United States securities and exchange commission logo
April 4, 2023
Kenneth Myszkowski
Chief Financial Officer
Arrowhead Pharmaceuticals, Inc.
177 E. Colorado Blvd, Suite 700
Pasadena, California 91105
Re: Arrowhead
Pharmaceuticals, Inc.
Form 10-K for the
Fiscal Year Ended September 30, 2022
Filed November 28,
2022
File No. 001-38042
Dear Kenneth Myszkowski:
We have reviewed your March 3, 2023 response to our comment
letter and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to the 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 the comment, we may have
additional comments.
Unless we note otherwise, our reference to the prior comment is to
comments in our February 10,
2023 letter.
Form 10-K for the Fiscal Year Ended September 30, 2022
Notes to the Consolidated Financial Statements
Note 2. Collaboration and License Agreements
Joint Venture and License Agreement with Visirna Therapeutics, Inc. ,
page F-18
1. We note your response
to our prior comment two. Please explain your assertion that
your contribution of
Licensed Products to the joint venture was between entities under
common control. In this
regard, Visirna appears to have been incorporated by Vivo
Capital on January 25,
2022. It is therefore unclear how Visirna was considered an entity
under common control at
the time of your initial investment on April 25, 2022.
Kenneth Myszkowski
FirstName
ArrowheadLastNameKenneth Myszkowski
Pharmaceuticals, Inc.
Comapany
April NameArrowhead Pharmaceuticals, Inc.
4, 2023
April 24, 2023 Page 2
Page
FirstName LastName
You may contact Frank Wyman at 202-551-3660 or Angela Connell at
202-551-3426 if
you have any questions.
Sincerely,
Division of Corporation
Finance
Office of Life Sciences