Quarterlytics / Healthcare / Biotechnology / Aclaris Therapeutics, Inc.

Aclaris Therapeutics, Inc.

acrs · NASDAQ Healthcare
Claim this profile
Ticker acrs
Exchange NASDAQ
Sector Healthcare
Industry Biotechnology
Employees 61
← All annual reports
FY2017 Annual Report · Aclaris Therapeutics, Inc.
Sign in to download
Loading PDF…
Table of Contents

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM 10-K

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF
THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2017

Commission file number 001-37581

Incorporated under the Laws of the
State of Delaware

I.R.S. Employer Identification No.
46-0571712

ACLARIS THERAPEUTICS, INC.

640 Lee Road, Suite 200
Wayne, PA 19087
(484) 324-7933

Securities registered pursuant to Section 12(b) of the Exchange Act:

Title of Each Class:
Common Stock, $0.00001 par value

Name of Each Exchange on which Registered
The Nasdaq Stock Market, LLC

Securities registered pursuant to Section 12(g) of the Exchange Act:

None

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes ◻     No ☒ 

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or 15(d) of the Exchange Act. Yes ◻      No ☒

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding
12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. Yes ☒     No ◻

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Web site, if any, every Interactive Data File required to be submitted

and posted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit
and post such files). Yes ☒     No ◻ 

Indicate by check mark if disclosure of delinquent filers pursuant to Item 405 of Regulations S-K (§ 229.405 of this chapter) is not contained herein, and will not be contained,

to the best of registrant's knowledge, in definitive proxy or information statements incorporated by reference in Part III of this Form 10-K or any amendment to this Form 10-K. ☒

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company or emerging growth
company. See definitions of “large accelerated filer,” “accelerated filer”, “smaller reporting company” and “emerging growth company” in Rule 12b-2 of the Exchange Act.

Large accelerated filer ◻

Accelerated filer ☒

Non-accelerated filer ◻
(Do not check if a
smaller reporting company)

Smaller reporting company ◻

Emerging growth company ☒

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial

accounting standards provided pursuant to Section 13(a) of the Exchange Act. ☒

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes ◻    No ☒

As of June 30, 2017, the last business day of the registrant’s last completed second quarter, the aggregate market value of the registrant’s common stock held by non-affiliates

of the registrant was approximately $639.2 million based on the closing price of the registrant’s common stock, as reported by the Nasdaq Global Select Market, on such date. 

As of March 9, 2018, 30,901,492 shares of common stock, $0.00001 par value, were outstanding.

DOCUMENTS INCORPORATED BY REFERENCE

Portions of the Company's definitive proxy statement, to be filed pursuant to Regulation 14A under the Securities Exchange Act of 1934, for its 2018 Annual Meeting of
Stockholders are incorporated by reference in Part III of this Form 10-K.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

SPECIAL NOTE REGARDING FORWARD-LOOKING STATEMENTS

This Annual Report on Form 10-K (this “Annual Report”) contains forward-looking statements within the meaning
of  Section  27A  of  the  Securities  Act  of  1933,  as  amended,  and  Section  21E  of  the  Securities  Exchange  Act  of  1934,  as
amended, or the Exchange Act, that involve substantial risks and uncertainties. The forward-looking statements are contained
principally in Part I, Item 1. “Business,” Part I, Item 1A. “Risk Factors,” and Part II, Item 7. “Management’s Discussion and
Analysis of Financial Condition and Results of Operations,” but are also contained elsewhere in this Annual Report. In some
cases,  you  can  identify  forward-looking  statements  by  the  words  “may,”  “might,”  “will,”  “could,”  “would,”  “should,”
“expect,” “intend,” “plan,” “objective,” “anticipate,” “believe,” “estimate,” “predict,” “project,” “potential,” “continue” and
“ongoing,” or the negative of these terms, or other comparable terminology intended to identify statements about the future.
These statements involve known and unknown risks, uncertainties and other factors that may cause our actual results, levels
of  activity,  performance  or  achievements  to  be  materially  different  from  the  information  expressed  or  implied  by  these
forward-looking  statements.  Although  we  believe  that  we  have  a  reasonable  basis  for  each  forward-looking  statement
contained  in  this  Annual  Report,  we  caution  you  that  these  statements  are  based  on  a  combination  of  facts  and  factors
currently  known  by  us  and  our  expectations  of  the  future,  about  which  we  cannot  be  certain.  Forward-looking  statements
include statements about:

·
·
·
·
·
·
·
·

·
·
·
·
·

·

our plans to commercialize ESKATA in the United States;
our plans to develop and commercialize our other drug candidates;
the timing of our planned clinical trials of our drug candidates;
the timing of the submission of our NDA for A-101 45% Topical Solution for the treatment of common warts;
the timing of and our ability to obtain and maintain regulatory approvals for our drug candidates;
the clinical utility of our drug candidates;
our commercialization, marketing and manufacturing capabilities and strategy;
our expectations about the willingness of patients to pay out of pocket for procedures using ESKATA for the
treatment of SK;
our expectations about the willingness of dermatologists to use ESKATA for the treatment of SK;
the timing of our INDs for our immunology drug candidates;
our efforts to obtain five year NCE exclusivity from the FDA and a patent term extension from the USPTO;
our intellectual property position;
our plans to in-license or acquire additional drug candidates for other dermatological conditions to build a fully
integrated dermatology company; and
our estimates regarding future revenue, expenses and needs for additional financing. 

You should refer to “Item 1A. Risk Factors” in this Annual Report for a discussion of important factors that may
cause our actual results to differ materially from those expressed or implied by our forward‑looking statements. As a result of
these  factors,  we  cannot  assure  you  that  the  forward‑looking  statements  in  this  Annual  Report  will  prove  to  be  accurate.
Furthermore,  if  our  forward‑looking  statements  prove  to  be  inaccurate,  the  inaccuracy  may  be  material.  In  light  of  the
significant uncertainties in these forward‑looking statements, you should not regard these statements as a representation or
warranty by us or any other person that we will achieve our objectives and plans in any specified time frame, or at all. The
forward-looking statements in this Annual Report represent our views as of the date of this Annual Report. We anticipate that
subsequent events and developments may cause our views to change. However, while we may elect to update these forward-
looking  statements  at  some  point  in  the  future,  we  undertake  no  obligation  to  publicly  update  any  forward‑looking
statements,  whether  as  a  result  of  new  information,  future  events  or  otherwise,  except  as  required  by  law.  You  should,
therefore, not rely on these forward-looking statements as representing our views as of any date subsequent to the date of this
Annual Report.

All  brand  names  or  trademarks  appearing  in  this  Annual  Report,  including  ESKATA,  are  the  property  of  their
respective owners. Unless the context requires otherwise, references in this report to “Aclaris,” the “Company,” “we,” “us,”
and “our” refer to Aclaris Therapeutics, Inc. and its subsidiaries.

2

 
 
 
 
 
TABLE OF CONTENTS

Table of Contents

PART I 
Item 1. Business 
Item 1A. Risk Factors 
Item 1B. Unresolved Staff Comments 
Item 2. Properties 
Item 3. Legal Matters 
Item 4. Mine Safety Disclosures 

PART II 
Item 5. Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity

Securities 

Item 6. Selected Consolidated Financial Data 
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations 
Item 7A. Quantitative and Qualitative Disclosure About Market Risk 
Item 8. Financial Statements and Supplementary Data 
Item 9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure 
Item 9A. Controls and Procedures 
Item 9B. Other Information 

PART III 
Item 10. Directors, Executive Officers and Corporate Governance 
Item 11. Executive Compensation 
Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters 
Item 13. Certain Relationships and Related Transactions, and Director Independence 
Item 14. Principal Accountant Fees and Services 

PART IV 
Item 15. Exhibits and Financial Statement Schedules 
Item 16.  Form 10-K Summary 
Signatures 

3

Page

4
27
65
66
66
66

67
69
70
88
89
122
122
122

123
123
123
123
123

124
126
127

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Item 1. Business

Overview

PART I

We  are  a  dermatologist-led  biopharmaceutical  company  focused  on  identifying,  developing  and  commercializing
innovative  and  differentiated  therapies  to  address  significant  unmet  needs  in  medical  and  aesthetic  dermatology  and
immunology.    Our  lead  product,  ESKATA  (hydrogen  peroxide)  topical  solution,  40%  (w/w),  or  ESKATA,  is  a  proprietary
formulation  of  high-concentration  hydrogen  peroxide  topical  solution  that  has  been  approved  by  the  U.S.  Food  and  Drug
Administration,  or  FDA,  as  a  prescription  treatment  for  raised  seborrheic  keratosis,  or  SK,  a  common  non-malignant  skin
tumor.  The FDA approved our New Drug Application, or NDA, for ESKATA for the treatment of raised SKs in December
2017, making ESKATA the first drug approved by the FDA for the treatment of raised SKs.  We also submitted a Marketing
Authorization Application, or MAA, for ESKATA in the European Union in July 2017.  We are also developing another high-
concentration formulation of hydrogen peroxide, A-101 45% Topical Solution, as a prescription treatment for common warts,
also known as verruca vulgaris.  Additionally, in 2015, we in-licensed exclusive, worldwide rights to certain inhibitors of the
Janus kinase, or JAK, family of enzymes, for specified dermatological conditions, including alopecia areata, or AA, as well
as  vitiligo  and  androgenetic  alopecia,  or  AGA,  also  known  as  male  or  female  pattern  baldness.    In  2016,  we  acquired
additional  intellectual  property  rights  for  the  development  and  commercialization  of  certain  JAK  inhibitors  for  specified
dermatological  conditions.    We  intend  to  continue  to  in-license  or  acquire  additional  drug  candidates  and  technologies  to
build a fully integrated dermatology company. 

SK lesions are among the most common non-malignant skin tumors and one of the most frequent diagnoses made
by  dermatologists.  SK  lesions  typically  have  a  waxy,  scaly,  slightly  elevated  appearance,  and  multiple  lesions  are  often
present. Though the lesions are non-malignant, patients often elect to have their condition treated by a dermatologist, either
because  the  lesions  have  become  inflamed  or  because  the  patient  feels  they  are  cosmetically  unattractive.    SK  lesions  are
usually treated by cryosurgery, electrodesiccation, curettage or excision. Each of these methods may be painful or can result
in pigmentary changes or scarring at the treatment site. 

We  are  developing  our  sales,  marketing  and  product  distribution  capabilities  for  ESKATA  in  order  to  support  a
commercial product launch in the United States, which we expect to occur in the second quarter of 2018.  We have also hired
a targeted sales force of 50 sales representatives which we believe will allow us to reach the approximately 6,000 health care
providers  in  the  United  States  with  the  highest  potential  for  using  ESKATA.    A  study  published  in  the  Journal  of  The
American Academy of Dermatology in 2006, which we refer to as the AAD study, estimated that SK affects over 83 million
people  in  the  United  States.  Based  on  a  market  survey  we  commissioned  in  2014,  we  estimate  that  there  are  18.5  million
patient  visits  to  dermatologists  for  SK  and  dermatologists  perform  approximately  8.3  million  procedures  to  remove  SK
lesions annually in the United States. We estimate that the cost of these procedures to third-party payors and patients is more
than $1.2 billion annually. 

We are developing A-101 45% Topical Solution for the treatment of common warts.  Although common warts are
generally not harmful and in most cases eventually clear without medical treatment, they may be painful and aesthetically
unattractive  and  are  contagious.    On  an  annual  basis,  approximately  2.0  million  people  are  diagnosed  with  common
warts.  As with SK lesions, cryosurgery is the most frequently used in-office treatment for common warts.  Common warts
can also be removed with slow-acting, over-the-counter products containing salicylic acid.  No prescription drugs have been
approved by the FDA for the treatment of common warts.  In January 2018, we reported top line results from two Phase 2
clinical trials of A-101 45% Topical Solution, WART-202 and WART-203, to assess the dose frequency in adult and pediatric
patients with common warts.  In these trials, we observed clinically and statistically significant outcomes for all primary and
secondary endpoints of each trial.  Based on these results, we expect to initiate Phase 3 clinical trials of A-101 45% Topical
Solution for the treatment of common warts in the second half of 2018.  Patients in both Phase 2 trials are continuing in a 3-
month  drug-free  follow-up  phase  of  these  trials.    We  expect  to  report  data  from  the  Phase  3  clinical  trials  of  A-101  45%
Topical Solution in the second half of 2019 and, if positive, submit an NDA to the FDA. 

4

 
 
 
 
 
 
 
Table of Contents

We are developing our JAK inhibitor drug candidates, ATI-501, formerly ATI-50001, and ATI-502, formerly ATI-
50002,  which  we  in-licensed  from  Rigel  Pharmaceuticals,  Inc.,  or  Rigel,  as  potential  treatments  for  AA.  AA  is  an
autoimmune  dermatologic  condition  typically  characterized  by  patchy  non-scarring  hair  loss  on  the  scalp  and  body.  More
severe forms of AA include total scalp hair loss, known as alopecia totalis, or AT, and total hair loss on the scalp and body,
known  as  alopecia  universalis,  or  AU.   AA  affects  up  to  2.0%  of  people  globally  at  some  point  during  their  lifetime  (i.e.
incidence) and up to 0.2% of people are affected at any given time (i.e. prevalence) - with two-thirds of affected individuals
being 30 years old or younger at the time of disease onset. Treatment options for the less severe, patchy forms of AA include
corticosteroids, either topically applied or injected directly into the scalp where the bare patches are located, or the induction
of  an  allergic  reaction  at  the  site  of  hair  loss  using  a  topical  contact  sensitizing  agent,  an  approach  known  as  topical
immunotherapy.  The  same  treatment  options  are  utilized  for  the  more  severe  forms  of  AA,  although  utilization  of  these
treatment  options  for  the  more  severe  forms  of  AA  is  limited  due  to  limited  efficacy,  certain  side  effects,  and  their
impracticality for extensive surface areas.  We are also developing ATI-502 for the treatment of vitiligo and another series of
JAK inhibitors for the treatment of AGA.

In August 2017, we acquired Confluence Life Sciences, Inc. or Confluence.  The acquisition of Confluence added
small  molecule  drug  discovery  and  preclinical  development  capabilities  that  allow  us  to  bring  early-stage  research  and
development activities in-house that we previously outsourced to third parties.  Through the acquisition of Confluence, we
also  acquired  several  preclinical  drug  candidates,  including  additional  JAK  inhibitors  known  as  “soft”  JAK  inhibitors,
inhibitors  of  the  MK-2  signaling  pathway  and  inhibitors  of  interleukin-2-inducible  T  cell  kinase,  or  ITK.    We  expect  to
submit an investigational new drug application, or IND, to the FDA for ATI-450, an MK-2 inhibitor, in mid-2019, and for our
soft JAK inhibitors and ITK inhibitors in the second half of 2019. 

Our  intellectual  property  portfolio  contains  issued  patents  directed  to  methods  of  use  for  high-concentration
hydrogen  peroxide  compositions  of  at  least  23%  or  more  hydrogen  peroxide,  including  ESKATA  and  A-101  45%  Topical
Solution and issued patents directed to our JAK inhibitor drug candidates, ATI-501 and ATI-502.  Our issued patents relating
to  the  use  of  A-101  high-concentration  hydrogen  peroxide  compositions  including  ESKATA  and  A-101  45%  Topical
Solution,  begin  to  expire  in  2022,  subject  to  any  applicable  patent  term  extension  that  may  be  available  in  a  particular
country. Our intellectual property portfolio also contains an issued U.S. patent, European and other foreign country patent
applications  directed  to,  among  other  things,  formulations  and  methods  of  use  for  high  concentration  hydrogen  peroxide
compositions,  including  ESKATA  and  A-101  45%  Topical  Solution  and  a  single-use,  self-contained,  pre-filled,  disposable
pen-type applicator for use with such formulations.  The issued U.S. formulation patent expires in 2035 and the pending U.S.,
European and other foreign country formulation patent applications, if they issue as patents, would also be expected to expire
in  2035,  subject  to  any  applicable  patent  term  adjustment  or  extension  that  may  be  available  in  a  particular  country.  With
respect to our JAK inhibitor drug candidates ATI-501 and ATI-502, the issued U.S. and foreign patents that specifically cover
the composition of matter for these compounds begin to expire in 2030, subject to any applicable patent term extension that
may  be  available  in  a  particular  country.  Our  intellectual  property  portfolio  also  contains  issued  patents  and  pending
applications  directed  to,  among  other  things,  the  use  of  JAK  inhibitors  for  treating  hair  loss  disorders  that  expire,  or  are
expected  to  expire,  in  2031,  subject  to  any  applicable  patent  term  adjustment  or  extension  that  may  be  available  in  a
particular country.

5

 
 
 
 
Table of Contents

Our Drug Candidates

We have utilized our experience to establish a pipeline of drug candidates that we believe will address significant

unmet needs in dermatology and immunology.  Our pipeline of drug candidates is summarized in the table below:

6

 
 
 
 
Table of Contents

ESKATA for the Treatment of Raised Seborrheic Keratosis

ESKATA, our lead product, is the first FDA-approved drug for the treatment of raised SKs.  SK lesions typically
have a waxy, scaly, slightly elevated appearance, and multiple lesions are often present.  The lesions can vary in color from
light  tan  to  dark  brown  or  black  and  typically  appear  on  the  face,  trunk  and  extremities.    Though  the  lesions  are  non-
malignant,  patients  often  elect  to  have  their  condition  treated  by  a  dermatologist,  either  because  the  lesions  have  become
inflamed or because the patient feels they are cosmetically unattractive. 

In November 2016, we completed two pivotal Phase 3 clinical trials of ESKATA in a combined 937 patients who
each had a total of four target SK lesions located on the face, trunk and extremities.  Each trial met all primary and secondary
endpoints for that trial, achieving clinically and statistically significant clearance of SK lesions. Additionally, we completed
an open-label safety trial of ESKATA in November 2016, in which we enrolled 147 subjects.  Across all three clinical trials,
there were no treatment-related serious adverse events among patients treated with ESKATA, and the most common adverse
events  reported  were  nasopharyngitis  and  sinusitis  which  were  determined  to  be  unrelated  to  ESKATA.    Based  on  these
results, we submitted an NDA for ESKATA for the treatment of raised SKs to the FDA in February 2017, and the NDA was
approved by the FDA in December 2017.  We also submitted an MAA in the European Union for ESKATA in July 2017. 

We  are  developing  our  sales,  marketing  and  product  distribution  capabilities  for  ESKATA  in  order  to  support  a
commercial product launch in the United States, which we expect to occur in the second quarter of 2018.  We have also hired
a targeted sales force of 50 sales representatives which we believe will allow us to reach the approximately 6,000 health care
providers in the United States with the highest potential for prescribing ESKATA to their patients. 

A-101 45% Topical Solution for Treatment of Common Warts

We are developing A-101 45% Topical Solution for the treatment of common warts.  Although common warts are
generally not harmful and in most cases eventually clear without medical treatment, they may be painful and aesthetically
unattractive and are contagious.  On an annual basis, approximately 2.0 million people are diagnosed with common warts. As
with SK lesions, cryosurgery is the most frequently used in-office treatment for common warts.  Common warts can also be
removed with slow-acting, over-the-counter products containing salicylic acid.  No prescription drugs have been approved by
the FDA for the treatment of common warts.  We completed a Phase 2 clinical trial, WART-201, in August 2016 evaluating
40%  and  45%  concentrations  of  A-101  for  the  treatment  of  common  warts,  in  which  we  observed  statistically  significant
improvements in the mean change in the Physician’s Wart Assessment, or PWA, score and in complete clearance of common
warts in patients treated with the 45% concentration of A-101 compared to placebo.  The PWA score is a four-point scale of
the investigators assessment of the severity of a target wart at a particular time point. 

In  June  2017,  we  commenced  two  additional  Phase  2  clinical  trials,  WART-202  and  WART-203,  of  A-101  45%
Topical Solution to assess the dose frequency in adult and pediatric patients with common warts.  Both trials evaluated the
safety and efficacy of A-101 45% as compared to placebo, or vehicle.  The two randomized, double-blind, vehicle-controlled
trials  were  designed  to  understand  the  effects  of  dose  frequency  and  to  explore  additional  clinical  endpoints  that  will  be
further evaluated in a planned Phase 3 development program.  We enrolled a total of 316 patients at 34 investigational centers
in the United States across both trials.  In January 2018, we reported top line results from these two Phase 2 clinical trials of
A-101  45%  Topical  Solution.    The  results  demonstrated  clinically  and  statistically  significant  outcomes  for  primary,
secondary and exploratory endpoints, analyzed to date, of each of the two additional Phase 2 trials.  There were no treatment-
related serious adverse events among patients treated with A-101 45% Topical Solution. 

