United States securities and exchange commission logo
December 10, 2021
Albert Bourla
Chairman and Chief Executive Officer
PFIZER INC
235 East 42nd Street
New York, New York 10017
Re: PFIZER INC
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed February 25,
2021
File No. 001-03619
Dear Mr. Bourla:
We have reviewed your filing 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, 2020
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Non-GAAP Financial Measure: Adjusted Income
Reconciliation of GAAP Reported to Non-GAAP Adjusted Information -
Certain Line Items,
page 40
1. We note your tabular
reconciliations included here appear to essentially represent full
non- GAAP statements of
operations. Please explain why you believe your disclosures
comply with Question
102.10 of the Compliance and Disclosure Interpretations on Non-
GAAP Financial
Measures, or revise your disclosures in future filings. The same
comment also applies to
your quarterly reporting under Form 10-Q and your earnings
release under Form 8-K.
Albert Bourla
FirstName LastNameAlbert Bourla
PFIZER INC
Comapany10,
December NamePFIZER
2021 INC
December
Page 2 10, 2021 Page 2
FirstName LastName
Details of Income Statement Items Included in GAAP Reported but Excluded from
Non-GAAP
Adjusted Income, page 43, page 43
2. Here you include in note I adjustments to exclude the upfront and
milestone payments
made for collaboration agreements from Research and developments
expense and net
income attributable to Pfizer Inc. common shareholders. Please explain
how you believe
this presentation is consistent with the guidance in Question 100.01
of the Non-GAAP
Financial Measures Compliance and Disclosure Interpretations, or
revise your disclosures
in future filings. Please also expand, in future filings, to provide
sufficient detail of each
significant adjustment, to allow a reader to understand the nature of
the reconciling items
and your reasons for their adjustment, in accordance with the guidance
in Item 10(e) of
Regulation S-K and the Non- GAAP Financial Measures Compliance and
Disclosure
Interpretations. The same comments also apply to your quarterly
reporting under Form
10-Q and your earnings release under Form 8-K.
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 Li Xiao at (202) 551 - 4391 or Kevin Vaughn, Accounting
Branch
Chief, at (202) 551 - 3494 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Life
Sciences