United States securities and exchange commission logo
September 15, 2022
Kelly Deck
Chief Financial Officer
Inhibrx, Inc.
11025 N. Torrey Pines Rd.
Suite 200
La Jolla, CA 92037
Re: Inhibrx, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed February 28,
2022
Form 10-Q for the
Fiscal Quarter Ended June 30, 2022
Filed August 8,
2022
File No. 001-39452
Dear Ms. Deck:
We have limited our review of your filings 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-Q for the Fiscal Quarter Ended June 30, 2022
Item 6. Exhibits , page 43
1. Please revise your
future filings to include the opening language of paragraph 4 related to
your internal control
over financial reporting in accordance with Item 601 of Regulation
S-K for exhibits 31.1
and 31.2. Provide us with your proposed revisions in your response.
Form 10-K for the Fiscal Year Ended December 31, 2021
Cover Page
2. We note that your cover
page reflects your filing status to be a large accelerated filer and a
Kelly Deck
Inhibrx, Inc.
September 15, 2022
Page 2
smaller reporting company. This was also noted on the cover of your
Form 10-Q for the
period ended June 30, 2022. As your public float as of June 30, 2021
is greater than $700
million, as reported on the front cover of your Form 10-K, it appears
you are not eligible
to use the requirements for smaller reporting companies under the
revenue test to meet the
condition to be considered a smaller reporting company. Please address
the following
points regarding your filer status:
Tell us how your reported filer status is consistent with
Release No. 34-88365:
Accelerated Filer and Large Accelerated Filer Definitions; Final
Rule.
Revise the cover page of your document in future filings to
report your filer status
consistent with the above guidance, and provide us with a summary
of such proposed
disclosure.
Tell us how the change in filer status impacts the adoption of
recent accounting
pronouncements, specifically ASU 2016-13, Financial Instruments -
Credit Losses:
Measurement of Credit Losses on Financial Statements (Topic 362)
as disclosed on
page 131.
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 Sasha Parikh at 202-551-3627 or Tracie Mariner at
202-551-3744 with
any questions.
FirstName LastNameKelly Deck Sincerely,
Comapany NameInhibrx, Inc.
Division of
Corporation Finance
September 15, 2022 Page 2 Office of Life
Sciences
FirstName LastName