United States securities and exchange commission logo
December 29, 2021
Steven Helwig
Interim Principal Financial Officer
Radius Health, Inc.
22 Boston Wharf Rd., 7th Floor
Boston, MA 02210
Re: Radius Health, Inc.
Form 10-K for the
Period Ended December 31, 2021
Filed February 25,
2021
Form 8-K Filed
November 8, 2021
File No. 001-35726
Dear Mr. Helwig:
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 8-K Filed November 8, 2021
Exhibit 99.1 Radius Health Inc. Press Release dated November 8, 2021
Radius Health, Inc.: Third Quarter 2021 Results, page 1
1. In future filings,
please present with equal or greater prominence the GAAP measure
comparable to the
non-GAAP measure "Adjusted EBITDA" which is net income (loss).
For example, there is
no mention of your net loss until page 3 of the exhibit and no
mention of net loss in
any of the content of your opening bullet points or the bullet points
in "Q3 2021 Financial
Highlights". Refer to Item 10(e)(1)(i)(A) of Regulation S-K.
2. Please revise your
non-GAAP discussion on page 9 in future filings to indicate that
adjusted EBITDA is a
non-GAAP measure and comply with the requirements of Item
10(e)(1)(i) of
Regulation S-K, including reconciliation to the comparable GAAP measure.
Also, revise the titles
for your non-GAAP measures throughout the document for
Steven Helwig
Radius Health, Inc.
December 29, 2021
Page 2
consistency. For example, you use non-GAAP net loss and non-GAAP loss
per share on
page 8 rather than your identified non-GAAP measures non-GAAP adjusted
net loss and
non-GAAP net loss per share.
3. We noted in the power point presentation related to your third quarter
2021 earnings call
provides a full non-GAAP income statement for the three months and
quarter ended
September 30, 2021. Please confirm that the full non-GAAP financial
statement
presentation will not be used in future filings. The presentation of a
non-GAAP financial
statement gives undue prominence to the non-GAAP information. As a
substitute for this
presentation format, you may consider presenting only individual
non-GAAP measures
(i.e., line items, subtotals, etc.) provided each one complies with
Item 10 of Reg. S-K and
the Division of Corporation Finance s Frequently Asked Questions
Regarding Use of non-
GAAP Financial Measures.
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 Sasha Parikh at 202-551-3627 or Christine Torney at
202-551-
3652 with any questions.
FirstName LastNameSteven Helwig Sincerely,
Comapany NameRadius Health, Inc.
Division of
Corporation Finance
December 29, 2021 Page 2 Office of Life
Sciences
FirstName LastName