The  WART-202  trial  evaluated  157  patients  who  self-administered  either  A-101  45%  Topical  Solution  or  placebo
once weekly through Day 56, for a total of 8 treatments.  Each patient had between one and four warts at baseline. The trial
achieved its primary endpoint, which was mean change from baseline in the PWA score of the target wart at Day 56 (one
week after the last treatment).  The mean reduction in PWA score at Day 56 on the target warts was 0.77 points in patients
who received A-101 45% Topical Solution, compared to a reduction of 0.23 points for the target warts that received placebo,
a result that was also statistically significant (p<0.001). 

The  WART-203  trial  evaluated  159  patients  who  self-administered  either  A-101  45%  Topical  Solution  or  placebo

twice weekly through Day 56, for a total of 16 treatments.  Each patient had between one and six warts at baseline.  The

7

 
 
 
 
 
 
 
 
 
 
Table of Contents

WART-203  trial  achieved  its  primary  endpoint,  which  was  mean  change  from  baseline  in  the  PWA  scale  score  at  Day  56
(Visit 10 or one week after the last treatment).  The mean reduction in PWA score at Day 56 on the target warts was 0.87
points in patients who received A-101 45%, compared to a reduction of 0.17 points for the target warts that received placebo,
a result that was statistically significant (p<0.001). 

Patients in both Phase 2 trials, WART-202 and WART-203, are continuing in a 3-month drug-free follow-up phase of
these trials.  Based on the results of these Phase 2 clinical trials, we expect to initiate Phase 3 clinical trials of A-101 45%
Topical Solution for the treatment of common warts in the second half of 2018.  We expect to report data from these Phase 3
clinical trials of A-101 45% Topical Solution in the second half of 2019 and, if positive, submit an NDA to the FDA. 

ATI-501 and ATI-502

We  are  developing  the  JAK  inhibitors,  ATI-501  and  ATI-502,  which  we  in-licensed  from  Rigel  as  potential
treatments for AA. AA is an autoimmune dermatologic condition typically characterized by patchy non-scarring hair loss on
the scalp and body.  More severe forms of AA include AT, which is total scalp hair loss, and AU, which is total hair loss on
the scalp and body.  AA affects up to 2.0% of people globally at some point during their lifetime (i.e. incidence) and up to
0.2% of people are affected at any given time (i.e. prevalence) - with two-thirds of affected individuals being 30 years old or
younger at the time of disease onset. Treatment options for the less severe, patchy forms of AA include corticosteroids, either
topically applied or injected directly into the scalp where the bare patches are located, or the induction of an allergic reaction
at  the  site  of  hair  loss  using  a  topical  contact  sensitizing  agent,  an  approach  known  as  topical  immunotherapy.   The  same
treatment options are utilized for the more severe forms of AA, although utilization of these treatment options for the more
severe forms of AA is limited due to limited efficacy, certain side effects, and their impracticality for extensive surface areas.

We are developing ATI-501 as an oral treatment for AA.  We submitted an IND to the FDA for ATI-501 in October
2016, and we completed a Phase 1 clinical trial to evaluate the pharmacokinetic and pharmacodynamic, or PK/PD, properties
of this drug candidate in the first quarter of 2017. 

We are developing ATI-502 as a topical treatment for AA, vitiligo, AGA and loss of eyebrow hair.  We submitted an
IND to the FDA for ATI-502 for the treatment of AA in July 2017.  We are also developing another series of JAK inhibitors
for the treatment of AGA.  The following table summarizes the status of our ongoing Phase 2 clinical trials of ATI-501 and
ATI-502, including their indications, trial objectives and expected timing for initiation and receipt of preliminary results: 

Study

Indication

Objective

Patients

Expected
Initiation

P

Preliminary
Results
Expected

ATI-501-AUAT-201

AT/AU

Dose-ranging

120-160

1H 2018

Mid 2019

ATI-502-AA-201
ATI-502-AA-202
ATI-502-AUATB-201
ATI-502-VITI-201
ATI-502-AGA-201

AA
AA
Eyebrow
Vitiligo
AGA

Dose-ranging
PK/PD
Open-label study
Open-label study
Open-label study

120
12
24
24
24

2H 2017
2H 2017
2H 2017
2H 2017
1H 2018

2H 2018
1H 2018
Mid 2018
1H 2019
1H 2019

8

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Manufacturing and Supply

We do not have any manufacturing facilities.  We rely on third parties for the manufacture of preclinical and clinical
supplies for all of our drug candidates.  We also rely on third parties for the commercial manufacture of ESKATA.  We have
entered  into  an  exclusive,  ten-year,  automatically  renewable  supply  agreement  with  PeroxyChem  LLC,  or  PeroxyChem,
which  goes  into  effect  on  the  date  of  first  commercial  sale  of  ESKATA,  to  provide  hydrogen  peroxide,  the  active
pharmaceutical  ingredient,  or  API,  that  can  be  used  in  ESKATA  for  the  treatment  of  raised  SKs  and  a  number  of  other
specified  dermatological  indications.    We  or  PeroxyChem  may  terminate  the  supply  agreement  with  prior  written  notice
immediately for specified financial reasons, after a 10-day and 60-day cure period for material monetary and non-monetary
material breaches, respectively, and in the event of a force majeure event, that continues for 90 consecutive days. In addition,
we may terminate the PeroxyChem supply agreement, with prior written notice, for PeroxyChem's failure to supply API to us
for more than 90 cumulative days in a year. 

We  have  entered  into  an  exclusive  commercial  supply  agreement  with  James  Alexander  Corporation,  or  James
Alexander, for the manufacture of the finished dosage form of ESKATA.  We must meet a minimum purchase requirement
each year between 2018 and 2022.  Additionally, during the term of the agreement, James Alexander will not manufacture
any competitive product, as defined in the agreement. In the event that we do not meet the purchase minimum requirements
James Alexander’s exclusivity obligation will cease.  The term of the agreement with James Alexander is five years from the
date of the first commercial sale of ESKATA and thereafter will be renewed automatically for one-year periods. Either party
may  terminate  the  agreement  for  any  reason  upon  180  days  prior  written  notice.  In  addition,  either  party  has  the  right  to
immediately terminate the supply agreement under certain circumstances including (i) the other party files for bankruptcy, (ii)
the other party materially breaches the supply agreement and such breach is not cured within a specified period and (iii) any
required license, permit or certificate required of the other party to perform its obligations under the supply agreement is not
approved or issued or is revoked by an applicable governmental regulatory authority. 

Replacement of any of these third-party manufacturers would require us to qualify new manufacturers and negotiate
and execute contractual agreements with them. If any of our supply or service agreements with third-party manufacturers are
terminated, we will experience delays and additional expenses in the commercialization of ESKATA.

Commercialization

We are planning to commercialize ESKATA ourselves in the United States, and to establish collaborations with third
parties  to  commercialize  it  outside  the  United  States,  if  approved.    We  are  developing  our  sales,  marketing  and  product
distribution capabilities for ESKATA, and we have hired a targeted sales force of 50 sales representatives, in order to support
a commercial product launch in the United States, which we expect to occur in the second quarter of 2018.  We believe a
scientifically  oriented,  customer-focused  team  of  50  sales  representatives  will  allow  us  to  reach  the  approximately  6,000
health care providers in the United States with the highest potential for prescribing ESKATA to their patients.  We estimate
these  health  care  providers  will  continue  to  account  for  over  70%  of  in-office  SK  treatments  performed  in  the  United
States.    Our  sales  force  will  be  supported  by  sales  and  marketing  management,  internal  sales  and  marketing,  a  direct-to-
consumer advertising campaign, and commercial product distribution. 

We believe dermatologists will be inclined to adopt ESKATA to treat their patients with SK lesions not only because
of  its  clinical  profile,  but  also  because  it  may  provide  an  expanded  source  of  revenue  for  their  practices.  Dermatologists
expect declining reimbursements from third-party payors for providing medical services. In addition, a greater portion of the
cost of medical care has been shifted to patients, in the form of higher deductibles and co‑insurance. Collecting from patients
can be difficult and costly for physician practices. We believe many dermatologists are interested in expanding the cash-pay
aesthetic portion of their practices, meaning the portion of procedures that are not medically necessary and not reimbursed by
third-party payors, by treating new aesthetic patients and by offering new services to current aesthetic patients. Though SK
patients typically come into the dermatology practice seeking a medical diagnosis, we believe they often are willing to pay
for removal of SK lesions to improve appearance even after they learn that the lesions are non-malignant, and that removal
may not be reimbursed. In addition, since ESKATA can be administered by non-physician staff, we believe it could provide
incremental practice revenue with minimal time commitment by the dermatologist after the diagnosis is made.

We believe dermatologists tend to be particularly focused on the safety of pharmaceutical products because, while
skin  diseases  can  have  profound  effects  on  patients'  quality  of  life,  few  are  life-threatening.  As  a  result,  we  believe  that
dermatologists, as well as their patients, often prefer to use topical treatments when possible to limit the risk of systemic

9

 
 
 
 
 
 
 
 
Table of Contents

side effects. Dermatologists also tend to place a high level of emphasis on products that are easy to use because they often
manage high volumes of patients. We believe this also contributes to a general preference for topical treatments. Finally, in
our  experience,  dermatologists  tend  to  engage  with  sales  and  medical  affairs  personnel  from  the  pharmaceutical  industry
regarding the scientific evidence supporting dermatology products and the challenges experienced by physicians and patients
in the use of these products. Dermatologists often rely on trusted relationships with scientifically oriented, customer-focused
sales representatives who can provide them with the necessary information to support their use of appropriate treatments.

Competition

The pharmaceutical industry is characterized by rapidly advancing technologies, intense competition and a strong
emphasis  on  proprietary  drugs.  While  we  believe  that  our  knowledge,  experience  and  scientific  resources  provide  us  with
competitive  advantages,  we  face  potential  competition  from  many  different  sources,  including  major  pharmaceutical,
biotechnology  and  specialty  pharmaceutical  companies,  academic  institutions  and  governmental  agencies  and  public  and
private research institutions. Any drug candidates that we successfully develop and commercialize will compete with existing
treatments and new treatments that may become available in the future.

The key competitive factors affecting the success of ESKATA for the treatment of raised SKs, are likely to be its
efficacy,  safety,  non-invasiveness,  pain  profile  and  ability  to  be  administered  by  non-physician  staff.    With  respect  to
ESKATA for the treatment of raised SKs, we are aware of the following companies that are developing treatments for SK:
BioLineRx  Ltd.  is  developing  an  over-the-counter  drug  candidate  targeting  multiple  skin  conditions,  including  SK;
Skincential  Sciences,  Inc.  currently  markets  a  line  of  cosmetic  products  targeting  skin  conditions,  including  SK;  and
Epipharm, AG is developing a topical drug candidate targeting multiple skin conditions, including SK.  We are also aware of
early  research  being  conducted  with  Akt  inhibitors  as  a  potential  treatment  for  SK.  None  of  these  products  have  been
approved by the FDA for the treatment of SK in the United States. 

With  respect  to  A-101  45%  Topical  Solution  for  the  treatment  of  common  warts,  we  are  aware  of  the  following
companies that are developing treatments for common warts: Nielsen BioSciences, Inc. is developing a drug candidate for the
treatment  of  common  warts;  BioLineRx  Ltd.  is  developing  an  over-the-counter  drug  candidate  targeting  multiple  skin
conditions, including common warts; Cutanea Lifesciences, Inc. is developing a drug candidate for the treatment of common
warts; and RXi Pharmaceuticals, Inc. is also developing a drug candidate for the treatment of common warts. In addition,
other drugs have been used off-label as treatments for common warts. We could also encounter competition from over-the-
counter treatments for common warts. 

With respect to ATI-501 and ATI-502 for the treatment of AA, we anticipate competing with sensitizing agents such
as  diphencyprone,  and  topical,  intralesional  and  systemic  corticosteroids,  which  have  been  found  to  occasionally  reduce
symptoms of AA. Other treatments utilized for patchy AA include anthralin and minoxidil solution. We may also compete
with  companies  developing  chemical  agents  to  be  used  in  topical  immunotherapies,  as  well  as  companies  developing
biologics, immunosuppressive agents, laser therapy, phototherapy, other JAK inhibitors and prostaglandin analogues to treat
AA.

Our  commercial  opportunity  could  be  reduced  or  eliminated  if  our  competitors  develop  and  commercialize  drugs
that are safer, more effective, have fewer or less severe side effects, are more convenient or are less expensive than ESKATA
or any other drug that we may develop. Our competitors also may obtain FDA or other regulatory approval for their drugs
more  rapidly  than  we  may  obtain  approval  for  our  drug  candidates,  which  could  result  in  our  competitors  establishing  a
strong market position before we are able to enter the market. Many of the companies against which we are competing, or
against  which  we  may  compete  in  the  future,  have  significantly  greater  financial  resources  and  expertise  in  research  and
development,  manufacturing,  preclinical  testing,  conducting  clinical  trials,  obtaining  regulatory  approvals  and  marketing
approved drugs than we do. Mergers and acquisitions in the pharmaceutical and biotechnology industries may result in even
more resources being concentrated among a smaller number of our competitors. Smaller or early-stage companies may also
prove  to  be  significant  competitors,  particularly  through  collaborative  arrangements  with  large  and  established  companies.
These  competitors  also  compete  with  us  in  recruiting  and  retaining  qualified  scientific  and  management  personnel  and
establishing clinical trial sites and subject registration for clinical trials, as well as in acquiring technologies complementary
to, or that may be necessary for, our programs.

10

 
 
 
 
 
 
 
 
Table of Contents

Intellectual Property

Our  success  depends  in  large  part  upon  our  ability  to  obtain  and  maintain  proprietary  protection  for  our  drug
candidates and to operate without infringing the proprietary rights of others. We seek to avoid the latter by monitoring patents
and publications that may affect our business, and to the extent we identify such developments, evaluate and take appropriate
courses of action. Our policy is to protect our proprietary position by, among other methods, filing for patent applications on
inventions that are important to the development and conduct of our business with the U.S. Patent and Trademark Office, or
USPTO, and its foreign counterparts.

With respect to ESKATA and A-101 45% Topical Solution, we do not currently rely on licenses to any third party's
intellectual  property.  We  own  two  U.S.  patents  that  include  claims  that  cover  the  use  of  high-concentration  hydrogen
peroxide of at least 23%, including ESKATA and A-101 45% Topical Solution, for the alleviation of SK and acrochordons.
The patents in Australia, New Zealand and India include claims that cover the use of high-concentration hydrogen peroxide
of at least 23%, including ESKATA and A-101 45% Topical Solution, for the alleviation of various skin conditions including
SK, acrochordons, corns, tags, acne, warts and rosacea. The patents in Germany, the United Kingdom, Mexico and Singapore
include claims that cover the use of high-concentration hydrogen peroxide of at least 23%, including ESKATA and A-101
45% Topical Solution for the alleviation of acrochordons. The issued patents relating to the use of ESKATA and A-101 45%
Topical Solution begin to expire in 2022, subject to any applicable patent term extension that may be available in a particular
country. 

We also own one issued U.S. patent and pending U.S., European and other foreign patent applications directed to
various  formulations  comprising  high-concentration  hydrogen  peroxide,  including  ESKATA  and  A-101  45%  Topical
Solution dosing regimens for such formulations, applicators for use with such formulations, and methods of treating various
skin conditions, including SK and common warts, by the topical administration of such formulations.  Our U.S. formulation
patent expires in 2035 and any claims that issue from the pending formulation applications will expire in 2035, subject to any
applicable patent term adjustment or extension that may be available in a particular country.  In addition, we own a U.S. and
PCT  patent  application  directed  to  the  use  of  high-concentration  hydrogen  peroxide,  including  ESKATA  and  A-101  45%
Topical Solution, for the treatment of warts.  Any claims that issue from these applications will expire in 2037, subject to any
applicable patent term adjustment or extension that may be available in a particular country.

With  respect  to  ATI-501  and  ATI-502,  we  exclusively  licensed  from  Rigel  multiple  families  of  patents  and
applications  relating  to  these  compounds  and  the  uses  thereof  in  the  field  of  dermatology.    In  particular,  we  exclusively
licensed patents and applications with claims that specifically cover the composition of matter for these compounds in the
United  States,  the  European  Union,  and  other  major  foreign  markets.  The  issued  patents  specifically  directed  to  these
compounds  begin  to  expire  in  2030,  subject  to  any  applicable  patent  term  extension  that  may  be  available  in  a  particular
country. We also exclusively licensed an issued U.S. patent and pending applications in the United States, Australia, Canada,
the European Union and Japan with claims that cover the use of these compounds for the treatment of alopecia areata.  The
U.S. patent, and any claims that issue from these applications, expire, or will expire, in 2034, subject to any applicable patent
term  adjustment  or  extension  that  may  be  available  in  a  particular  country.  We  also  licensed  a  family  of  patents  and
applications that relate to ATI-501 and ATI-502 that expire in 2023, subject to any applicable patent term extension that may
be available in a particular country.

We  also  exclusively  licensed  patents  and  applications  from  Columbia  University  relating  to  the  use  of  JAK
inhibitors to induce hair growth and treat hair loss disorders, including AA and AGA.  In particular, we exclusively licensed
multiple  U.S.  patents  with  claims  directed  to  the  use  of  certain  third-party  JAK  inhibitors  for  the  treatment  of  hair  loss
disorders, including AA and AGA, and inducing hair growth, which expires in 2031.  We also exclusively licensed patents
and  applications  with  claims  directed  to  the  use  of  certain  JAK1,  JAK2  or  JAK3  inhibitors  for  the  treatment  of  hair  loss
disorders, including AA and AGA, and inducing hair growth in the U.S., the European Union, Japan and South Korea.  Any
claims that issue from the pending applications begin to expire in 2031, subject to any applicable patent term adjustment or
extension that may be available in a particular country.  In addition, we exclusively licensed patent applications in the United
States and other foreign countries directed to methods of inducing hair growth with JAK1, JAK2 or JAK3 inhibitors as well
as  biomarkers  for  AA,  which  if  claims  issue,  would  expire  in  2036,  subject  to  any  applicable  patent  term  adjustment  or
extension that may be available in a particular country.

With respect to our inhibitors of the MK-2 signaling pathway, we own one U.S. patent and pending applications in
the  European  Union  and  other  foreign  countries  that  cover  our  lead  candidate.    The  U.S.  patent  expires  in  2034  and  any
claims that issue from the pending applications expire in 2034, subject to any applicable patent term adjustment or

11

 
 
 
 
 
 
 
Table of Contents

extension that may be available in a particular country.  We also own six U.S. patents and pending foreign patent applications
directed  to  other  inhibitors  of  the  MK-2  signaling  pathway,  which  expire  or  will  expire  in  2031  and  2032,  subject  to  any
applicable patent term adjustment or extension that may be available in a particular country. 

With  respect  to  our  “soft”  JAK  inhibitors,  we  have  filed  a  number  of  provisional  applications  directed  to  various
novel inhibitors of JAK1 and/or JAK3 and methods of using the same.  Any claims that may issue would expire in 2038,
subject to any applicable patent term adjustment or extension that may be available in a particular country.

With respect to our ITK inhibitors, we own multiple U.S. patents and pending applications in the United States and
foreign countries directed to novel inhibitors of ITK and methods of using the same.  The patents and pending applications, if
issued, expire between 2035 and 2038, subject to any applicable patent term adjustment or extension that may be available in
a particular country.

We  also  use  other  forms  of  protection,  such  as  trademark,  copyright,  and  trade  secret  protection,  to  protect  our
intellectual  property,  particularly  where  we  do  not  believe  patent  protection  is  appropriate  or  obtainable.  We  aim  to  take
advantage of all of the intellectual property rights that are available to us and believe that this comprehensive approach will
provide us with proprietary positions for our drug candidates, where available.

Patents  extend  for  varying  periods  according  to  the  date  of  patent  filing  or  grant  and  the  legal  term  of  patents  in
various  countries  where  patent  protection  is  obtained.  The  actual  protection  afforded  by  a  patent,  which  can  vary  from
country  to  country,  depends  on  the  type  of  patent,  the  scope  of  its  coverage  and  the  availability  of  legal  remedies  in  the
country.  In  most  countries  in  which  we  file,  the  patent  term  is  20  years  from  the  earliest  date  of  filing  a  non-provisional
patent  application.  In  the  United  States,  a  patent  term  may  be  shortened  if  a  patent  is  terminally  disclaimed  over  another
patent or as a result of delays in patent prosecution by the patentee, and a patent's term may be lengthened by patent term
adjustment,  which  compensates  a  patentee  for  administrative  delays  by  the  USPTO  in  granting  a  patent  or  by  patent  term
extension, which compensates a patentee for delays at the FDA. The patent term of a European patent is 20 years from its
filing date; however, unlike in the United States, the European patent does not grant patent term adjustments. The European
Union does have a compensation program similar to patent term extension called supplementary patent certificate that would
effectively extend patent protection for up to five years.

