December 4, 2019
Joerg Hornstein
Chief Financial Officer
AC Immune SA
EPFL Innovation Park
Building B
1015 Lausanne
Switzerland
Re: AC Immune SA
Form 20-F for the Fiscal Year Ended December 31, 2018
Filed April 19, 2019
Form 6-K for the Quarterly Period Ended June 30, 2019
Filed August 14, 2019
File No. 001-37891
Dear Mr. Hornstein:
We have limited our review of your filing to the financial statements
and related
disclosures 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 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 the comment, we may have additional
comments.
Form 6-K dated August 14, 2019
Exhibit 99.1
Interim Condensed Financial Statements (Unaudited)
Notes to Interim Condensed Financial Statements
3.1 Licensing and collaboration agreements , page 13
1. Please provide us the following information supporting your revenue
recognition for the
license granted under the collaboration agreement with Eli Lilly and
Company ("Lilly").
Explain the factors that you considered in characterizing this license
transferred to
Lilly as a distinct performance obligation representing a
"right-to-use" rather than a
"right-to-access."
Joerg Hornstein
AC Immune SA
December 4, 2019
Page 2
Explain how Lilly has used and is expected to use this license
during Phase 1 clinical
trials and whether it has benefited from this license since the
effective date.
Explain your consideration of factors discussed in IFRS 15.B58
and B59, particularly
the extent to which Lilly has been or will be exposed to the
positive or negative
results of your Phase 1 clinical trials.
Provide support for your use of the residual approach to estimate
the standalone
selling price for this license, given that this approach is only
permissible in limited
circumstances.
Explain how the apparent premium implicit in the
contemporaneously-negotiated
convertible note, which converted to common shares on April 23,
2019, impacted
your determination of transaction price and revenue recognized in
2019.
Refer us to the technical guidance upon which you relied.
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 Ibolya Ignat at (202) 551-3636 or Franklin Wyman at
(202) 551-3660
with any questions.
FirstName LastNameJoerg Hornstein Sincerely,
Comapany NameAC Immune SA
Division of
Corporation Finance
December 4, 2019 Page 2 Office of Life
Sciences
FirstName LastName