October 26, 2018
David Gryska
Chief Financial Officer
Incyte Corporation
1801 Augustine Cut-Off
Wilmington, DE 19803
Re: Incyte Corporation
Form 10-K for Fiscal Year Ended December 31, 2017
Filed February 15, 2018
Form 8-K Filed July 31, 2018
File No. 001-12400
Dear Mr. Gryska:
We have reviewed your filings 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, 2017
Item 8. Financial Statements and Supplementary Data
Consolidated Balance Sheets, page 78
1. Your accrued and other current liabilities amounts represented 53% and
46% of total
current liabilities as of December 31, 2017 and 2016, respectively.
Please separately
disclose, either on your balance sheet or in a footnote, any item in
excess of five percent
of total current liabilities, or explain to us how you have complied with
Rule 5-02.20 of
Regulation S-X.
David Gryska
Incyte Corporation
October 26, 2018
Page 2
Form 8-K Filed July 31, 2018
Exhibit 99.1
Reconciliation of GAAP Net Income (Loss) to Selected Non-GAAP Adjusted
Information, page
13
2. Please disclose your purpose for including the adjustments for
"milestones received from
new or existing partners" and "upfront consideration and milestones
paid to new or
existing partners" in calculating the non-GAAP net income and non-GAAP
net income
per share measures. Also, tell us how you determined these adjustments
do not substitute
individually-tailored income or expense recognition methods for those
of GAAP. Refer to
Question 100.04 of the Division's Non-GAAP Financial Measures
Compliance and
Disclosure Interpretations.
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 Suying Li at (202) 551-3335 or Rufus Decker, Branch
Chief, at (202)
551-3769 with any questions.
Sincerely,
FirstName LastNameDavid Gryska
Division of
Corporation Finance
Comapany NameIncyte Corporation
Office of
Beverages, Apparel and
October 26, 2018 Page 2 Mining
FirstName LastName