We also protect our proprietary information by requiring our employees, consultants, contractors and other advisors
to  execute  nondisclosure  and  assignment  of  invention  agreements  upon  commencement  of  their  respective  employment  or
engagement. Agreements with our employees also prevent them from bringing the proprietary rights of third parties to us. In
addition, we also require confidentiality or service agreements from third parties that receive our confidential information or
materials.

Assignment Agreement and Finder's Services Agreement

In August 2012, we entered into an assignment agreement with the Estate of Mickey Miller, or the Miller Estate,
under which we acquired some of the intellectual property rights covering ESKATA and A-101 45% Topical Solution.  The
assignment  of  intellectual  property  rights  covers  specified  know-how,  along  with  modifications  of,  improvements  to  and
variations on A-101 that meet defined chemical properties. Under the agreement, we have the sole and exclusive right, but
not  the  duty,  to  develop,  obtain  marketing  approval  for  and  commercialize  ESKATA  and  A-101  45%  Topical  Solution  in
various  countries  throughout  the  world.  We  are  required  to  use  commercially  reasonable  efforts  to  develop  and
commercialize  at  least  one  product  for  at  least  one  indication  in  the  United  States.  In  connection  with  obtaining  the
assignment  of  the  intellectual  property  from  the  Miller  Estate,  we  also  entered  into  a  separate  finder's  services  agreement
with KPT Consulting, LLC. 

Under  the  terms  of  the  assignment  agreement  and  the  finder's  services  agreement,  we  made  aggregate  upfront
payments  of  $0.6  million  in  2012  and  one-time  milestone  payments  of  $0.4  million  in  2013  upon  the  dosing  of  the  first
human subject with ESKATA in our Phase 2 clinical trial. There are no remaining potential milestone payments under the
assignment  agreement.  Under  the  finder's  services  agreement,  we  made  a  one-time  milestone  payment  of  $0.3  million  in
February  2016  upon  the  dosing  of  the  first  human  subject  with  ESKATA  in  our  Phase  3  clinical  trial,  and  a  one-time
milestone  payment  of  $1.0  million  in  April  2017  upon  the  achievement  of  specified  development  and  regulatory
milestones.    We  are  obligated  to  make  additional  milestone  payments  up  to  an  aggregate  of  $4.5  million  upon  the
achievement  of  specified  commercial  milestones.    Under  each  of  the  assignment  agreement  and  the  finder's  services
agreement, we are also obligated to pay royalties on sales of ESKATA or related products, at low single-digit percentages

12

 
 
 
 
 
 
 
 
 
Table of Contents

of net sales, subject to reduction in specified circumstances. We have not made any royalty payments to date under either
agreement.  Both  agreements  will  terminate  upon  the  expiration  of  the  last  pending,  viable  patent  claim  of  the  patents
acquired under the assignment agreement, but no sooner than 15 years from the effective date of the agreements.

License Agreement with Rigel

In  August  2015,  we  entered  into  an  exclusive,  worldwide  license  and  collaboration  agreement  with  Rigel  for  the
development and commercialization of products containing two specified JAK inhibitors, ATI-501 and ATI-502. Under this
agreement,  we  intend  to  develop  these  JAK  inhibitors  for  the  treatment  of  AA  and  potentially  for  other  dermatological
conditions. We paid Rigel an upfront non-refundable payment of $8.0 million and have agreed to make aggregate payments
of  up  to  $80.0  million  upon  the  achievement  of  specified  pre-commercialization  milestones,  such  as  clinical  trials  and
regulatory approvals. Further, we have agreed to pay up to an additional $10.0 million to Rigel upon the achievement of a
second  set  of  development  milestones.  With  respect  to  any  products  we  commercialize  under  the  agreement,  we  will  pay
Rigel quarterly tiered royalties on our annual net sales of each product at a high single-digit percentage of annual net sales,
subject to specified reductions, until the date that all of the patent rights for that product have expired, as determined on a
country-by-country and product-by-product basis or, in specified countries under specified circumstances, ten years from the
first commercial sale of such product.

The agreement terminates on the date of expiration of all royalty obligations unless earlier terminated by either party
for a material breach. We may also terminate the agreement without cause at any time upon advance written notice to Rigel.
Rigel, after consultation with us, will be responsible for maintaining and prosecuting the patent rights, and we will have final
decision-making  authority  regarding  such  patent  rights  for  a  product  in  the  United  States  and  the  European  Union.  To  the
extent  that  we  jointly  develop  intellectual  property,  we  will  confer  and  decide  which  party  will  be  responsible  for  filing,
prosecuting and maintaining those patent rights. The agreement also establishes a joint steering committee composed of an
equal number of representatives for each party, which will monitor progress of the development of products.

Stock Purchase Agreement with Vixen Pharmaceuticals, Inc.

On March 24, 2016, we entered into a stock purchase agreement with Vixen Pharmaceuticals, Inc., or Vixen,  and
JAK1, LLC, JAK2, LLC and JAK3, LLC, all together with Vixen, the Selling Stockholders, and Shareholder Representative
Services  LLC,  a  Colorado  limited  liability  company,  solely  in  its  capacity  as  the  representative  of  the  Selling
Stockholders.    Pursuant  to  the  stock  purchase  agreement,  we  acquired  all  shares  of  Vixen’s  capital  stock  from  the  Selling
Stockholders,  the  Vixen  Acquisition.    Following  the  Vixen  Acquisition,  Vixen  became  a  wholly-owned  subsidiary  of
us.  Pursuant to the stock purchase agreement, we paid $0.6 million upfront and issued an aggregate of 159,420 shares of our
common stock to the Selling Stockholders. We are obligated to make annual payments of $0.1 million on March 24  of each
year, through March 2022, with such amounts being creditable against specified future payments that may be paid under the
stock purchase agreement.

th

Under  the  stock  purchase  agreement,  we  agreed  to  use  commercially  reasonable  efforts  to  develop  and
commercialize at least one product for the treatment of AA in humans and at least one product for the treatment of AGA in
humans, in each case for commercial sale and distribution throughout the United States and such other areas of the world as
we determine to be commercially prudent.  In the event we do not comply with these obligations, we are obligated to license,
on  a  non-exclusive  basis,  certain  intellectual  property  rights  related  to  the  products  to  the  Selling  Stockholders  or  their
designee, on terms to be mutually agreed to by the parties, among other rights exercisable by the Selling Stockholders.

We  are  obligated  to  make  aggregate  payments  of  up  to  $18.0  million  to  the  Selling  Stockholders  upon  the
achievement of specified pre-commercialization milestones for three products in the United States, the European Union and
Japan,  and  aggregate  payments  of  up  to  $22.5  million  upon  the  achievement  of  specified  commercial  milestones.  With
respect to any commercialized products covered by the stock purchase agreement, we are obligated to pay low single-digit
royalties on net sales, subject to specified reductions, limitations and other adjustments, until the date that all of the patent
rights  for  that  product  have  expired,  as  determined  on  a  country-by-country  and  product-by-product  basis  or,  in  specified
circumstances, ten years from the first commercial sale of such product. If we sublicense any of Vixen’s patent rights and
know-how acquired pursuant to the stock purchase agreement, we will be obligated to pay a portion of any consideration we
receive from such sublicenses in specified circumstances. 

13

 
 
 
 
 
 
 
 
 
Table of Contents

License Agreement with Columbia University 

As a result of the Vixen Acquisition, we became party to the Exclusive License Agreement, by and between Vixen
and  the  Trustees  of  Columbia  University  in  the  City  of  New  York,  or  Columbia,  dated  as  of  December  31,  2015,  or  the
Columbia License Agreement.  Pursuant to the Columbia License Agreement, Vixen was granted an exclusive, worldwide
license under specified Columbia patent rights and a non-exclusive, worldwide license under specified Columbia know-how
in all fields to develop and commercialize a product that otherwise infringes a Columbia patent right or uses Columbia know-
how.    Vixen’s  rights  to  this  Columbia  intellectual  property  cover  the  use  of  specified  JAK  inhibitor  compounds  for  the
potential treatment of AA, AGA and other dermatological conditions. 

We  are  obligated  to  pay  Columbia  an  annual  license  fee  of  $10,000,  subject  to  specified  adjustments  for  patent
expenses  incurred  by  Columbia  and  creditable  against  any  royalties  that  may  be  paid  under  the  Columbia  License
Agreement. We are also obligated to pay up to an aggregate of $11.6 million upon the achievement of specified commercial
milestones,  including  specified  levels  of  net  sales  of  products  covered  by  Columbia  patent  rights  and/or  know-how,  and
royalties at a sub-single-digit percentage of annual net sales of products covered by Columbia patent rights and/or know-how,
subject to specified adjustments. If we sublicense any of Columbia’s patent rights and know-how acquired pursuant to the
Columbia  License  Agreement,  we  will  be  obligated  to  pay  Columbia  a  portion  of  any  consideration  received  from  such
sublicenses in specified circumstances.  The royalties, as determined on a country-by-country and product-by-product basis,
are payable until the date that all of the patent rights for that product have expired, the expiration of any market exclusivity
period granted by a regulatory body or, in specified circumstances, ten years from the first commercial sale of such product.

We have agreed to use commercially reasonable efforts to develop and commercialize at least one product. In the
event we do not comply with this obligation, Columbia has the option to terminate the license or convert the exclusive patent
license to a non-exclusive patent license. Further, in the event we do not comply with our obligations under the Vixen stock
purchase agreement to develop and commercialize products, our rights under the Columbia License Agreement may revert to
a  party  to  be  designated  by  the  Selling  Stockholders.    Columbia  is  responsible  for  maintaining  and  prosecuting  the  patent
rights, giving due consideration to our reasonable comments related thereto.

The Columbia License Agreement terminates on the date of expiration of all royalty obligations thereunder unless
earlier  terminated  by  either  party  for  a  material  breach,  subject  to  a  specified  cure  period.  We  may  also  terminate  the
Columbia License Agreement without cause at any time upon advance written notice to Columbia.

Agreement and Plan of Merger with Confluence

In August 2017, we entered into an Agreement and Plan of Merger with Confluence, Aclaris Life Sciences, Inc., our
wholly-owned subsidiary, or Merger Sub, and Fortis Advisors LLC, as representative of the equity holders of Confluence, or
the Agreement and Plan of Merger.  Pursuant to the terms of the Agreement and Plan of Merger, the Merger Sub merged with
and  into  Confluence,  with  Confluence  surviving  as  a  wholly-owned  subsidiary  of  Aclaris,  resulting  in  our  acquisition  of
100%  of  the  outstanding  shares  of  Confluence.    Pursuant  to  the  terms  of  the  Agreement  and  Plan  of  Merger,  we  gave
aggregate consideration with a fair value of $24.3 million to the equity holders of Confluence. 

We  also  agreed  to  pay  the  Confluence  equity  holders  aggregate  contingent  consideration  of  up  to  $80.0  million,
based upon the achievement of certain development, regulatory and commercial milestones set forth in the Agreement and
Plan  of  Merger.    Of  the  contingent  consideration,  $2.5  million  may  be  paid  in  shares  of  our  common  stock  upon  the
achievement  of  a  specified  development  milestone.    In  addition,  we  have  agreed  to  pay  the  Confluence  equity  holders
specified  future  royalty  payments  calculated  as  a  low  single-digit  percentage  of  annual  net  sales,  subject  to  specified
reductions,  limitations  and  other  adjustments,  until  the  date  that  all  of  the  patent  rights  for  that  product  have  expired,  as
determined  on  a  country-by-country  and  product-by-product  basis  or,  in  specified  circumstances,  ten  years  from  the  first
commercial sale of such product.  In addition, if we sell, license or transfer any of the intellectual property acquired from
Confluence pursuant to the Agreement and Plan of Merger to a third party, we will be obligated to pay the Confluence equity
holders a portion of any incremental consideration (in excess of the development and milestone payments described above)
that we receive from such sale, license or transfer in specified circumstances. 

14

 
 
 
 
 
 
 
 
 
 
Table of Contents

Government Regulation and Product Approval

Governmental authorities in the United States, at the federal, state and local level, and analogous authorities in other
countries  extensively  regulate,  among  other  things,  the  research,  development,  testing,  manufacture,  safety  surveillance,
efficacy,  quality  control,  labeling,  packaging,  distribution,  record  keeping,  promotion,  storage,  advertising,  distribution,
marketing, sale, export and import, and the reporting of safety and other post-market information of products such as the one
we are developing. A drug candidate must be approved by the FDA before it may be legally promoted in the United States
and by comparable foreign regulatory authorities before marketing in other jurisdictions.  The process of obtaining regulatory
approvals and the subsequent compliance with applicable federal, state, local and foreign statutes and regulations require the
expenditure of substantial time and resources. Failure to comply with the applicable U.S. requirements at any time during the
product  development  process,  approval  process  or  after  approval  may  subject  an  applicant  and/or  sponsor  to  a  variety  of
administrative  or  judicial  sanctions,  including  refusal  by  regulatory  authorities  to  approve  applications,  withdrawal  of  an
approval, imposition of a clinical hold, import/export delays, issuance of warning letters and untitled letters, product recalls,
product seizures, total or partial suspension of production or distribution, injunctions, fines, refusals of government contracts,
restitution, disgorgement of profits, or civil or criminal investigations and penalties brought by FDA and the Department of
Justice or other governmental entities.

United States Government Regulation

NDA Approval Processes

In  the  United  States,  the  FDA  regulates  drug  and  medical  device  products  under  the  Federal  Food,  Drug,  and
Cosmetic  Act,  or  FDCA,  and  its  implementing  regulations.  Certain  of  our  drug  candidates  are  comprised  of  both  a  drug
component (the hydrogen peroxide solution or gel) and a pen-type applicator. In the case of our drug candidates, the FDA's
Center for Drug Evaluation and Research has primary jurisdiction over the premarket development, review and approval of
our drug candidates. Accordingly, we are investigating our drug candidates pursuant to IND applications and expect to seek
approval through the NDA pathway. Based on our discussions with the FDA to date, we do not anticipate that the FDA will
require us to submit a separate marketing application for the pen-type applicator that will be used with certain of our drug
candidates, but this could change during the course of the FDA's review of the respective NDA.

An  applicant  seeking  approval  to  market  and  distribute  a  new  drug  product  in  the  United  States  must  typically

undertake the following:

·

·
·

·

·
·
·

·
·

completion of preclinical laboratory tests, animal studies and formulation studies in compliance with the FDA's
good laboratory practice regulations;
submission to the FDA of an IND which must take effect before clinical trials may begin;
approval by an independent institutional review board, or IRB, representing each clinical site before clinical testing
may be initiated at the clinical site;
performance of adequate and well-controlled clinical trials in accordance with good clinical practice, or GCP,
regulations to establish the safety and efficacy of the proposed drug product for each indication;
preparation and submission to the FDA of an NDA;
review of the NDA by a FDA advisory committee, if applicable;
satisfactory completion of one or more FDA inspections of the manufacturing facility or facilities at which the
product or its components are produced to assess compliance with current good manufacturing practices, or cGMP,
regulations to assure that the facilities, methods and controls are adequate to preserve the product's identity, strength,
quality and purity;
payment of user fees and securing FDA approval of the NDA; and
compliance with any post-approval requirements, including potential requirements for a risk evaluation and
mitigation strategy and post-approval studies required by the FDA.

15

 
 
 
 
 
 
 
 
Table of Contents

Once a drug candidate is identified for development, it enters the preclinical or nonclinical testing stage. Preclinical
studies include laboratory evaluations of product chemistry, pharmacology, toxicity and formulation. An IND sponsor must
submit the results of the preclinical studies, together with manufacturing information and analytical data, to the FDA as part
of the IND. Some preclinical studies may continue even after the IND is submitted. In addition to including the results of the
preclinical studies, the IND will also include a protocol detailing, among other things, the objectives of the clinical trial, the
parameters to be used in monitoring safety and the effectiveness criteria to be evaluated if the first phase lends itself to an
efficacy determination. The IND automatically becomes effective 30 days after receipt by the FDA, unless the FDA, within
the  30-day  time  period,  places  the  IND  on  clinical  hold.  In  such  a  case,  the  IND  sponsor  and  the  FDA  must  resolve  any
outstanding concerns before clinical trials can begin. A clinical hold may occur at any time during the life of an IND, and
may affect one or more specific clinical trials or all clinical trials conducted under the IND.

All clinical trials must be conducted under the supervision of one or more qualified investigators in accordance with
current  Good  Clinical  Practices  regulations.  They  must  be  conducted  under  protocols  detailing  the  objectives  of  the  trial,
dosing procedures, research subject selection and exclusion criteria and the safety and effectiveness criteria to be evaluated.
Each protocol must be submitted to the FDA as part of the IND, and progress reports detailing the status of the clinical trials
must be submitted to the FDA annually. Sponsors also must timely report to FDA serious and unexpected adverse reactions,
any  clinically  important  increase  in  the  rate  of  a  serious  suspected  adverse  reaction  over  that  listed  in  the  protocol  or
investigator brochure, or any findings from other studies or animal or in vitro testing that suggest a significant risk in humans
exposed to the drug. An institutional review board, or IRB, at each institution participating in the clinical trial must review
and  approve  the  protocol  before  the  clinical  trial  commences  at  that  institution  and  must  also  approve  the  information
regarding the trial and the consent form that must be provided to each research subject or the subject's legal representative,
monitor the study until completed and otherwise comply with IRB regulations.

Clinical trials are typically conducted in three sequential phases that may overlap or be combined:

·

·

·

Phase  1.    The  drug  is  initially  introduced  into  healthy  human  subjects  and  tested  for  safety,  dosage  tolerance,
absorption,  metabolism,  distribution  and  elimination.  In  the  case  of  some  products  for  severe  or  life-threatening
diseases,  such  as  cancer,  and  especially  when  the  product  may  be  inherently  too  toxic  to  ethically  administer  to
healthy volunteers, the initial human testing is often conducted in patients who already have the condition.
Phase 2.  Clinical trials are performed on a limited patient population intended to identify possible adverse effects
and safety risks, to preliminarily evaluate the efficacy of the product for specific targeted diseases and to determine
dosage tolerance and optimal dosage.
Phase 3.  If a drug candidate is found to be potentially effective and to have an acceptable safety profile in Phase 2
clinical trials, the clinical trial program will be expanded to Phase 3 clinical trials to further evaluate dosage, clinical
efficacy and safety in an expanded patient population at geographically dispersed clinical trial sites. These studies
are  intended  to  establish  the  overall  risk-benefit  ratio  of  the  product  and  provide  an  adequate  basis  for  product
approval and labeling claims.

Phase 4 clinical trials are conducted after approval to gain additional experience from the treatment of patients in the
intended therapeutic indication and to document a clinical benefit in the case of drugs approved under accelerated approval
regulations, or when otherwise requested by the FDA in the form of post-market requirements or commitments. Failure to
promptly conduct any required Phase 4 clinical trials could result in withdrawal of approval.

Clinical trials are inherently uncertain, and Phase 1, Phase 2 and Phase 3 testing may not be successfully completed.
The FDA or the sponsor may suspend a clinical trial at any time for a variety of reasons, including a finding that the research
subjects or patients are being exposed to an unacceptable health risk. Similarly, an IRB can suspend or terminate approval of
a clinical trial at its institution if the clinical trial is not being conducted in accordance with the IRB's requirements or if the
drug  has  been  associated  with  unexpected  serious  harm  to  patients.  In  some  cases,  clinical  trials  are  overseen  by  an
independent group of qualified experts organized by the trial sponsor, which is called the clinical monitoring board or data
safety monitoring board. This group provides authorization for whether or not a trial may move forward at designated check
points. These decisions are based on the limited access to data from the ongoing trial.

16

 
 
 
 
 
 
 
Table of Contents

During  the  development  of  a  new  drug,  sponsors  are  given  opportunities  to  meet  with  the  FDA  at  certain  points.
These points may be prior to the submission of an IND, at the end-of-Phase 2 and before an NDA is submitted. Meetings at
other times may be requested. These meetings can provide an opportunity for the sponsor to share information about the data
gathered to date and for the FDA to provide advice on the next phase of development. Sponsors typically use the meeting at
the end-of-Phase 2 to discuss their Phase 2 clinical trial results and present their plans for the pivotal Phase 3 clinical trial or
trials that they believe will support the approval of the new drug.

