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United States securities and exchange commission logo
September 24, 2021
Thomas P. Kelly
Chief Financial Officer
Deciphera Pharmaceuticals, Inc.
200 Smith Street
Waltham, MA 02451
Re: Deciphera
Pharmaceuticals, Inc.
Form 10-K for the
fiscal year ended December 31, 2020
Filed February 9,
2021
File No. 1-38219
Dear Mr. Kelly:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment. We may ask you to provide us
with information so
we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 10-K for the fiscal year ended December 31, 2020
Management's Discussion and Analysis, page 104
Results of Operations, page 111
1. Cost of sales were only
$0.2 million for the year ended December 31, 2020, resulting in a
gross margin percentage
of 99.4%. You state on page 112 that external manufacturing
costs associated with
QINLOCK inventory prior to FDA approval were previously
expensed as research
and development expenses and, therefore, are not included in cost of
sales during the year
then ended. Please explain the following and consider providing
additional disclosure
in your future filings:
the amount of
estimated revenues represented by inventory on hand at December
31, 2020 for which
manufacturing costs were expensed in prior periods as research
and development
expenses (i.e.,"zero cost inventories");
when you expect to
finish selling the zero cost inventories;
the shelf life of
your inventory and your consideration of whether or not any
Thomas P. Kelly
Deciphera Pharmaceuticals, Inc.
September 24, 2021
Page 2
additional inventory will be determined to be obsolete in future
periods; and
your estimate of what the gross margin percentage will be after
the zero cost
inventories are sold.
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 Jenn Do at (202) 551-3743 or Angela Connell at (202)
551-3426 with
any questions.
FirstName LastNameThomas P. Kelly Sincerely,
Comapany NameDeciphera Pharmaceuticals, Inc.
Division of
Corporation Finance
September 24, 2021 Page 2 Office of Life
Sciences
FirstName LastName