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United States securities and exchange commission logo
September 4, 2020
Laura Clague
Chief Financial Officer
Retrophin, Inc.
3721 Valley Centre Drive, Suite 200
San Diego, CA 92130
Re: Retrophin, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2019
Filed February 24,
2020
File No. 001-36257
Dear Ms. Clague:
We have limited our review of your filing to the financial
statements and related
disclosures 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 the Fiscal Year Ended December 31, 2019
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Results of Operations - Operating Expenses, page 53
1. We note your selling,
general and administrative expenses increased by 24% due to
increased legal and
compensation expenses. In future filings, please describe in further
detail the underlying
reasons for the significant increase and provide additional
quantitative
information as necessary.
Consolidated Financial Statements
Note 9. Intangible Assets
Thiola License Agreement, page F-22
2. We note that in 2019
you added $15.8 million to intangible assets related to royalties in
excess of the minimum.
Please explain to us the basis for your accounting treatment to
Laura Clague
Retrophin, Inc.
September 4, 2020
Page 2
capitalize royalty payments in excess of minimum royalties and the
accounting literature
that you relied on for this treatment. Please explain to us the reason
you do not expense
the annual royalty payments.
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 Michael Fay at 202-551-3812 or Brian Cascio, Accounting
Branch
Chief, at 202-551-3676 with any questions.
FirstName LastNameLaura Clague Sincerely,
Comapany NameRetrophin, Inc.
Division of
Corporation Finance
September 4, 2020 Page 2 Office of Life
Sciences
FirstName LastName