Concurrent  with  clinical  trials,  sponsors  usually  complete  additional  animal  safety  studies  and  also  develop
additional information about the chemistry and physical characteristics of the drug and finalize a process for manufacturing
commercial quantities of the product in accordance with cGMP requirements. The manufacturing process must be capable of
consistently producing quality batches of the drug and the manufacturer must develop methods for testing the quality, purity
and  potency  of  the  drug.  Additionally,  appropriate  packaging  must  be  selected  and  tested,  and  stability  studies  must  be
conducted to demonstrate that the drug candidate does not undergo unacceptable deterioration over its proposed shelf-life.

The  results  of  product  development,  preclinical  studies  and  clinical  trials,  along  with  descriptions  of  the
manufacturing process, analytical tests and other control mechanisms, proposed labeling and other relevant information are
submitted to the FDA as part of an NDA requesting approval to market the product. The submission of an NDA is subject to
the  payment  of  user  fees,  but  a  waiver  of  such  fees  may  be  obtained  under  specified  circumstances.  The  FDA  reviews  all
NDAs submitted for a period of 60 days to ensure that they are sufficiently complete for substantive review before it accepts
them for filing. It may request additional information rather than accept an NDA for filing. In this event, the NDA must be
resubmitted with the additional information. The resubmitted application also is subject to review before the FDA accepts it
for filing.

During  the  approval  process,  the  FDA  also  will  determine  whether  a  risk  evaluation  and  mitigation  strategy,  or
REMS,  is  necessary  to  assure  the  safe  use  of  the  product.  If  the  FDA  concludes  a  REMS  is  needed,  the  sponsor  of  the
application  must  submit  a  proposed  REMS,  and  the  FDA  will  not  approve  the  application  without  an  approved  REMS,  if
required. A REMS can substantially increase the costs of obtaining approval. The FDA could also require a special warning,
known as a boxed warning, to be included in the product label in order to highlight a particular safety risk.

Once  the  submission  is  accepted  for  filing,  the  FDA  begins  an  in-depth  review.  The  FDA  reviews  an  NDA  to
determine, among other things, whether a product is safe and effective for its intended use and whether its manufacturing is
cGMP-compliant. The FDA may refer the NDA to an advisory committee for review and recommendation as to whether the
application should be approved and under what conditions. The FDA is not bound by the recommendation of an advisory
committee,  but  it  generally  follows  such  recommendations.  NDAs  receive  either  standard  or  priority  review.  A  drug
representing  a  significant  improvement  in  treatment,  prevention  or  diagnosis  of  disease  may  receive  priority  review.  A
priority review designation is intended to direct overall attention and resources to the evaluation of such applications, and to
shorten the FDA's goal for taking action on the NDA from ten months to six months from FDA filing of the NDA. After the
FDA evaluates the NDA and conducts inspections of manufacturing facilities where the drug product and/or its API will be
produced, it may issue an approval letter or a Complete Response Letter. An approval letter authorizes commercial marketing
of  the  drug  with  specific  prescribing  information  for  specific  indications.  A  Complete  Response  Letter  indicates  that  the
review cycle of the application is complete, and the application is not ready for approval. A Complete Response Letter may
require additional clinical data and/or an additional pivotal Phase 3 clinical trial(s), and/or other significant, expensive and
time-consuming  requirements  related  to  clinical  trials,  preclinical  studies  or  manufacturing.  Even  if  such  data  and
information are submitted, the FDA may ultimately decide that the NDA does not satisfy the criteria for approval.

17

 
 
 
 
 
 
Table of Contents

Post-approval Requirements

Drugs manufactured or distributed pursuant to FDA approvals are subject to pervasive and continuing regulation by
the FDA and other governmental agencies, including, among other things, requirements relating to recordkeeping, periodic
reporting,  product  sampling  and  distribution,  advertising  and  promotion  and  reporting  of  adverse  experiences  with  the
product. Once an approval is granted, the FDA may withdraw the approval if compliance with regulatory requirements is not
maintained or if problems occur after the product reaches the market. Later discovery of previously unknown problems with
a  product  may  result  in  restrictions  on  the  product  or  even  complete  withdrawal  of  the  product  from  the  market.  After
approval,  some  types  of  changes  to  the  approved  product,  such  as  adding  new  indications,  manufacturing  changes  and
additional  labeling  claims,  are  subject  to  further  FDA  review  and  approval.  There  also  are  continuing,  annual  user  fee
requirements for products and the establishments at which such products are manufactured, as well as new application fees
for  certain  supplemental  applications.  In  addition,  the  FDA  may  require  testing  and  surveillance  programs  to  monitor  the
effect of approved products that have been commercialized, and the FDA has the power to prevent or limit further marketing
of a product based on the results of these post-marketing programs.

Drug manufacturers and other entities involved in the manufacture and distribution of approved drugs are required
to register their establishments with the FDA and certain state agencies, and are subject to periodic unannounced inspections
by  the  FDA  and  some  state  agencies  for  compliance  with  GMP  regulations  and  other  laws.  The  FDA  has  promulgated
specific  requirements  for  drug  cGMPs  and  device  cGMPs  embodied  in  the  Quality  System  Regulation.  Changes  to  the
manufacturing  process  are  strictly  regulated  and  often  require  prior  FDA  approval  before  being  implemented.  FDA
regulations also require investigation and correction of any deviations from cGMP requirements and impose reporting and
documentation  requirements  upon  the  sponsor  and  any  third-party  manufacturers  that  the  sponsor  may  decide  to  use.
Accordingly, manufacturers must continue to expend time, money, and effort in the area of production and quality control to
maintain cGMP compliance.

Failure  to  comply  with  the  applicable  U.S.  requirements  at  any  time  during  the  product  development  process  or
approval process, or after approval, may subject us to administrative or judicial sanctions, any of which could have a material
adverse effect on us. These sanctions could include:

·
·
·
·
·
·
·
·

refusal to approve pending applications;
withdrawal of an approval;
imposition of a clinical hold;
warning letters;
product seizures or detention, or refusal to permit the import or export of products;
restrictions on the marketing or manufacturing of the product;
total or partial suspension of production or distribution or product recalls; or
injunctions, fines, disgorgement, or civil or criminal penalties.

The FDA strictly regulates the marketing, labeling, advertising and promotion of drug products that are placed on
the market. Drugs may be promoted only for the approved indications and in accordance with the provisions of the approved
label. The FDA and other agencies actively enforce the laws and regulations prohibiting the promotion of off-label uses, and
a company that is found to have improperly promoted off-label uses may be subject to significant liability.

From  time  to  time,  legislation  is  drafted,  introduced  and  passed  in  Congress  that  could  significantly  change  the
statutory  provisions  governing  the  approval,  manufacturing  and  marketing  of  products  regulated  by  the  FDA.  In  addition,
FDA regulations and guidance are often issued revised or reinterpreted by the agency in ways that may significantly affect
our  business  and  our  products.  It  is  impossible  to  predict  whether  legislative  changes  will  be  enacted,  or  whether  FDA
regulations, guidance or interpretations will be issued or changed or what the impact of such changes, if any, may be.

18

 
 
 
 
 
 
 
 
Table of Contents

Non-patent Exclusivity

The  FDCA  provides  a  five-year  period  of  non-patent  marketing  exclusivity  within  the  United  States  to  the  first
applicant to obtain approval of an NDA for a new chemical entity, or NCE. A drug is an NCE if the FDA has not previously
approved any other new drug containing the same active moiety, which is the molecule or ion responsible for the action of
the drug substance.  If market exclusivity is granted for an NCE, during the exclusivity period, the FDA may not accept for
review or approve an abbreviated new drug application, or ANDA, or a 505(b)(2) NDA submitted by another company for
another version of such drug where the applicant does not own or have a legal right of reference to all the data required for
approval. However, an application may be submitted after four years if it contains a certification of patent invalidity or non-
infringement to one of the patents listed with the FDA by the innovator NDA holder.

The FDCA also provides three years of marketing exclusivity for an NDA, or supplement to an existing NDA if new
clinical investigations, other than bioavailability studies, that were conducted or sponsored by the applicant are deemed by
the FDA to be essential to the approval of the application, for example new indications, dosages, dosage forms or strengths of
an existing drug.  This three-year exclusivity covers only the conditions associated with the new clinical investigations and
prohibits  the  FDA  from  approving  an  ANDA,  or  a  505(b)(2)  NDA  submitted  by  another  company  with  overlapping
conditions associated with the new clinical investigations for the three-year period.  Clinical investigation exclusivity does
not  prohibit  the  FDA  from  approving  ANDAs  for  drugs  containing  the  original  active  agent.  Five-year  and  three-year
exclusivity  will  not  delay  the  submission  or  approval  of  an  NDA  for  the  same  drug.  However,  an  applicant  submitting  an
NDA  would  be  required  to  conduct  or  obtain  a  right  of  reference  to  all  of  the  preclinical  studies  and  adequate  and  well-
controlled clinical trials necessary to demonstrate safety and effectiveness.

19

 
 
 
 
Table of Contents

Regulation Outside of the United States

In  addition  to  regulations  in  the  United  States,  we  will  be  subject  to  regulations  of  other  countries  governing  our
business activities, including, our clinical trials and the commercial sale and distribution of our product. Even if we obtain
FDA approval for a product, we must obtain approval by the comparable regulatory authorities of countries outside of the
United States before we can commence clinical trials in such countries and approval of the regulators of such countries or
economic  areas,  such  as  the  European  Union  before  we  may  market  products  in  those  countries  or  areas.  The  approval
process  and  requirements  governing  the  conduct  of  clinical  trials,  product  licensing  and  promotion,  pricing  and
reimbursement vary greatly by geographic region, and the time may be longer or shorter than that required for FDA approval.

In the European Economic Area, or EEA, which is composed of the 28 Member States of the European Union plus
Norway,  Iceland  and  Liechtenstein,  medicinal  products  can  only  be  commercialized  after  obtaining  a  Marketing
Authorization, or MA.

There are two types of MAs:

·

·

The Community MA, which is issued by the European Commission through the Centralized Procedure, based on the
opinion of the Committee for Medicinal Products for Human Use (CHMP) of the European Medicines Agency, or
EMA,  and  which  is  valid  throughout  the  entire  territory  of  the  EEA.  The  Centralized  Procedure  is  mandatory  for
certain  types  of  products,  such  as  biotechnology  medicinal  products,  orphan  medicinal  products,  and  medicinal
products indicated for the treatment of AIDS, cancer, neurodegenerative disorders, diabetes, auto-immune and viral
diseases. The Centralized Procedure is optional for products containing a new active substance not yet authorized in
the EEA, or for products that constitute a significant therapeutic, scientific or technical innovation or which are in
the interest of public health in the EU. Under the Centralized Procedure, the maximum timeframe for the evaluation
of  a  marketing  authorization  application  is  210  days  (excluding  clock  stops,  when  additional  written  or  oral
information is to be provided by the applicant in response to questions asked by the CHMP). Accelerated evaluation
might  be  granted  by  the  CHMP  in  exceptional  cases,  when  the  authorization  of  a  medicinal  product  is  of  major
interest  from  the  point  of  view  of  public  health  and,  in  particular,  from  the  viewpoint  of  therapeutic  innovation.
Under the accelerated procedure, the standard 210 days review period is reduced to 150 days.
National MAs, which are issued by the competent authorities of the Member States of the EEA and only cover their
respective territory, are available for products not falling within the mandatory scope of the Centralized Procedure.
Where a product has already been authorized for marketing in a Member State of the EEA, this National MA can be
recognized in another Member States through the Mutual Recognition Procedure. If the product has not received a
National MA in any Member State at the time of application, it can be approved simultaneously in various Member
States through the Decentralized Procedure.

In  the  EEA,  upon  receiving  marketing  authorization,  new  chemical  entities  generally  receive  eight  years  of  data
exclusivity and an additional two years of market exclusivity. If granted, data exclusivity prevents regulatory authorities in
the  European  Union  from  referencing  the  innovator's  data  to  assess  a  generic  application.  During  the  additional  two-year
period of market exclusivity, a generic marketing authorization can be submitted, and the innovator's data may be referenced,
but no generic product can be marketed until the expiration of the market exclusivity. However, there is no guarantee that a
product will be considered by the European Union's regulatory authorities to be a new chemical entity, and products may not
qualify for data exclusivity.

20

 
 
 
 
 
 
 
Table of Contents

Other Healthcare Laws

Healthcare providers, physicians and third-party payors in the United States and elsewhere will play a primary role
in  the  recommendation  and  prescription  of  ESKATA  and  any  other  drug  candidates  for  which  we  obtain  marketing
approval.  Our current and future arrangements with third-party payors, health care professionals and customers may expose
us to broadly applicable fraud and abuse and other healthcare laws and regulations, including, without limitation, the federal
Anti-Kickback Statute and the federal civil False Claims Act, that may constrain the business or financial arrangements and
relationships through which we sell, market and distribute any drugs for which we obtain marketing approval. In addition, we
may  be  subject  to  transparency  laws  and  patient  privacy  regulation  by  the  federal  government  and  by  the  U.S.  states  and
foreign jurisdictions in which we conduct our business.

The  federal  Anti-Kickback  Statute  makes  it  illegal  for  any  person  or  entity,  including  a  prescription  drug
manufacturer (or a party acting on its behalf) to knowingly and willfully, directly or indirectly, solicit, receive, offer, or pay
any  remuneration  that  is  intended  to  induce  the  referral  of  business,  including  the  purchase,  order,  or  lease  of  any  good,
facility, item or service for which payment may be made under a federal healthcare program, such as Medicare or Medicaid.
The  term  "remuneration"  has  been  broadly  interpreted  to  include  anything  of  value.  The  Anti-Kickback  Statute  has  been
interpreted  to  apply  to  arrangements  between  pharmaceutical  manufacturers  on  one  hand  and  prescribers,  purchasers,
formulary managers, and beneficiaries on the other. Although there are a number of statutory exceptions and regulatory safe
harbors protecting some common activities from prosecution, the exceptions and safe harbors are drawn narrowly. Practices
that involve remuneration that may be alleged to be intended to induce prescribing, purchases or recommendations may be
subject to scrutiny if they do not qualify for an exception or safe harbor. Failure to meet all of the requirements of a particular
applicable  statutory  exception  or  regulatory  safe  harbor  does  not  make  the  conduct  per  se  illegal  under  the  Anti-Kickback
Statute. Instead, the legality of the arrangement will be evaluated on a case-by-case basis based on a cumulative review of all
its facts and circumstances. Several courts have interpreted the statute's intent requirement to mean that if any one purpose of
an  arrangement  involving  remuneration  is  to  induce  referrals  of  federal  healthcare  covered  business,  the  Anti-Kickback
Statute has been violated. Violations of this law are punishable by up to five years in prison, and can also result in criminal
fines, civil money penalties, administrative penalties and exclusion from participation in federal healthcare programs.

Additionally,  the  intent  standard  under  the  Anti-Kickback  Statute  was  amended  by  the  Patient  Protection  and
Affordable  Care  Act  of  2010,  as  amended  by  the  Health  Care  and  Education  Reconciliation  Act  of  2010,  collectively  the
Affordable Care Act, to a stricter standard such that a person or entity no longer needs to have actual knowledge of the statute
or specific intent to violate it in order to have committed a violation. In addition, the Affordable Care Act codified case law
that a claim including items or services resulting from a violation of the federal Anti-Kickback Statute constitutes a false or
fraudulent claim for purposes of the federal civil False Claims Act.

Federal false claims and false statement laws, including the federal civil False Claims Act, prohibits, among other
things, any person or entity from knowingly presenting, or causing to be presented, for payment to, or approval by, federal
programs, including Medicare and Medicaid, claims for items or services, including drugs, that are false or fraudulent or not
provided as claimed. Entities can be held liable under these laws if they are deemed to "cause" the submission of false or
fraudulent claims by, for example, providing inaccurate billing or coding information to customers, promoting a product off-
label,  or  for  providing  medically  unnecessary  services  or  items.  In  addition,  our  future  activities  relating  to  the  sale  and
marketing of our product are subject to scrutiny under this law. Penalties for the federal civil False Claims Act violations may
include up to three times the actual damages sustained by the government, plus mandatory civil penalties of between $10,957
and $21,916 for each separate false claim, the potential for exclusion from participation in federal healthcare programs, and,
although the federal civil False Claims Act is a civil statute, False Claims Act violations may also implicate various federal
criminal statutes.  For example, the federal Health Insurance Portability and Accountability Act of 1996, or HIPAA, created
federal  criminal  statutes  that  prohibit  among  other  actions,  knowingly  and  willfully  executing,  or  attempting  to  execute,  a
scheme to defraud any healthcare benefit program, including private third-party payors, knowingly and willfully embezzling
or  stealing  from  a  healthcare  benefit  program,  willfully  obstructing  a  criminal  investigation  of  a  healthcare  offense,  and
knowingly  and  willfully  falsifying,  concealing  or  covering  up  a  material  fact  or  making  any  materially  false,  fictitious  or
fraudulent statement in connection with the delivery of or payment for healthcare benefits, items or services. Like the Anti-
Kickback Statute, the Affordable Care Act amended the intent standard for the healthcare fraud statute under HIPAA such
that a person or entity no longer needs to have actual knowledge of the statute or specific intent to violate it in order to have
committed a violation.

21

 
 
 
 
 
 
Table of Contents

The  civil  monetary  penalties  statute  imposes  penalties  against  any  person  or  entity  that,  among  other  things,  is
determined to have presented or caused to be presented a claim to a federal health program that the person knows or should
know is for an item or service that was not provided as claimed or is false or fraudulent.

Also, many states have similar fraud and abuse statutes or regulations that may be broader in scope and may apply
regardless of payor, in addition to items and services reimbursed under Medicaid and other state programs. Additionally, to
the extent that our product is sold in a foreign country, we may be subject to similar foreign laws.

In  addition,  legislation  imposing  marketing  restrictions  and  transparency  requirements  on  pharmaceutical
manufacturers has been enacted at the state and federal levels.  For example, the Affordable Care Act imposed, among other
things, annual reporting requirements for covered manufacturers for certain payments and other transfers of value provided to
physicians  and  teaching  hospitals,  as  well  as  ownership  and  investment  interests  held  by  physicians  and  their  immediate
family members. Failure to submit timely, accurately and completely the required information for all payments, transfers of
value and ownership or investment interests may result in civil monetary penalties of up to an aggregate of $165,786 per year
and  up  to  an  aggregate  of  $1,105,241  per  year  for  "knowing  failures."    Certain  states  also  mandate  implementation  of
compliance  programs,  impose  restrictions  on  drug  manufacturer  marketing  practices,  require  registration  of  certain
employees engaged in marketing activities in the location, and/or require the tracking and reporting of gifts, compensation
and other remuneration to physicians. 

Because  we  intend  to  commercialize  products  that  could  be  reimbursed  under  a  federal  healthcare  program  and
other  governmental  healthcare  programs,  we  intend  to  continue  to  develop  a  comprehensive  compliance  program  that
establishes internal controls to facilitate adherence to the rules and program requirements to which we will or may become
subject. Although the development and implementation of compliance programs designed to establish internal controls and
facilitate compliance can mitigate the risk of investigation, prosecution, and penalties assessed for violations of these laws, or
any other laws that may apply to us, the risks cannot be entirely eliminated. If our operations are found to be in violation of
any  of  such  laws  or  any  other  governmental  regulations,  we  may  be  subject  to  penalties,  including,  without  limitation,
administrative,  civil,  and  criminal  penalties,  damages,  fines,  disgorgement,  contractual  damages,  reputational  harm,
diminished  profits  and  future  earnings,  the  curtailment  or  restructuring  of  our  operations,  exclusion  from  participation  in
federal and state healthcare programs, additional reporting requirements and oversight if we become subject to a corporate
integrity  agreement  or  similar  agreement  to  resolve  allegations  of  non-compliance  with  these  laws  and  individual
imprisonment, any of which could adversely affect our ability to operate our business and our financial results.

We  may  also  be  subject  to  data  privacy  and  security  regulation  by  both  the  federal  government  and  the  states  in
which  we  conduct  our  business.  HIPAA,  as  amended  by  the  Health  Information  Technology  for  Economic  and  Clinical
Health Act, or HITECH, and their implementing regulations, including the final omnibus rule published on January 25, 2013,
mandates,  among  other  things,  the  adoption  of  uniform  standards  for  the  electronic  exchange  of  information  in  common
healthcare  transactions,  as  well  as  standards  relating  to  the  privacy  and  security  of  individually  identifiable  health
information,  which  require  the  adoption  of  administrative,  physical  and  technical  safeguards  to  protect  such  information.
Among  other  things,  HITECH  makes  HIPAA's  security  standards  directly  applicable  to  "business  associates",  namely
independent  contractors  or  agents  of  HIPAA  covered  entities  that  create,  receive  or  obtain  protected  health  information  in
connection  with  providing  a  service  for  or  on  behalf  of  a  covered  entity.  HITECH  also  increased  the  civil  and  criminal
penalties  that  may  be  imposed  against  covered  entities  and  business  associates,  and  gave  state  attorneys  general  new
authority  to  file  civil  actions  for  damages  or  injunctions  in  federal  courts  to  enforce  the  federal  HIPAA  laws  and  seek
attorney's fees and costs associated with pursuing federal civil actions. In addition, certain state laws govern the privacy and
security of health information in certain circumstances, some of which are more stringent than HIPAA and many of which
differ from each other in significant ways and may not have the same effect, thus complicating compliance efforts. Failure to
comply with these laws, where applicable, can result in the imposition of significant civil and/or criminal penalties.

