharmaceuticals, Inc. Form 10-K for Fiscal Year Ended December 31, 2025 · Accession 0000000000-26-002758 · 1 staff comment(s) issued
Company response(s): 2026-04-01
Exhibits, Certifications & Signatures
2026-03-18 · Vertex Pharmaceuticals, Inc. Form 10-K for Fiscal Year Ended December 31, 2025 · Comment 1 · Out-license Agreements, page F-20 Partly revised / explained
Staff comment: We note your disclosure stating that you entered into collaboration agreements with Zai Lab Limited and Ono Pharmaceuticals Co. Ltd. In future filings, if material, please expand your disclosure to describe the material terms of these agreements including, but not limited to, the termination provisions and any royalty or milestone payment requirements. Disclose the royalty rate or a range not exceeding 10%. In addition, tell us how you considered whether to file the agreements as exhibits. letter →
Company response: The Company acknowledges the Staff’s comment, and respectfully advises the Staff that the Company has concluded that its agreements with Zai Lab Limited (the “Zai Agreement”) and Ono Pharmaceuticals Co., Ltd. (the “Ono Agreement,” and together with the Zai Agreement, the “Agreements”), while beneficial, are not material to the Company and, therefore, are not required to be filed as exhibits to the Company’s filings with the Commission, including the 2025 10-K, pursuant to Item 601(b)(10) of Regulation S-K. The Company reached this conclusion based on the following primary considerations: • Immaterial financial value . The upfront consideration paid to the Company and potential future… response letter →
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