22

 
 
 
 
 
 
Table of Contents

Health Care Reform

In  the  United  States,  there  have  been  and  continue  to  be  a  number  of  significant  legislative  initiatives  to  contain
healthcare  costs.  For  example,  in  March  2010,  the  Affordable  Care  Act  was  passed,  which  has  had,  and  is  expected  to
continue to have, a significant impact on the healthcare industry. The Affordable Care Act was designed to expand coverage
for the uninsured and at the same time containing overall healthcare costs. With regard to pharmaceutical products, among
other things, the Affordable Care Act expanded and increased industry rebates for drugs covered under Medicaid programs;
addressed  a  new  methodology  by  which  rebates  owed  by  manufacturers  under  the  Medicaid  Drug  Rebate  Program  are
calculated  for  drugs  that  are  inhaled,  infused,  instilled,  implanted  or  injected;  extended  the  rebate  program  to  individuals
enrolled  in  Medicaid  managed  care  organizations;  established  annual  fees  and  taxes  on  manufacturers  of  certain  branded
prescription drugs; made changes to the coverage requirements under the Medicare prescription drug benefit; and established
a new Medicare Part D coverage gap discount program, in which manufacturers, as a condition for their outpatient drugs to
be covered under Medicare Part D,   must agree to offer 50% (and 70% commencing January 1, 2019) point-of-sale discounts
off  negotiated  prices  of  applicable  brand  drugs  to  eligible  beneficiaries  during  their  coverage  gap  period.    Moreover,  the
Affordable  Care  Act  provided  incentives  to  programs  that  increase  the  federal  government's  comparative  effectiveness
research  and  implemented  payment  system  reforms  including  a  national  pilot  program  on  payment  bundling  meant  to
encourage hospitals, physicians and other providers to improve the coordination, quality and efficiency of certain healthcare
services.

Since  its  enactment  there  have  been  judicial  and  Congressional  challenges  to,  as  well  efforts  by  the  Trump
Administration to repeal or replace certain aspects of the Affordable Care Act.  For example, since January 2017, President
Trump  has  signed  two  executive  orders  and  other  directives  designed  to  delay,  circumvent,  or  loosen  certain  requirements
mandated  by  the  Affordable  Care  Act.  Concurrently,  Congress  has  considered  legislation  that  would  repeal  or  repeal  and
replace  all  or  part  of  the  Affordable  Care  Act.  While  Congress  has  not  passed  comprehensive  repeal  legislation,  two  bills
affecting the implementation of certain taxes under the Affordable Care Act have been signed into law.  The Tax Cuts and
Jobs  Act  of  2017  includes  a  provision  repealing,  effective  January  1,  2019,  the  tax-based  shared  responsibility  payment
imposed by the Affordable Care Act on certain individuals who fail to maintain qualifying health coverage for all or part of a
year that is commonly referred to as the “individual mandate”.  Additionally, on January 22, 2018, President Trump signed a
continuing resolution on appropriations for fiscal year 2018 that delayed the implementation of certain Affordable Care Act-
mandated fees, including the so-called “Cadillac” tax on certain high cost employer-sponsored insurance plans, the annual
fee imposed on certain health insurance providers based on market share, and the medical device excise tax on non-exempt
medical devices. Further, the Bipartisan Budget Act of 2018, or the BBA, among other things, amends the Affordable Care
Act, effective January 1, 2019, to close the coverage gap in most Medicare drug plans, commonly referred to as the “donut
hole”. Congress may consider other legislation to repeal or replace elements of the Affordable Care Act. 

In addition, other legislative changes have been proposed and adopted since the Affordable Care Act was enacted.
For  example,  in  August  2011,  the  President  signed  into  law  the  Budget  Control  Act  of  2011,  which,  among  other  things,
created the Joint Select Committee on Deficit Reduction to recommend to Congress proposals in spending reductions. The
Joint  Select  Committee  on  Deficit  Reduction  did  not  achieve  a  targeted  deficit  reduction  of  at  least  $1.2  trillion  for  fiscal
years  2012  through  2021,  triggering  the  legislation's  automatic  reduction  to  several  government  programs.  This  includes
aggregate reductions in Medicare payments to providers of 2% per fiscal year, which went into effect beginning on April 1,
2013  and,  due  to  subsequent  legislative  amendments  to  the  statute,  including  the  BBA,  will  stay  in  effect  through  2027,
unless additional Congressional action is taken. Additionally, in January 2013, the American Taxpayer Relief Act of 2012
was signed into law, which, among other things, reduced Medicare payments to several providers, including hospitals, cancer
treatment  centers  and  imaging  centers.  Moreover,  the  Drug  Supply  Chain  Security  Act  imposes  new  obligations  on
manufacturers of pharmaceutical products related to product tracking and tracing. Legislative and regulatory proposals have
been made to expand post-approval requirements and restrict sales and promotional activities for pharmaceutical products.

More recently, there has been heightened governmental scrutiny over the manner in which manufacturers set prices
for their marketed products. Such scrutiny has resulted in several recent Congressional inquiries and proposed and enacted
federal  and  state  legislation  designed  to,  among  other  things,  bring  more  transparency  to  product  pricing,  review  the
relationship  between  pricing  and  manufacturer  patient  programs,  and  reform  government  program  reimbursement
methodologies for products.  At the federal level, the Trump Administration’s budget proposal for fiscal year 2019 contains
further  drug  price  control  measures  that  could  be  enacted  during  the  2019  budget  process  or  in  other  future  legislation,
including, for example, measures to permit Medicare Part D plans to negotiate the price of certain drugs under Medicare Part
B, to allow some states to negotiate drug prices under Medicaid, and to eliminate cost sharing for generic drugs for

23

 
 
 
 
 
Table of Contents

low-income  patients.  While  any  proposed  measures  will  require  authorization  through  additional  legislation  to  become
effective,  Congress  and  the  Trump  Administration  have  both  stated  that  they  will  continue  to  seek  new  legislative  and/or
administrative measures to control drug costs. At the state level, legislatures have become increasingly aggressive in passing
legislation and implementing regulations designed to control pharmaceutical and biological product pricing, including price
or  patient  reimbursement  constraints,  discounts,  restrictions  on  certain  product  access  and  marketing  cost  disclosure  and
transparency measures, and, in some cases, designed to encourage importation from other countries and bulk purchasing.

The Affordable Care Act, as well as other federal and state healthcare reform measures that have been and may be
adopted in the future, could harm our future revenue.  Additional legislative actions may be taken in the future which may
change current regulations, guidance and interpretations.  The impact of such actions on our business, if any, cannot presently
be determined.

The Hatch Waxman Amendments to the FDC Act

Orange Book Listing

In  seeking  approval  for  a  drug  through  an  NDA,  applicants  are  required  to  list  with  the  FDA  each  patent  whose
claims cover the applicant's product or a method of using the product. Upon approval of a drug, each of the patents listed in
the  application  for  the  drug  is  then  published  in  the  FDA's  Approved  Drug  Products  with  Therapeutic  Equivalence
Evaluations,  commonly  known  as  the  Orange  Book.  Drugs  listed  in  the  Orange  Book  can,  in  turn,  be  cited  by  potential
competitors in support of approval of an ANDA or an application covered by Section 505(b)(2) of the Federal Food, Drug,
and  Cosmetic  Act,  or  FDCA.  An  ANDA  provides  for  marketing  of  a  drug  product  that  has  the  same  active  ingredients,
generally  in  the  same  strengths  and  dosage  form,  as  the  listed  drug  and  has  been  shown  through  pharmacokinetic,  or  PK,
testing to be bioequivalent to the listed drug. Drugs approved in this way are commonly referred to as "generic equivalents"
to the listed drug, and can often be substituted by pharmacists under prescriptions written for the original listed drug. Other
than the requirement for bioequivalence testing, ANDA applicants are generally not required to conduct, or submit results of,
preclinical studies or clinical tests to prove the safety or effectiveness of their drug product. Section 505(b)(2) applications
provide for marketing of a drug product that may have the same active ingredients as the listed drug and contains full safety
and  effectiveness  data  as  an  NDA,  but  at  least  some  of  this  information  comes  from  studies  not  conducted  by  or  for  the
applicant. This alternate regulatory pathway enables the applicant to rely, in part, on the FDA's findings of safety and efficacy
for  an  existing  product,  or  published  literature,  in  support  of  its  application.  The  FDA  may  then  approve  the  new  drug
candidate for all or some of the labeled indications for which the referenced product has been approved, as well as for any
new indication sought by the 505(b)(2) applicant.

The ANDA or Section 505(b)(2) applicant is required to certify to the FDA concerning any patents listed for the
approved product in the FDA's Orange Book. Specifically, the applicant must certify that: (i) the required patent information
has not been filed; (ii) the listed patent has expired; (iii) the listed patent has not expired, but will expire on a particular date
and approval is sought after patent expiration; or (iv) the listed patent is invalid or will not be infringed by the new product.
The ANDA or Section 505(b)(2) applicant may also elect to submit a statement certifying that its proposed ANDA label does
not contain, or carves out, any language regarding a patented method of use rather than certify to such listed method of use
patent. If the applicant does not challenge the listed patents by filing a certification that the listed patent is invalid or will not
be infringed by the new product, the ANDA or Section 505(b)(2) application will not be approved until all the listed patents
claiming the referenced product have expired.

A  certification  that  the  new  product  will  not  infringe  the  already  approved  product's  listed  patents,  or  that  such
patents  are  invalid,  is  called  a  Paragraph  IV  certification.  If  the  ANDA  or  Section  505(b)(2)  applicant  has  provided  a
Paragraph IV certification to the FDA, the applicant must also send notice of the Paragraph IV certification to the NDA and
patent  holders  once  the  ANDA  or  Section  505(b)(2)  application  has  been  accepted  for  filing  by  the  FDA.  The  NDA  and
patent holders may then initiate a patent infringement lawsuit in response to the notice of the Paragraph IV certification. The
filing of a patent infringement lawsuit within 45 days of the receipt of a Paragraph IV certification automatically prevents the
FDA from approving the ANDA or Section 505(b)(2) application until the earliest of 30 months, expiration of the patent,
settlement  of  the  lawsuit,  and  a  decision  in  the  infringement  case  that  is  favorable  to  the  ANDA  or  Section  505(b)(2)
applicant.  This  prohibition  is  generally  referred  to  as  the  30-month  stay.  Thus,  approval  of  an  ANDA  or  505(b)(2)  NDA
could be delayed for a significant period of time depending on the patent certification the applicant makes and the reference
drug sponsor's decision to initiate patent litigation.

24

 
 
 
 
 
 
 
 
Table of Contents

The ANDA or Section 505(b)(2) application also will not be approved until any applicable non-patent exclusivity

listed in the Orange Book for the referenced product has expired.

Patent Term Extension

In the United States, after NDA approval, owners of relevant drug patents may apply for up to a five year patent
extension, which provides patent term restoration as compensation for the patent term lost during the FDA regulatory review
process  for  the  first  permitted  commercial  marketing  of  a  drug  product.  The  Drug  Price  Competition  and  Patent  Term
Restoration Act of 1984, or the Hatch-Waxman Act, permits a patent term extension of up to five years beyond the expiration
of the patent. The allowable patent term extension is calculated as half of the drug's testing phase, which is the time between
the IND submission becoming effective and the NDA submission, and all of the review phase, which is the time between
NDA submission and approval, up to a maximum extension of five years. The time can be shortened if the FDA determines
that the applicant did not pursue approval with due diligence. Patent extension cannot extend the remaining term of a patent
beyond  a  total  of  14  years  from  the  date  of  product  approval  and  only  one  patent  applicable  to  an  approved  drug  may  be
extended. 

Similar provisions are available in the European Union and other foreign jurisdictions to extend the term of a patent
that covers an approved drug. For example, in Japan, it may be possible to extend the patent term for up to five years and in
the  European  Union,  it  may  be  possible  to  obtain  a  supplementary  patent  certificate  that  would  effectively  extend  patent
protection for up to five years.

Coverage and Reimbursement

We  do  not  expect  third-party  payors  to  cover  and  reimburse  customers  who  use  ESKATA  on  patients  for  the
treatment  of  raised  SKs.  Payors  generally  do  not  reimburse  the  provider  for  the  product  used  to  remove  non-malignant
lesions, including SK. In addition, they do not generally reimburse providers for the procedure removing such lesions, since
the procedure is considered to be cosmetic in nature, unless there is a medical need to remove the lesion such as confirming a
diagnosis  with  a  biopsy  or  treating  SK  that  are  causing  the  patient  physical  discomfort.  We  anticipate  that  in  some  cases,
ESKATA  may  be  used  to  remove  SK  lesions  that  are  inflamed  and  causing  the  patient  discomfort.  Any  reduction  in
reimbursement for the procedure to remove inflamed SK may result in a higher percentage of patients needing to pay out of
pocket  for  treatment  with  ESKATA.    Accordingly,  the  commercial  success  of  ESKATA  depends  on  the  extent  to  which
patients are willing to pay out of pocket for the in-office procedure using our product.  By contrast, in the case of A-101 45%
Topical Solution, if approved, for the treatment of common warts, we believe our success will depend on continued coverage
and  adequate  reimbursement  for  in-office  wart  treatment  procedures  or  in  the  absence  of  coverage  and  adequate
reimbursement, on the extent to which patients will be willing to pay out of pocket for the in-office procedures that include
our product.

Third-party payors determine which medical procedures they will cover and establish reimbursement levels. Even if
a third-party payor covers a particular procedure, the resulting reimbursement payment rates may not be adequate. Patients
who  are  treated  in-office  for  a  medical  condition  generally  rely  on  third-party  payors  to  reimburse  all  or  part  of  the  costs
associated with the procedure and may be unwilling to undergo such procedures for the removal of warts in the absence of
such coverage and reimbursement. Physicians may be unlikely to offer procedures for the treatment of warts if they are not
covered  by  insurance  and  may  be  unlikely  to  purchase  and  use  our  product  for  warts  unless  coverage  is  provided,  and
reimbursement is adequate.

Reimbursement  by  a  third-party  payor  may  depend  upon  a  number  of  factors,  including:  the  third-party  payor's
determination  that  a  procedure  is  neither  cosmetic,  experimental,  nor  investigational;  safe,  effective,  and  medically
necessary; appropriate for the specific patient; cost-effective; supported by peer-reviewed medical journals; and included in
clinical practice guidelines.

In the United States, no uniform policy of coverage and reimbursement for medical procedures exists among third-
party payors. Therefore, coverage and reimbursement for procedures can differ significantly from payor to payor. Decisions
regarding the extent of coverage and amount of reimbursement to be provided for an in-office procedure to remove warts are
made  on  a  plan  by  plan  basis.  One  payor's  determination  to  provide  coverage  for  a  procedure  does  not  assure  that  other
payors will also provide coverage, and adequate reimbursement.

25

 
 
 
 
 
 
 
 
 
 
Table of Contents

In addition to uncertainties surrounding coverage policies, there are periodic changes to reimbursement. Third-party
payors  regularly  update  reimbursement  amounts  and  also  from  time  to  time  revise  the  methodologies  used  to  determine
reimbursement  amounts.  To  the  extent  the  procedure  using  our  drug  candidates  would  be  covered,  the  cost  of  our  drugs
generally  is  recovered  by  the  healthcare  provider  as  part  of  the  payment  for  performing  a  procedure  and  not  separately
reimbursed. Accordingly, these updates could impact the demand for our drug candidates. An example of payment updates is
the Medicare program's updates to hospital and physician payments, which are done on an annual basis using a prescribed
statutory formula. In the past, when the application of the formula resulted in lower payment, Congress has passed interim
legislation to prevent the reductions. The Medicare Access and CHIP Reauthorization Act of 2015, or MACRA, ended the
use of the statutory formula, and provided for a 0.5% annual increase in payment rates under the Medicare Physician Fee
Schedule through 2019, but no annual update from 2020 through 2025.  MACRA also introduced a merit based incentive
bonus program for Medicare physicians beginning in 2019.  At this time, it is unclear how the introduction of the merit based
incentive program will impact overall physician reimbursement under the Medicare program.

Foreign  governments  also  have  their  own  healthcare  reimbursement  systems,  which  vary  significantly  by  country
and  region,  and  we  cannot  be  sure  that  coverage  and  adequate  reimbursement  will  be  made  available  with  respect  to  the
treatments in which our drugs are used under any foreign reimbursement system. 

Employees

As of December 31, 2017, we had 96 full-time and part-time employees. All of our employees are located in the
United States. None of our employees is represented by a labor union or covered by a collective bargaining agreement. We
consider our relationship with our employees to be good. 

Information about Segments

We currently operate in two business segments, dermatology therapeutics and contract research.  Our dermatology
therapeutics  segment  is  focused  on  identifying,  developing  and  commercializing  innovative  and  differentiated  therapies  to
address  significant  unmet  needs  in  medical  and  aesthetic  dermatology.    Our  contract  research  segment  is  focused  on
providing  laboratory  services  under  contract  research  arrangements  to  pharmaceutical  and  biotech  companies  looking  to
supplement  their  research  and  development  efforts  with  difficult-to-execute  specialty  skills  and  programs.    See  “Note  2—
Summary of Significant Accounting Policies—Segment Data” to our consolidated financial statements contained in Part II,
Item 8 of this Annual Report. 

Corporate Information

We  were  incorporated  under  the  laws  of  the  State  of  Delaware  in  July  2012.  Our  principal  executive  offices  are
located at 640 Lee Road, Suite 200, Wayne, PA 19087. Our telephone number is (484) 324-7933. We completed our initial
public  offering  in  October  2015  and  our  common  stock  is  listed  on  the  Nasdaq  Global  Select  Market  under  the  symbol
“ACRS”. 

Available Information

Our internet website address is www.aclaristx.com. In addition to the information contained in this Annual Report,
information about us can be found on our website. Our website and information included in or linked to our website are not
part of this Annual Report. 

Our annual reports on Form 10-K, quarterly reports on Form 10-Q, current reports on Form 8-K and amendments to
those reports filed or furnished pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended, are
available  free  of  charge  through  our  website  as  soon  as  reasonably  practicable  after  they  are  electronically  filed  with  or
furnished to the Securities and Exchange Commission, or SEC. The public may read and copy the materials we file with the
SEC at the SEC’s Public Reference Room at 100 F Street, NE, Washington, DC 20549. The public may obtain information
on the operation of the Public Reference Room by calling the SEC at 1-800-SEC-0330. Additionally, the SEC maintains an
internet site that contains reports, proxy and information statements and other information. The address of the SEC’s website
is www.sec.gov. 

26

 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Item 1A. Risk Factors

Our  business  is  subject  to  numerous  risks.  You  should  carefully  consider  the  following  risks  and  all  other
information  contained  in  this  Annual  Report,  as  well  as  general  economic  and  business  risks,  together  with  any  other
documents we file with the SEC. If any of the following events actually occur or risks actually materialize, it could have a
material adverse effect on our business, operating results and financial condition and cause the trading price of our common
stock to decline.

Risks Related to Our Financial Position and Capital Needs

We have incurred significant losses since our inception. We expect to incur losses over the next several years and

may never achieve or maintain profitability.

We have a limited operating history. Since inception, we have incurred significant net losses. We incurred net losses
of $68.5 million and $48.1 million for the years ended December 31, 2017 and 2016, respectively. As of December 31, 2017,
we  had  an  accumulated  deficit  of  $159.4  million.  We  have  financed  our  operations  since  inception  from  sales  of  our
convertible  preferred  stock  and,  beginning  with  our  initial  public  offering  in  October  2015,  from  public  offerings  and  a
private placement of our common stock.  We currently have only one product, ESKATA, approved for commercialization and
have never generated any revenue from product sales. 

We  have  devoted  substantially  all  of  our  financial  resources  and  efforts  to  date  to  the  development  of  our  drug
candidates, including preclinical studies and clinical trials. We expect to continue to incur significant expenses and operating
losses  over  the  next  several  years.  Our  net  losses  may  fluctuate  significantly  from  quarter  to  quarter  and  year  to  year.  We
anticipate that our expenses will increase substantially as we:

·
·
·

·

·
·

begin to commercialize ESKATA in the United States;
pursue marketing approval for ESKATA in the European Union for the treatment of SK; 
continue our ongoing clinical trials evaluating A-101 45% Topical Solution for the treatment of common warts and
pursue marketing approvals for A-101 45% Topical Solution and for any other drug candidates that successfully
complete clinical trials;
initiate and continue clinical trials of our other drug candidates, including ATI-501 and ATI-502 for the treatment of
AA, vitiligo and AGA;
seek to discover and develop additional drug candidates;
establish a commercialization infrastructure and scale up external manufacturing and distribution capabilities to
commercialize ESKATA and any other drug candidates for which we may obtain marketing approval;
seek to in-license or acquire additional drug candidates for other dermatological conditions;
adapt our regulatory compliance efforts to incorporate requirements applicable to marketed drugs;

·
·
· maintain, expand and protect our intellectual property portfolio;
hire additional clinical, manufacturing and scientific personnel;
·
add operational, financial and management information systems and personnel, including personnel to support our
·
drug development and planned future expanded commercialization efforts; and
incur additional legal, accounting, investor relations and other administrative expenses in operating as a public
company.

·

To become and remain profitable, we must succeed in developing and eventually commercializing drug candidates
that  generate  significant  revenue.  This  will  require  us  to  be  successful  in  a  range  of  challenging  activities,  including
completing  preclinical  testing  and  clinical  trials  of  our  drug  candidates,  obtaining  marketing  approval,  and  manufacturing,
marketing  and  selling  any  drug  candidates  for  which  we  may  obtain  marketing  approval,  as  well  as  discovering  and
developing additional drug candidates. We are only in the early stages of most of these activities. We may never succeed in
these activities and, even if we do, may never generate revenue that is significant enough to achieve profitability. 

27

 
 
 
 
 
 
 
 
 
Table of Contents

For ESKATA and for any other drug candidates for which we are successful in obtaining marketing approval, our
revenue will be dependent, in part, upon the size of the markets in the territories for which we gain marketing approval, the
accepted price for the product, the ability to obtain coverage and reimbursement, if any, and whether we own the commercial
rights for that territory. If the number of our addressable patients is not as significant as we estimate, the indication approved
by  regulatory  authorities  is  narrower  than  we  expect,  or  the  treatment  population  is  narrowed  by  competition,  physician
choice or treatment guidelines, we may not generate significant revenue from sales of such drug products, even if approved. 

Because  of  the  numerous  risks  and  uncertainties  associated  with  drug  development,  we  are  unable  to  accurately
predict  the  timing  or  amount  of  expenses  or  when,  or  if,  we  will  be  able  to  achieve  profitability.  If  we  are  required  by
regulatory  authorities  to  perform  studies  in  addition  to  those  expected,  or  if  there  are  any  delays  in  the  initiation  and
completion of our clinical trials or the development of any of our drug candidates, our expenses could increase.

Even  if  we  achieve  profitability,  we  may  not  be  able  to  sustain  or  increase  profitability  on  a  quarterly  or  annual
basis. Our failure to become and remain profitable would depress the value of our company and could impair our ability to
raise capital, expand our business, maintain our development efforts, obtain marketing approvals for our drugs, diversify our
offerings or continue our operations. A decline in the value of our company could also cause you to lose all or part of your
investment.

We  will  need  substantial  additional  funding  to  meet  our  financial  obligations  and  to  pursue  our  business
objectives. If we are unable to raise capital when needed, we could be forced to curtail our planned operations and the
pursuit of our growth strategy. 

Identifying  potential  drug  candidates  and  conducting  preclinical  testing  and  clinical  trials  is  a  time-consuming,
expensive  and  uncertain  process  that  takes  years  to  complete,  and  we  may  never  generate  the  necessary  data  or  results
required  to  obtain  marketing  approval  and  achieve  product  sales.  We  expect  to  continue  to  incur  significant  expenses  and
operating losses over the next several years as we begin to commercialize ESKATA and conduct clinical trials of and seek
marketing  approval  for  our  drug  candidates.    In  addition,  ESKATA,  and  our  other  drug  candidates,  if  approved,  may  not
achieve  commercial  success.  Though  ESKATA  has  been  approved  by  the  FDA,  we  do  not  expect  to  generate  substantial
revenue  from  sales  of  ESKATA  in  the  near  term,  if  at  all.    In  addition,  if  we  obtain  marketing  approval  for  A-101  45%
Topical  Solution  for  the  treatment  of  common  warts  or  any  other  drug  candidates  that  we  develop,  we  expect  to  incur
additional  significant  commercialization  expenses  related  to  product  sales,  marketing,  distribution  and  manufacturing.  We
also expect an increase in our expenses associated with creating additional infrastructure to support our continuing operations
as a public company.

28

 
 
 
 
 
 
Table of Contents

As of December 31, 2017, we had cash, cash equivalents and marketable securities of $208.9 million. We believe
that our existing cash and cash equivalents as of the date of this Annual Report will enable us to fund our operating expenses
and capital expenditure requirements for a period greater than 12 months from the date of this report based on our current
operating assumptions. These assumptions may prove to be wrong, and we could use our available capital resources sooner
than  we  expect.  Changes  may  occur  beyond  our  control  that  would  cause  us  to  consume  our  available  capital  before  that
time,  including  changes  in  and  progress  of  our  development  activities,  acquisitions  of  additional  drug  candidates,  and
changes in regulation. Our future capital requirements will depend on many factors, including:

·
·
·

·

·
·
·
·

·

·
·

the progress and success of commercializing ESKATA for the treatment of raised SKs in the United States;
the progress of obtaining marketing approval for ESKATA in the European Union;
the progress and results of the Phase 2 and Phase 3 clinical trials evaluating A-101 45% Topical Solution as a
potential treatment for common warts;
the scope, progress, results and costs of preclinical development, laboratory testing and clinical trials for our other
drug candidates, including ATI-501 and ATI-502;
the extent to which we in-license or acquire other drug candidates and technologies;
the number and development requirements of other drug candidates that we may pursue;
the costs, timing and outcome of regulatory review of our drug candidates;
the costs and timing of future commercialization activities, including drug manufacturing, marketing, sales and
distribution, for any of our drug candidates for which we receive marketing approval;
the revenue received from commercial sales of ESKATA and any of our other drug candidates for which we receive
marketing approval;
our ability to establish collaborations to commercialize ESKATA outside the United States; and
the costs and timing of preparing, filing and prosecuting patent applications, maintaining and enforcing our
intellectual property rights and defending any intellectual property-related claims.

In  connection  with  the  commercial  launch  of  ESKATA  in  the  United  States,  we  expect  to  incur  significant
commercialization expenses related to product manufacturing, sales, marketing and distribution.  We also expect that we will
require additional capital to complete the clinical trials for and potentially commercialize A-101 45% Topical Solution for the
treatment of common warts.  Additional funds may not be available on a timely basis, on commercially acceptable terms, or
at all, and such funds, if raised, may not be sufficient to enable us to continue to implement our long-term business strategy.
If we are unable to raise sufficient additional capital, we could be forced to curtail our planned operations and the pursuit of
our growth strategy.

Raising  additional  capital  may  cause  dilution  to  our  stockholders,  restrict  our  operations  or  require  us  to

relinquish rights to our technologies or drug candidates.

Until  such  time,  if  ever,  as  we  can  generate  substantial  revenue,  we  may  finance  our  cash  needs  through  a
combination  of  equity  offerings,  debt  financings  and  license  and  collaboration  agreements.  We  do  not  currently  have  any
committed external source of funds. To the extent that we raise additional capital through the sale of equity or convertible
debt  securities,  your  ownership  interest  will  be  diluted,  and  the  terms  of  these  securities  may  include  liquidation  or  other
preferences  that  adversely  affect  your  rights  as  a  common  stockholder.  Debt  financing  and  preferred  equity  financing,  if
available, may involve agreements that include covenants limiting or restricting our ability to take specific actions, such as
incurring additional debt, making capital expenditures or declaring dividends.

If  we  raise  additional  funds  through  collaborations,  strategic  alliances  or  marketing,  distribution  or  licensing
arrangements with third parties, we may be required to relinquish valuable rights to our technologies, future revenue streams
or  drug  candidates  or  grant  licenses  on  terms  that  may  not  be  favorable  to  us.  If  we  are  unable  to  raise  additional  funds
through  equity  or  debt  financings  when  needed,  we  may  be  required  to  delay,  limit,  reduce  or  terminate  our  drug
development  or  future  commercialization  efforts  or  grant  rights  to  develop  and  market  drug  candidates  that  we  would
otherwise prefer to develop and market ourselves.

29

 
 
 
 
 
 
 
Table of Contents

We have a limited operating history and no history of commercializing drugs, which may make it difficult for you

to evaluate the success of our business to date and to assess our future viability.

We  commenced  operations  in  2012,  and  our  operations  to  date  have  been  largely  focused  on  raising  capital,
developing ESKATA for the treatment of raised SKs, including undertaking preclinical studies and conducting clinical trials,
and acquiring new drug candidates and related intellectual property. ESKATA, A-101 45% Topical Solution and ATI-501 are
our only product and drug candidates for which we have completed clinical trials. We have not yet demonstrated our ability
to successfully manufacture a drug on a commercial scale, or arrange for a third party to do so on our behalf, or conduct sales
and  marketing  activities  necessary  for  successful  commercialization.  Consequently,  any  predictions  you  make  about  our
future  success  or  viability  may  not  be  as  accurate  as  they  could  be  if  we  had  a  longer  operating  history  or  a  history  of
successfully developing and commercializing drugs.

We may encounter unforeseen expenses, difficulties, complications, delays and other known or unknown factors in
achieving our business objectives. We will need to transition at some point from a company with a development focus to a
company capable of supporting commercial activities. We may not be successful in such a transition.

Risks Related to the Development of Our Drug Candidates

If we are unable to successfully develop, receive marketing approval for and commercialize our drug candidates,

or experience significant delays in doing so, our business will be harmed.

We currently only have one product that is approved for commercial sale. We have invested substantially all of our
efforts and financial resources in the development of ESKATA for the treatment of raised SKs, as well as the development of
our other drug candidates and the identification of potential drug candidates. Our ability to generate substantial revenue from
our  drug  candidates,  which  we  do  not  expect  will  occur  in  the  near  term,  will  depend  heavily  on  their  successful
development, marketing approval and eventual commercialization of these drug candidates. The success of ESKATA and any
drug  candidates  that  we  develop,  including  A-101  45%  Topical  Solution,  ATI-501  and  ATI-502,  will  depend  on  several
factors, including:

·
·

·
·
·

·

·
·
·

successful completion of preclinical studies and our clinical trials;
successful development of our manufacturing processes for ESKATA and for any of our drug candidates that receive
marketing approval;
receipt of timely approvals from applicable regulatory authorities;
commercial launch of ESKATA and, if approved, our other drug candidates;
acceptance of ESKATA and our drug candidates, if approved, by patients, the medical community and third-party
payors, and willingness of patients to pay out of pocket for procedures using our drug candidates when third-party
payor coverage and reimbursement is limited or unavailable;
our success in educating physicians and patients about the benefits, administration and use of ESKATA or, if
approved, any other drug candidates;
the prevalence and severity of adverse events experienced with our other drug candidates;
the availability, perceived advantages, cost, safety and efficacy of alternative treatments for SK and common warts;
obtaining and maintaining patent, trademark and trade secret protection and regulatory exclusivity for our drug
candidates and otherwise protecting our rights in our intellectual property portfolio;

· maintaining compliance with regulatory requirements, including current good manufacturing practices, or cGMPs;
·
· maintaining a continued acceptable safety, tolerability and efficacy profile of our drugs following approval.

competing effectively with other treatment procedures; and

Whether  marketing  approval  will  be  granted  is  unpredictable  and  depends  upon  numerous  factors,  including  the
substantial discretion of the regulatory authorities. Our drug candidates’ success in clinical trials will not guarantee marketing
approval. If, following submission, our NDA for any drug candidate is not accepted for substantive review, or even if it is
accepted  for  substantive  review,  the  FDA  or  other  comparable  foreign  regulatory  authorities  may  require  that  we  conduct
additional studies or clinical trials, provide additional data, take additional manufacturing steps, or require other conditions
before they will reconsider or approve our application. If the FDA or other comparable foreign regulatory authorities require
additional studies, clinical trials or data, we would incur increased costs and delays in the marketing

30

 
 
 
 
 
 
 
 
Table of Contents

approval  process,  which  may  require  us  to  expend  more  resources  than  we  have  available.  In  addition,  the  FDA  or  other
comparable foreign regulatory authorities may not consider sufficient any additional required studies, clinical trials, data or
information that we perform and complete or generate, or we may decide to abandon the program.

It  is  possible  that  our  drug  candidates  currently  in  development  will  never  obtain  marketing  approval,  even  if  we
expend substantial time and resources seeking such approval. If we do not achieve one or more of these factors in a timely
manner or at all, we could experience significant delays or an inability to successfully commercialize our drug candidates,
which would harm our business.

Clinical drug development involves a lengthy and expensive process, with an uncertain outcome. We may incur
additional  costs  or  experience  delays  in  completing,  or  ultimately  be  unable  to  complete,  the  development  and
commercialization of our drug candidates.

The risk of failure for our drug candidates is high. It is impossible to predict when or if any of our drug candidates
other  than  ESKATA  will  prove  effective  or  safe  in  humans  or  will  receive  marketing  approval.  Before  obtaining  approval
from regulatory authorities for the sale of any drug candidate, we must complete preclinical development and then conduct
extensive clinical trials to demonstrate the safety and efficacy of our drug candidates in humans. Clinical testing is expensive,
difficult to design and implement, can take many years to complete and is inherently uncertain as to outcome. A failure of
one or more clinical trials can occur at any stage of testing. The outcome of preclinical testing and early clinical trials may
not be predictive of the success of later clinical trials, and interim results of a clinical trial do not necessarily predict final
results.  Moreover,  preclinical  and  clinical  data  are  often  susceptible  to  varying  interpretations  and  analyses,  and  many
companies  that  have  believed  their  drug  candidates  performed  satisfactorily  in  preclinical  studies  and  clinical  trials  have
nonetheless failed to obtain marketing approval of their drugs.

We may experience numerous unforeseen events during or as a result of clinical trials that could delay or prevent

our ability to receive marketing approval or commercialize our drug candidates, including:

·

·

·

·

·

·

·

·
·

regulators or institutional review boards may not authorize us or our investigators to commence a clinical trial or
conduct a clinical trial at a prospective trial site;
we may experience delays in reaching, or fail to reach, agreement on acceptable clinical trial contracts or clinical
trial protocols with prospective trial sites or prospective contract research organizations, or CROs, the terms of
which can be subject to extensive negotiation and may vary significantly among different CROs and trial sites;
clinical trials of our drug candidates may produce negative or inconclusive results, including failure to demonstrate
statistical significance, and we may decide, or regulators may require us, to conduct additional clinical trials or
abandon drug development programs;
the number of patients required for clinical trials of our drug candidates may be larger than we anticipate, enrollment
in these clinical trials may be slower than we anticipate, or participants may drop out of these clinical trials or fail to
return for post-treatment follow-up at a higher rate than we anticipate;
our drug candidates may have undesirable side effects or other unexpected characteristics, causing us or our
investigators, regulators or institutional review boards to suspend or terminate the trials;
our third-party contractors may fail to comply with regulatory requirements or meet their contractual obligations to
us in a timely manner, or at all;
regulators or institutional review boards may require that we or our investigators suspend or terminate clinical
development for various reasons, including noncompliance with regulatory requirements or a finding that the
participants are being exposed to unacceptable health risks;
the cost of clinical trials of our drug candidates may be greater than we anticipate; and
the supply or quality of our drug candidates or other materials necessary to conduct clinical trials of our drug
candidates may be insufficient or inadequate.

We could also encounter delays if a clinical trial is suspended or terminated by us, by the institutional review boards
of the institutions in which such trials are being conducted, by the data safety monitoring board for such trial or by the FDA
or  other  regulatory  authorities.  Such  authorities  may  impose  such  a  suspension  or  termination  due  to  a  number  of  factors,
including failure to conduct the clinical trial in accordance with regulatory requirements or our clinical protocols, inspection
of the clinical trial operations or trial site by the FDA or other regulatory authorities resulting in the imposition of a clinical
hold, unforeseen safety issues or adverse side effects, failure to demonstrate a benefit from using

31

 
 
 
 
 
 
 
Table of Contents

a  drug,  changes  in  governmental  regulations  or  administrative  actions  or  lack  of  adequate  funding  to  continue  the  clinical
trial.  If we experience delays in the completion of, or termination of, any clinical trial of our drug candidates, the commercial
prospects  of  our  drug  candidates  will  be  harmed,  and  our  ability  to  generate  product  revenues  from  any  of  these  drug
candidates will be delayed. In addition, any delays in completing our clinical trials will increase our costs, slow down our
drug  candidate  development  and  approval  process  and  jeopardize  our  ability  to  commence  product  sales  and  generate
revenues. Any of these occurrences may harm our business, financial condition and prospects significantly. In addition, many
of the factors that cause, or lead to, a delay in the commencement or completion of clinical trials may also ultimately lead to
the denial of marketing approval of our drug candidates. If we are required to conduct additional clinical trials or other testing
of our drug candidates beyond those that we currently contemplate, if we are unable to successfully complete clinical trials of
our drug candidates or other testing, if the results of these trials or tests are not favorable or if there are safety concerns, we
may:

·
·
·
·
·
·

be delayed in obtaining marketing approval for our drug candidates;
not obtain marketing approval at all;
obtain marketing approval for indications or patient populations that are not as broad as intended or desired;
obtain marketing approval with labeling that includes significant use or distribution restrictions or safety warnings;
be subject to additional post-marketing testing requirements; or
have the drug removed from the market after obtaining marketing approval.

Our drug development costs will also increase if we experience delays in testing or marketing approvals. We do not
know whether any of our preclinical studies or clinical trials will begin as planned, will need to be restructured or will be
completed on schedule, or at all. Significant preclinical study or clinical trial delays also could shorten any periods during
which  we  may  have  the  exclusive  right  to  commercialize  our  drug  candidates  or  allow  our  competitors  to  bring  drugs  to
market before we do and impair our ability to successfully commercialize our drug candidates.

If  we  experience  delays  or  difficulties  in  the  enrollment  of  patients  in  clinical  trials,  our  receipt  of  necessary

marketing approvals could be delayed or prevented.

Successful and timely completion of clinical trials will require that we enroll a sufficient number of patients. Patient
enrollment, a significant factor in the timing of clinical trials, is affected by many factors including the size and nature of the
patient population. Trials may be subject to delays as a result of patient enrollment taking longer than anticipated or patient
withdrawal. We may not be able to initiate or continue clinical trials for our drug candidates if we are unable to locate and
enroll  a  sufficient  number  of  eligible  patients  to  participate  in  these  trials  as  required  by  the  FDA  or  similar  regulatory
authorities  outside  the  United  States.  We  cannot  predict  how  successful  we  will  be  at  enrolling  subjects  in  future  clinical
trials. Subject enrollment is affected by other factors including:

·
·
·
·
·
·
·

the eligibility criteria for the trial in question;
the perceived risks and benefits of the drug candidate in the trial;
the availability of drugs approved to treat the skin disease in the trial;
the efforts to facilitate timely enrollment in clinical trials;
the patient referral practices of physicians;
the ability to monitor patients adequately during and after treatment; and
the proximity and availability of clinical trial sites for prospective patients.

Our inability to enroll a sufficient number of patients for clinical trials would result in significant delays and could
require us or them to abandon one or more clinical trials altogether. Enrollment delays in these clinical trials may result in
increased development costs for our drug candidates, which would cause the value of our company to decline and limit our
ability to obtain additional financing. Furthermore, we rely on and expect to continue to rely on CROs and clinical trial sites
to ensure the proper and timely conduct of our clinical trials and we will have limited influence over their performance.

32

 
 
 
 
 
 
 
 
Table of Contents

Our clinical trials may fail to demonstrate the safety and efficacy of our drug candidates, or serious adverse or
unacceptable side effects may be identified during the development of our drug candidates, which could prevent or delay
marketing  approval  and  commercialization,  increase  our  costs  or  necessitate  the  abandonment  or  limitation  of  the
development of some of our drug candidates.

Before obtaining marketing approvals for the commercial sale of our drug candidates, we must demonstrate through
lengthy, complex and expensive preclinical testing and clinical trials that our drug candidates are both safe and effective for
use in each target indication, and failures can occur at any stage of testing. Clinical trials often fail to demonstrate safety and
efficacy of the drug candidate studied for the target indication.

If our drug candidates are associated with side effects in clinical trials or have characteristics that are unexpected,
we  may  need  to  abandon  their  development  or  limit  development  to  more  narrow  uses  in  which  the  side  effects  or  other
characteristics are less prevalent, less severe or more acceptable from a risk-benefit perspective. The FDA or an institutional
review  board  may  also  require  that  we  suspend,  discontinue,  or  limit  our  clinical  trials  based  on  safety  information.  Such
findings  could  further  result  in  regulatory  authorities  failing  to  provide  marketing  authorization  for  our  drug  candidates.
Many  drug  candidates  that  initially  showed  promise  in  early  stage  testing  have  later  been  found  to  cause  side  effects  that
prevented further development of the drug candidate.

Additionally,  if  we  or  others  identify  undesirable  side  effects  caused  by  our  drugs,  a  number  of  potentially

significant negative consequences could result, including:

·
·
·
·
·

regulatory authorities may withdraw approval to market such product;
regulatory authorities may require additional warnings on the labels;
we may be required to create a medication guide outlining the risks of such side effects for distribution to patients;
we could be sued and held liable for harm caused to patients; and
our reputation and physician or patient acceptance of our products may suffer.

Any  of  these  events  could  prevent  us  from  achieving  or  maintaining  market  acceptance  of  the  particular  drug

candidate and could significantly harm our business, results of operations and prospects.

Changes in methods of drug candidate manufacturing or formulation may result in additional costs or delay.

As  drug  candidates  are  developed  through  preclinical  studies  to  late-stage  clinical  trials  towards  approval  and
commercialization,  it  is  common  that  various  aspects  of  the  development  program,  such  as  manufacturing  methods  and
formulation, are altered along the way in an effort to optimize processes and results. Such changes carry the risk that they
will not achieve these intended objectives, and may also require additional testing, FDA notification or FDA approval.  Any
of  these  changes  could  cause  our  drug  candidates  to  perform  differently  and  affect  the  results  of  planned  clinical  trials  or
other  future  clinical  trials  conducted  with  the  altered  materials.   This  could  delay  completion  of  clinical  trials,  require  the
conduct of bridging clinical trials or the repetition of one or more clinical trials, increase clinical trial costs, delay approval of
our drug candidates and jeopardize our ability to commence sales and generate revenue.

We may not be successful in our efforts to increase our pipeline of drug candidates, including by in-licensing or

acquiring additional drug candidates for other dermatological conditions.

A key element of our strategy is to build and expand our pipeline of drug candidates. In addition, we intend to in-
license  or  acquire  additional  drug  candidates  for  other  dermatological  conditions  to  build  a  fully  integrated  dermatology
company. We may not be able to identify or develop drug candidates that are safe, tolerable and effective. Even if we are
successful in continuing to build our pipeline, the potential drug candidates that we identify, in-license or acquire may not be
suitable for clinical development, including as a result of being shown to have harmful side effects or other characteristics
that indicate that they are unlikely to be drugs that will receive marketing approval and achieve market acceptance.

33

 
 
 
 
 
 
 
 
 
 
 
Table of Contents

We may expend our limited resources to pursue a particular drug candidate or indication and fail to capitalize on

drug candidates or indications that may be more profitable or for which there is a greater likelihood of success.

Because  we  have  limited  financial  and  management  resources,  we  focus  on  development  programs  and  drug
candidates that we identify for specific indications. As such, we are currently primarily focused on the commercialization of
ESKATA  and  the  development  of  A-101  45%  Topical  Solution  for  the  treatment  of  common  warts.  As  a  result,  we  may
forego or delay pursuit of opportunities with other drug candidates or for other indications that later prove to have greater
commercial  potential.  Our  resource  allocation  decisions  may  cause  us  to  fail  to  capitalize  on  viable  commercial  drugs  or
profitable market opportunities. Our spending on current and future development programs and drug candidates for specific
indications may not yield any commercially viable drugs. If we do not accurately evaluate the commercial potential or target
market  for  a  particular  drug  candidate,  we  may  relinquish  valuable  rights  to  that  drug  candidate  through  collaboration,
licensing  or  other  royalty  arrangements  in  cases  in  which  it  would  have  been  more  advantageous  for  us  to  retain  sole
development and commercialization rights to such drug candidate.

Risks Related to the Commercialization of Our Drug Candidates

ESKATA,  and  any  of  our  drug  candidates  that  receive  marketing  approval,  may  fail  to  achieve  the  degree  of
market  acceptance  by  physicians,  patients,  third-party  payors  and  others  in  the  medical  community  necessary  for
commercial success.

ESKATA,  and  any  of  our  drug  candidates  that  receive  marketing  approval,  may  fail  to  gain  sufficient  market
acceptance  by  physicians,  patients,  third-party  payors  and  others  in  the  medical  community.  If  ESKATA  and  our  drug
candidates do not achieve an adequate level of acceptance, we may not generate significant revenue and we may not become
profitable. The degree of market acceptance of ESKATA and, if approved, any drug candidate, will depend on a number of
factors, including:

·
·
·
·
·
·
·
·
·
·

the efficacy, safety and potential advantages compared to alternative treatments;
our ability to offer our products for sale at competitive prices;
the convenience and ease of administration compared to alternative treatments;
the willingness of the target patient population to try new treatments and of physicians to prescribe these treatments;
our ability to hire and retain a sales force in the United States;
the strength of marketing and distribution support;
the willingness of patients to pay out of pocket for procedures using ESKATA for the treatment of raised SKs;
the availability of third-party coverage and adequate reimbursement;
the prevalence and severity of any side effects; and
any restrictions on the use of our products together with other medications.

If we are unable to establish sales, marketing and distribution capabilities for ESKATA, or a drug candidate that
may receive marketing approval, we may not be successful in commercializing ESKATA or those drug candidates if and
when they are approved.

To  achieve  commercial  success  for  ESKATA  and  any  other  drug  candidate  for  which  we  may  obtain  marketing
approval,  we  will  need  to  build  a  focused  sales  and  marketing  infrastructure  to  market  or  co-promote  ESKATA  and,  if
approved, some of our drug candidates in the United States.  We have begun this process, but there are risks involved with
establishing  our  own  sales,  marketing  and  distribution  capabilities.  For  example,  recruiting  and  training  a  sales  force  is
expensive and time consuming and could delay any drug launch. If the commercial launch of a drug candidate for which we
recruit  a  sales  force  and  establish  marketing  capabilities  is  delayed  or  does  not  occur  for  any  reason,  we  would  have
prematurely or unnecessarily incurred these commercialization expenses. This may be costly, and our investment would be
lost if we cannot retain or reposition our sales and marketing personnel.  Factors that may inhibit our efforts to commercialize
our drugs on our own include:

34

 
 
 
 
 
 
 
 
Table of Contents

·
·

·

·

our inability to recruit, train and retain adequate numbers of effective sales and marketing personnel;
the inability of sales personnel to obtain access to physicians or persuade adequate numbers of physicians to
prescribe any future drugs;
the lack of complementary drugs to be offered by sales personnel, which may put us at a competitive disadvantage
relative to companies with more extensive product lines; and
unforeseen costs and expenses associated with creating an independent sales and marketing organization.

If we are unable to establish our own sales, marketing and distribution capabilities and enter into arrangements with
third parties to perform these services, our revenue and our profitability, if any, are likely to be lower than if we were to sell,
market  and  distribute  any  drugs  that  we  develop  ourselves.  In  addition,  we  may  not  be  successful  in  entering  into
arrangements with third parties to sell, market and distribute our drug candidates or may be unable to do so on terms that are
favorable to us. We likely will have little control over such third parties, and any of them may fail to devote the necessary
resources  and  attention  to  sell  and  market  our  drugs  effectively.  If  we  do  not  establish  sales,  marketing  and  distribution
capabilities  successfully,  either  on  our  own  or  in  collaboration  with  third  parties,  we  will  not  be  successful  in
commercializing our drug candidates.

We  face  substantial  competition,  which  may  result  in  others  discovering,  developing  or  commercializing  drugs

before or more successfully than we do.

The development and commercialization of new drugs is highly competitive. We face competition with respect to
our current drug candidates, and will face competition with respect to any drug candidates that we may seek to develop or
commercialize  in  the  future,  from  many  different  sources,  including  major  pharmaceutical,  biotechnology  and  specialty
pharmaceutical companies, academic institutions and governmental agencies and public and private research institutions.

With  respect  to  ESKATA  for  the  treatment  of  raised  SKs,  we  are  aware  of  two  biopharmaceutical  companies
developing  drug  candidates  which  target  SK,  and  another  company  that  currently  markets  a  line  of  cosmetic  products
targeting  skin  conditions,  including  SK.  We  are  also  aware  of  early  research  being  conducted  with  Akt  inhibitors  as  a
potential treatment for SK.

With respect to A-101 45% Topical Solution for the treatment of common warts, we are aware of four companies
developing  drug  candidates  for  the  treatment  of  common  warts.  In  addition,  other  drugs  have  been  used  off-label  as
treatments for common warts. We could also encounter competition from over-the-counter treatments for common warts.

Our  commercial  opportunity  could  be  reduced  or  eliminated  if  our  competitors  develop  and  commercialize  drugs
that are safer, more effective, have fewer or less severe side effects, are more convenient or are less expensive than ESKATA
or any other drug that we may develop. Our competitors also may obtain FDA or other regulatory approval for their drugs
more rapidly than we may obtain approval for our drug, which could result in our competitors establishing a strong market
position before we are able to enter the market.

With respect to ATI-501 and ATI-502 for the treatment of AA, we anticipate competing with sensitizing agents such
as  diphencyprone,  and  topical,  intralesional  and  systemic  corticosteroids,  which  have  been  found  to  occasionally  reduce
symptoms of AA. Other treatments utilized for patchy AA include anthralin and minoxidil solution. We may also compete
with  companies  developing  chemical  agents  to  be  used  in  topical  immunotherapies,  as  well  as  companies  developing
biologics, immunosuppressive agents, laser therapy, phototherapy, other JAK inhibitors and prostaglandin analogues to treat
AA.

Many  of  the  companies  against  which  we  are  competing,  or  against  which  we  may  compete  in  the  future,  have
significantly greater financial resources and expertise in research and development, manufacturing, preclinical and clinical
development,  obtaining  regulatory  approvals  and  marketing  approved  drugs  than  we  do.  Mergers  and  acquisitions  in  the
pharmaceutical and biotechnology industries may result in even more resources being concentrated among a smaller number
of  our  competitors.  Smaller  or  early-stage  companies  may  also  prove  to  be  significant  competitors,  particularly  through
collaborative arrangements with large and established companies. These competitors also compete with us in recruiting and
retaining qualified scientific and management personnel and establishing clinical trial sites and patient registration for clinical
trials, as well as in acquiring technologies complementary to, or that may be necessary for, our programs.

35

 
 
 
 
 
 
 
 
 
 
 
Table of Contents

We  expect  third-party  payors  generally  will  not  cover  the  use  of  ESKATA  for  the  treatment  of  raised  SKs  and,

accordingly, our success will be dependent upon the willingness of patients to pay out of pocket for ESKATA.

We  do  not  expect  third-party  payors  to  cover  and  reimburse  providers  who  use  ESKATA  on  patients  for  the
treatment  of  raised  SKs.  Payors  generally  do  not  reimburse  the  provider  for  the  product  used  to  remove  non-malignant
lesions, including SK. In addition, they do not generally reimburse providers for the procedure removing such lesions, since
the procedure is considered to be cosmetic in nature, unless there is a medical need to remove the lesion such as confirming a
diagnosis  with  a  biopsy  or  treating  SK  that  are  causing  the  patient  physical  discomfort.  We  anticipate  that  in  some  cases,
ESKATA  will  be  used  to  remove  SK  lesions  that  are  inflamed  and  causing  the  patient  discomfort.  Any  reduction  in
reimbursement for the procedure to remove inflamed SK may result in a higher percentage of patients needing to pay out of
pocket  for  ESKATA.  Accordingly,  the  commercial  success  of  ESKATA  depends  on  the  extent  to  which  patients  will  be
willing to pay out of pocket for the in-office procedure. 

The  success  of  our  drug  candidates  for  the  treatment  of  common  warts  will  depend  significantly  on  continued

coverage and adequate reimbursement or the willingness of patients to pay for these procedures.

In the case of A-101 45% Topical Solution, if approved, for the treatment of common warts, we believe our success
depends  on  continued  coverage  and  adequate  reimbursement  for  in-office  wart  treatment  procedures  or,  in  the  absence  of
coverage and adequate reimbursement, on the extent to which patients will be willing to pay out of pocket for the in-office
procedures that include our drug candidates.

Third-party payors determine which medical procedures they will cover and establish reimbursement levels. Even if
a third-party payor covers a particular procedure, the resulting reimbursement payment rates may not be adequate. Patients
who  are  treated  in-office  for  a  medical  condition  generally  rely  on  third-party  payors  to  reimburse  all  or  part  of  the  costs
associated with the procedure and may be unwilling to undergo such procedures for the removal of warts in the absence of
such coverage and reimbursement. Physicians may be unlikely to offer procedures for the treatment of warts if they are not
covered  by  insurance  and  may  be  unlikely  to  purchase  and  use  our  product  for  warts  unless  coverage  is  provided  and
reimbursement is adequate. 

Reimbursement  by  a  third-party  payor  may  depend  upon  a  number  of  factors,  including  the  third-party  payor’s
determination  that  a  procedure  is  neither  cosmetic,  experimental,  nor  investigational;  safe,  effective,  and  medically
necessary; appropriate for the specific patient; cost-effective; supported by peer-reviewed medical journals; and included in
clinical practice guidelines.

Further,  from  time  to  time,  typically  on  an  annual  basis,  payment  rates  are  updated  and  revised  by  third-party
payors.  To  the  extent  that  the  procedures  using  our  drug  candidates,  are  covered,  the  cost  of  our  products  are  generally
recovered  by  the  healthcare  provider  as  part  of  the  payment  for  performing  a  procedure  and  not  separately  reimbursed.
Accordingly,  these  updates  could  impact  the  demand  for  our  drug  candidates.  An  example  of  payment  updates  is  the
Medicare program updates to physician payments, which is done on an annual basis. In the past, when the application of the
formula resulted in lower payment, Congress has passed interim legislation to prevent the reductions.  MACRA ended the
use  of  the  statutory  formula  and  provided  for  a  0.5%  annual  increase  in  payment  rates  under  the  Medicare  Physician  Fee
Schedule through 2019, but no annual update from 2020 through 2025.  MACRA also introduced a merit based incentive
bonus program for Medicare physicians beginning in 2019.  At this time, it is unclear how the introduction of the merit based
incentive  program  will  impact  overall  physician  reimbursement  under  the  Medicare  program.  Any  resulting  decrease  in
payment under the merit based reimbursement system may adversely affect our revenue and results of operations. In addition,
the Medicare Physician Fee Schedule has been adapted by some private payors into their plan-specific physician payment
schedule.  We  cannot  predict  how  pending  and  future  healthcare  legislation  will  impact  our  business,  and  any  changes  in
coverage and reimbursement that further restricts coverage of our drug candidates or lowers reimbursement for procedures
using our products could harm our business.

Foreign  governments  also  have  their  own  healthcare  reimbursement  systems,  which  vary  significantly  by  country
and  region,  and  we  cannot  be  sure  that  coverage  and  adequate  reimbursement  will  be  made  available  with  respect  to  the
treatments in which our drugs are used under any foreign reimbursement system.

There can be no assurance that our drug candidates for the treatment of common warts, if they are approved for sale
in the United States or in other countries, will be considered medically reasonable and necessary, that they will be considered
cost-effective by third-party payors, that coverage or an adequate level of reimbursement will be available, or

36

 
 
 
 
 
 
 
 
 
Table of Contents

that reimbursement policies and practices in the United States and in foreign countries where our products are sold will not
adversely affect our ability to sell our drugs candidates profitably if they are approved for sale.

Product liability lawsuits against us could cause us to incur substantial liabilities and to limit commercialization

of any drugs that we may develop.

We face an inherent risk of product liability exposure related to the testing of our drug candidates in human clinical
trials  and  will  face  an  even  greater  risk  if  and  when  we  begin  commercially  selling  ESKATA.  If  we  cannot  successfully
defend  ourselves  against  claims  that  our  drug  candidates  or  drugs  caused  injuries,  we  will  incur  substantial  liabilities.
Regardless of merit or eventual outcome, liability claims may result in:

·
·
·
·
·
·
·
·

decreased demand for any drug candidates or drugs that we may develop;
injury to our reputation and significant negative media attention;
withdrawal of clinical trial participants;
significant costs to defend the related litigation;
substantial monetary awards paid to trial participants or patients;
loss of revenue;
reduced resources of our management to pursue our business strategy; and
the inability to commercialize any drugs that we may develop.

We currently hold $10 million in product liability insurance coverage in the aggregate, with a per incident limit of
$10 million, which may not be adequate to cover all liabilities that we may incur. We may need to increase our insurance
coverage as we expand our clinical trials or if we commence commercialization of our drug candidates. Insurance coverage is
increasingly expensive. We may not be able to maintain insurance coverage at a reasonable cost or in an amount adequate to
satisfy any liability that may arise.

Our business and operations would suffer in the event of computer system failures, cyber-attacks or a deficiency

in our cyber-security.

Despite the implementation of security measures, our internal computer systems, and those of third parties on which
we rely, are vulnerable to damage from computer viruses, malware, natural disasters, terrorism, war, telecommunication and
electrical failures, cyber-attacks or cyber-intrusions over the Internet, attachments to emails, persons inside our organization,
or persons with access to systems inside our organization. The risk of a security breach or disruption, particularly through
cyber-attacks  or  cyber  intrusion,  including  by  computer  hackers,  foreign  governments,  and  cyber  terrorists,  has  generally
increased  as  the  number,  intensity  and  sophistication  of  attempted  attacks  and  intrusions  from  around  the  world  have
increased. If such an event were to occur and cause interruptions in our operations, it could result in a material disruption of
our drug development programs. For example, the loss of clinical trial data from completed or ongoing or planned clinical
trials could result in delays in our marketing approval efforts and significantly increase our costs to recover or reproduce the
data. To the extent that any disruption or security breach was to result in a loss of or damage to our data or applications, or
inappropriate disclosure of confidential or proprietary information, we could incur material legal claims and liability, damage
to our reputation, and the further development or commercialization of our drug candidates could be delayed.

37

 
 
 
 
 
 
 
 
Table of Contents

Risks Related to Our Dependence on Third Parties

We will rely on third parties to conduct our future clinical trials for drug candidates, and those third parties may

not perform satisfactorily, including failing to meet deadlines for the completion of such trials.

We engage CROs to conduct clinical trials of our drug candidates. We expect to continue to rely on third parties,
such  as  clinical  data  management  organizations,  medical  institutions  and  clinical  investigators,  to  conduct  those  clinical
trials. If any of our relationships with these third parties terminate, we may not be able to timely enter into arrangements with
alternative third parties or to do so on commercially reasonable terms, if at all. In addition, any third parties conducting our
clinical trials will not be our employees, and except for remedies available to us under our agreements with such third parties,
we cannot control whether or not they devote sufficient time and resources to our clinical programs. If these third parties do
not successfully carry out their contractual duties or obligations or meet expected deadlines, if they need to be replaced or if
the quality or accuracy of the clinical data they obtain is compromised due to the failure to adhere to our clinical protocols,
regulatory requirements or for other reasons, our clinical trials may be extended, delayed or terminated and we may not be
able  to  obtain  marketing  approval  for  or  successfully  commercialize  our  drug  candidates.  Consequently,  our  results  of
operations and the commercial prospects for our drug candidates would be harmed, our costs could increase substantially and
our ability to generate revenue could be delayed significantly.

Switching or adding CROs involves substantial cost and requires management time and focus. In addition, there is a
natural  transition  period  when  a  new  CRO  commences  work.  As  a  result,  delays  occur,  which  can  materially  impact  our
ability to meet our desired clinical development timelines. Though we intend to carefully manage our relationships with our
CROs,  there  can  be  no  assurance  that  we  will  not  encounter  challenges  or  delays  in  the  future  or  that  these  delays  or
challenges will not have a material adverse impact on our business, financial condition and prospects.

We rely on these parties for execution of our preclinical studies and clinical trials, and generally do not control their
activities.  Our  reliance  on  these  third  parties  for  research  and  development  activities  will  reduce  our  control  over  these
activities but will not relieve us of our responsibilities. For example, we will remain responsible for ensuring that each of our
clinical trials is conducted in accordance with the general investigational plan and protocols for the trial. Moreover, the FDA
requires us to comply with standards, commonly referred to as good clinical practices, or GCPs, for conducting, recording
and reporting the results of clinical trials to assure that data and reported results are credible and accurate and that the rights,
integrity and confidentiality of trial participants are protected. We also are required to register ongoing clinical trials and post
the results of completed clinical trials on a government-sponsored database, ClinicalTrials.gov, within specified timeframes.
Failure  to  do  so  can  result  in  fines,  adverse  publicity  and  civil  and  criminal  sanctions.  If  we  or  any  of  our  CROs  fail  to
comply with applicable GCPs, the clinical data generated in our clinical trials may be deemed unreliable and the FDA, EMA
or  comparable  foreign  regulatory  authorities  may  require  us  to  perform  additional  clinical  trials  before  approving  our
marketing applications. We cannot assure you that upon inspection by a given regulatory authority, such regulatory authority
will determine that any of our clinical trials complies with GCP regulations. In addition, our clinical trials must be conducted
with  product  produced  under  cGMP  regulations.  Our  failure  to  comply  with  these  regulations  may  require  us  to  repeat
clinical trials, which would delay the marketing approval process.

We also rely on other third parties to store and distribute drug supplies for the commercialization of ESKATA and
for our clinical trials. Any performance failure on the part of our distributors could delay clinical development or marketing
approval of our drug candidates or commercialization of our drugs, producing additional losses and depriving us of potential
revenue.

38

 
 
 
 
 
 
 
Table of Contents

We contract with third parties for the manufacture of commercial quantities of ESKATA and supply of our drug
candidates  for  preclinical  and  clinical  testing.  This  reliance  on  third  parties  increases  the  risk  that  we  will  not  have
sufficient  quantities  of  ESKATA  and  our  drug  candidates  or  such  quantities  at  an  acceptable  cost,  which  could  delay,
prevent or impair our development or commercialization efforts.

We do not have any manufacturing facilities. We currently rely, and expect to continue to rely, on third parties for
the  manufacture  of  commercial  quantities  of  ESKATA  and  supply  of  our  drug  candidates  for  preclinical  and  clinical
testing.    For  example,  we  have  entered  into  an  exclusive,  ten-year,  automatically  renewable  supply  agreement  with
PeroxyChem,  a  manufacturer  of  hydrogen  peroxide,  to  provide  the  active  pharmaceutical  ingredient  that  can  be  used  in
ESKATA  for  the  treatment  of  raised  SKs.  This  reliance  on  third  parties  increases  the  risk  that  we  will  not  have  sufficient
quantities  of  our  drug  candidates  at  an  acceptable  cost  and/or  quality,  which  could  delay,  prevent  or  impair  our  ability  to
timely conduct our clinical trials or our other development or commercialization efforts.

The facilities used by our contract manufacturers to manufacture our drug candidates must be approved by the FDA
or  other  regulatory  authorities  pursuant  to  inspections  that  will  be  conducted  after  we  submit  our  NDA  or  comparable
marketing application to the FDA or other regulatory authority. We do not have control over a supplier’s or manufacturer’s
compliance with laws, regulations and applicable cGMP standards and other laws and regulations, such as those related to
environmental  health  and  safety  matters.  If  our  contract  manufacturers  cannot  successfully  manufacture  material  that
conforms to our specifications and the strict regulatory requirements of the FDA or others, they will not be able to secure and
maintain regulatory approval for their manufacturing facilities. In addition, we have no control over the ability of our contract
manufacturers to maintain adequate quality control, quality assurance and qualified personnel. If the FDA or a comparable
foreign regulatory authority does not approve these facilities for the manufacture of our drug candidates or if it withdraws
any such approval in the future, we may need to find alternative manufacturing facilities, which would significantly impact
our ability to develop, obtain regulatory approval for or market our drug candidates. 

We  may  be  unable  to  establish  any  agreements  with  future  third-party  manufacturers  or  to  do  so  on  acceptable
terms.  Even  if  we  are  able  to  establish  agreements  with  third-party  manufacturers,  reliance  on  third-party  manufacturers
entails additional risks, including:

·
·
·
·
·
·

reliance on the third party for regulatory compliance and quality assurance;
the possible breach of the manufacturing agreement by the third party;
the possible misappropriation of our proprietary information, including our trade secrets and know-how;
the possible increase in costs by PeroxyChem for the active pharmaceutical ingredient in ESKATA;
the possible increase in costs by James Alexander for the finished dosage form of ESKATA; and
the possible termination or nonrenewal of the agreement by the third party at a time that is costly or inconvenient for
us.

Third-party  manufacturers  may  not  be  able  to  comply  with  cGMP  regulations  or  similar  regulatory  requirements
outside the United States. Our failure, or the failure of our third-party manufacturers, to comply with applicable regulations
could result in sanctions being imposed on us, including clinical holds, fines, injunctions, civil penalties, delays, suspension
or  withdrawal  of  approvals,  license  revocation,  seizures  or  recalls  of  products,  operating  restrictions  and  criminal
prosecutions, any of which could significantly and adversely affect supplies of our products. 

Our products and drug candidates that we may develop may compete with other products and drug candidates for
access to manufacturing facilities. There are a limited number of manufacturers that operate under cGMP regulations and that
might be capable of manufacturing for us. Any performance failure on the part of our existing or future manufacturers could
delay clinical development or marketing approval. We do not currently have arrangements in place for redundant supply or a
second source for the components of ESKATA. 

If our current contract manufacturers cannot perform as agreed, we may be required to replace such manufacturers.

We may incur added costs and delays in identifying and qualifying any such replacement. 

We expect to continue to depend on third-party contract manufacturers for the foreseeable future. Our current and
anticipated future dependence upon others for the manufacture of our products and drug candidates may adversely affect our
future profit margins and our ability to commercialize any drugs that receive marketing approval on a timely and competitive
basis.

39

 
 
 
 
 
 
 
 
 
 
Table of Contents

We may seek collaborations with third parties for the development or commercialization of our drug candidates.
If  those  collaborations  are  not  successful,  we  may  not  be  able  to  capitalize  on  the  market  potential  of  these  drug
candidates.

We may seek third-party collaborators for the development and commercialization of our drug candidates, including
for the commercialization of any of our drug candidates that are approved for marketing outside the United States. Our likely
collaborators for any collaboration arrangements include large and mid-size pharmaceutical companies, regional and national
pharmaceutical companies and biotechnology companies. If we do enter into any such arrangements with any third parties,
we  will  likely  have  limited  control  over  the  amount  and  timing  of  resources  that  our  collaborators  dedicate  to  the
development  or  commercialization  of  our  drug  candidates.  Our  ability  to  generate  revenue  from  these  arrangements  will
depend on our collaborators’ abilities to successfully perform the functions assigned to them in these arrangements.

Collaborations involving our drug candidates would pose the following risks to us:

·

·
·

·

·

·

·

·

·

·

·

collaborators have significant discretion in determining the efforts and resources that they will apply to these
collaborations;
collaborators may not perform their obligations as expected;
collaborators may not pursue development and commercialization of any drug candidates that achieve marketing
approval or may elect not to continue or renew development or commercialization programs based on clinical trial
results, changes in the collaborators’ strategic focus or available funding, or external factors, such as an acquisition,
that divert resources or create competing priorities;
collaborators may delay clinical trials, provide insufficient funding for a clinical trial program, stop a clinical trial or
abandon a drug candidate, repeat or conduct new clinical trials or require a new formulation of a drug candidate for
clinical testing;
collaborators could independently develop, or develop with third parties, products that compete directly or indirectly
with our products or drug candidates if the collaborators believe that competitive products are more likely to be
successfully developed or can be commercialized under terms that are more economically attractive than ours;
drug candidates discovered in collaboration with us may be viewed by our collaborators as competitive with their
own products or drug candidates, which may cause collaborators to cease to devote resources to the
commercialization of our products;
a collaborator with marketing and distribution rights to one or more of our drug candidates that achieve marketing
approval may not commit sufficient resources to the marketing and distribution of such drug candidates;
disagreements with collaborators, including disagreements over proprietary rights, contract interpretation or the
preferred course of development, might cause delays or termination of the research, development or
commercialization of drug candidates, might lead to additional responsibilities for us with respect to drug
candidates, or might result in litigation or arbitration, any of which would be time-consuming and expensive;
collaborators may not properly maintain or defend our or their intellectual property rights or may use our or their
proprietary information in such a way as to invite litigation that could jeopardize or invalidate such intellectual
property or proprietary information or expose us to potential litigation;
collaborators may infringe the intellectual property rights of third parties, which may expose us to litigation and
potential liability; and
collaborations may be terminated for the convenience of the collaborator and, if terminated, we could be required to
raise additional capital to pursue further development or commercialization of the applicable drug candidates.

Collaboration  agreements  may  not  lead  to  development  or  commercialization  of  drug  candidates  in  the  most
efficient  manner  or  at  all.  If  a  present  or  future  collaborator  of  ours  were  to  be  involved  in  a  business  combination,  the
continued  pursuit  and  emphasis  on  our  drug  development  or  commercialization  program  could  be  delayed,  diminished  or
terminated. 

40

 
 
 
 
 
 
Table of Contents

If we are not able to establish collaborations, we may have to alter our development and commercialization plans.

Our drug development programs and the potential commercialization of our drug candidates will require substantial
additional  capital.  For  some  of  our  drug  candidates,  we  may  decide  to  collaborate  with  pharmaceutical  and  biotechnology
companies for the development and potential commercialization of those drug candidates.

We face significant competition in seeking appropriate collaborators. Whether we reach a definitive agreement for a
collaboration will depend, among other things, upon our assessment of the collaborator’s resources and expertise, the terms
and conditions of the proposed collaboration and the proposed collaborator’s evaluation of a number of factors. Those factors
may include the design or results of clinical trials, the likelihood of approval by the FDA or similar regulatory authorities
outside the United States, the potential market for the subject drug candidate, the costs and complexities of manufacturing
and delivering such drug candidate to patients, the potential of competing products, the existence of uncertainty with respect
to our ownership of technology, which can exist if there is a challenge to such ownership without regard to the merits of the
challenge and industry and market conditions generally. The collaborator may also consider alternative drug candidates or
technologies for similar indications that may be available to collaborate on and whether such a collaboration could be more
attractive  than  the  one  with  us  for  our  drug  candidate.  Collaborations  are  complex  and  time-consuming  to  negotiate  and
document.  In  addition,  there  have  been  a  significant  number  of  recent  business  combinations  among  large  pharmaceutical
companies that have resulted in a reduced number of potential future collaborators.

We may not be able to negotiate collaborations on a timely basis, on acceptable terms, or at all. If we are unable to
do so, we may have to curtail the development of such drug candidate, reduce or delay its development program or one or
more of our other development programs, delay its potential commercialization or reduce the scope of any sales or marketing
activities, or increase our expenditures and undertake development or commercialization activities at our own expense. If we
elect to increase our expenditures to fund development or commercialization activities on our own, we may need to obtain
additional capital, which may not be available to us on acceptable terms or at all. If we do not have sufficient funds, we may
not be able to further develop our drug candidates or bring them to market and generate revenue.

Our sublease could terminate if the master lease is terminated for any reason, thus terminating our rights to our

corporate headquarters.

We sublease space for our corporate headquarters.  While the term of the sublease extends until October 2023, if for
any reason the master lease is terminated or expires prior to October 2023, our sublease will also automatically terminate.  In
such an event, we would need to obtain a new direct lease with the master landlord or negotiate and enter into a new lease for
office space at a different location, which we may not be able to do on commercially reasonable terms, if at all.

Risks Related to Our Intellectual Property

If we are unable to obtain and maintain patent protection for our drug candidates, or if the scope of the patent
protection  obtained  is  not  sufficiently  broad,  our  competitors  could  develop  and  commercialize  technology  and  drugs
similar  or  identical  to  ours,  and  our  ability  to  successfully  commercialize  our  technology  and  drug  candidates  may  be
impaired.

Our success depends in large part on our ability to obtain and maintain patent protection in the United States and
other countries with respect to our drug candidates. We seek to protect our proprietary position by filing patent applications
in the United States and abroad related to our drug candidates.

The  patent  prosecution  process  is  expensive  and  time-consuming,  however,  and  we  may  not  be  able  to  file  and
prosecute all necessary or desirable patent applications at a reasonable cost or in a timely manner. It is also possible that we
will fail to identify patentable aspects of our development output before it is too late to obtain patent protection. We may not
have  the  right  to  control  the  preparation,  filing  and  prosecution  of  patent  applications,  or  to  maintain  the  rights  to  patents
licensed to third parties. Therefore, these patents and applications may not be prosecuted and enforced in a manner consistent
with the best interests of our business.

41

 
 
 
 
 
 
 
 
 
 
 
Table of Contents

The patent position of biotechnology and pharmaceutical companies generally is highly uncertain, involves complex
legal  and  factual  questions  and  has  in  recent  years  been  the  subject  of  much  litigation.  In  addition,  the  laws  of  foreign
countries may not protect our rights to the same extent as the laws of the United States or vice versa. For example, European
patent law restricts the patentability of methods of treatment of the human body more than U.S. law does. Publications of
discoveries in the scientific literature often lag behind the actual discoveries, and patent applications in the United States and
other jurisdictions are typically not published until 18 months after filing, or in some cases not at all. Therefore, we cannot
know  with  certainty  whether  we  or  our  licensors  were  the  first  to  make  the  inventions  claimed  in  our  patents  or  pending
patent applications, or that we or our licensors were the first to file for patent protection of such inventions. As a result, the
issuance,  scope,  validity,  enforceability  and  commercial  value  of  our  patent  rights  are  highly  uncertain.  Our  pending  and
future patent applications may not result in patents being issued that protect our technology or drugs, in whole or in part, or
which effectively prevent others from commercializing competitive technologies and drugs. Changes in either the patent laws
or interpretation of the patent laws in the United States and other countries may diminish the value of our patents or narrow
the scope of our patent protection.

Recent patent reform legislation could increase the uncertainties and costs surrounding the prosecution of our patent
applications and the enforcement or defense of our issued patents. On September 16, 2011, the Leahy-Smith America Invents
Act, or the Leahy-Smith Act, was signed into law. The Leahy-Smith Act includes a number of significant changes to U.S.
patent  law.  These  include  provisions  that  affect  the  way  patent  applications  are  prosecuted  and  may  also  affect  patent
litigation. The United States Patent Office recently developed new regulations and procedures to govern administration of the
Leahy-Smith Act, and many of the substantive changes to patent law associated with the Leahy-Smith Act, and in particular,
the  first  to  file  provisions,  only  became  effective  on  March  16,  2013.  Accordingly,  it  is  not  clear  what,  if  any,  impact  the
Leahy-Smith Act will have on the operation of our business. However, the Leahy-Smith Act and its implementation could
increase the uncertainties and costs surrounding the prosecution of our patent applications and the enforcement or defense of
our issued patents, all of which could have a material adverse effect on our business and financial condition.

Moreover, we may be subject to a third-party preissuance submission of prior art to the U.S. Patent and Trademark
Office,  or  USPTO,  or  become  involved  in  opposition,  derivation,  reexamination,  inter partes  review,  post-grant  review  or
interference proceedings challenging our patent rights or the patent rights of others. An adverse determination in any such
submission,  proceeding  or  litigation  could  reduce  the  scope  of,  or  invalidate,  our  patent  rights,  allow  third  parties  to
commercialize  our  technology  or  drugs  and  compete  directly  with  us,  without  payment  to  us,  or  result  in  our  inability  to
manufacture  or  commercialize  drugs  without  infringing  third-party  patent  rights.  In  addition,  if  the  breadth  or  strength  of
protection provided by our patents and patent applications that we own, or license is threatened, it could dissuade companies
from collaborating with us to license, develop or commercialize current or future drug candidates.

Even if our patent applications that we own or license issue as patents, they may not issue in a form that will provide
us  with  any  meaningful  protection,  prevent  competitors  from  competing  with  us  or  otherwise  provide  us  with  any
competitive  advantage.  Our  competitors  may  be  able  to  circumvent  our  patents  by  developing  similar  or  alternative
technologies  or  drugs  in  a  non-infringing  manner.    For  example,  the  patents  and  patent  applications  that  we  exclusively
licensed from Columbia University that are primarily directed to methods of treating hair loss disorders with JAK inhibitors
may not issue or may issue with claims directed to the use of specific JAK inhibitors, which may not be relevant to the JAK
inhibitors we intend to commercialize or the JAK inhibitors that our competitors may commercialize. 

42

 
 
 
 
 
Table of Contents

In addition, the issuance of a patent is not conclusive as to its inventorship, scope, validity or enforceability, and our
patents may be challenged in the courts or patent offices in the United States and abroad. Such challenges may result in loss
of exclusivity or freedom to operate or in patent claims being narrowed, invalidated or held unenforceable, in whole or in
part, which could limit our ability to stop others from using or commercializing similar or identical technology and drugs, or
limit  the  duration  of  the  patent  protection  of  our  technology  and  drugs.    Our  issued  U.S.  patents,  with  claims  directed  to
treatment of SK and acrochordons with high-concentration hydrogen peroxide of at least 23%, including ESKATA and A-101
45% Topical Solution, are scheduled to expire in 2022, and our issued U.S. formulation patent with claims directed to high-
concentration hydrogen peroxide formulations, including ESKATA and A-101 45% Topical Solution, and methods of use is
scheduled to expire in 2035.  Certain issued U.S. patents relating to our JAK inhibitors, ATI-501 and ATI-502, are scheduled
to expire in 2023 and additional U.S. patents, with claims specifically directed to such JAK inhibitors, are scheduled to expire
in 2030.  The issued U.S. and Japanese patents that we exclusively licensed from Columbia University with claims directed
to the use of third party JAK inhibitors for the treatment of hair loss disorders, including AA and AGA, and inducing hair
growth, expire in 2031.  We currently do not have any patents issued directed to our “soft” JAK inhibitors, but any claims
that may issue would expire in 2038.  Our issued U.S. patent covering our lead inhibitors of the MK-2 signaling pathway
inhibitor, expires in 2034 and other issued patents covering different MK-2 signaling pathway inhibitors expire in 2031 and
2032. Our issued patents covering our novel inhibitors of ITK expire between 2035 and 2038.  Given the amount of time
required for the development, testing and regulatory review of new drug candidates, patents protecting such candidates might
expire before or shortly after such candidates are commercialized. As a result, our patent portfolio may not provide us with
sufficient rights to exclude others from commercializing drugs similar or identical to ours.

We may become involved in lawsuits to protect or enforce our patents or other intellectual property, which could
be expensive, time-consuming and unsuccessful.  Further, our issued patents could be found invalid or unenforceable if
challenged in court.

Competitors  may  infringe  our  issued  patents  or  other  intellectual  property.  Our  pending  applications  cannot  be
enforced  against  third  parties  practicing  the  technology  claimed  in  such  applications  unless  and  until  a  patent  issues  from
such applications. To counter infringement or unauthorized use, we may be required to file infringement claims, which can be
expensive  and  time-consuming.  Any  claims  we  assert  against  perceived  infringers  could  provoke  these  parties  to  assert
counterclaims against us alleging that we infringe their patents or that our patents are invalid or unenforceable.  Grounds for a
validity  challenge  could  be  an  alleged  failure  to  meet  any  of  several  statutory  requirements,  including  lack  of  novelty,
obviousness,  non-enablement  or  insufficient  written  description.  Grounds  for  an  unenforceability  assertion  could  be  an
allegation that someone connected with prosecution of the patent withheld relevant information from the USPTO or made a
misleading  statement  during  prosecution.  Third  parties  may  also  raise  similar  claims  before  the  USPTO,  in  post-grant
proceedings  such  as  ex  parte  reexaminations,  inter  partes  review,  or  post-grant  review,  or  oppositions  or  similar
administrative proceedings outside the United States, in parallel with litigation or, even outside the context of litigation. The
outcome following legal assertions of invalidity and unenforceability is unpredictable. With respect to the validity question,
for example, we cannot be certain that there is no invalidating prior art of which we and the patent examiner were unaware
during prosecution. If a defendant were to prevail on a legal assertion of invalidity or unenforceability, we would lose at least
part,  and  perhaps  all,  of  the  patent  protection  on  our  drug  candidates.  Such  a  loss  of  patent  protection  would  harm  our
business. 

In such a proceeding, a court or administrative board may decide that a patent of ours is invalid or unenforceable, in
whole or in part, construe the patent’s claims narrowly or refuse to stop the other party from using the technology at issue on
the grounds that our patents do not cover the technology. An adverse result in any such proceeding could put one or more of
our  patents  at  risk  of  being  invalidated  or  interpreted  narrowly.  We  may  find  it  impractical  or  undesirable  to  enforce  our
intellectual  property  against  some  third  parties.  For  instance,  we  are  aware  of  third  parties  that  have  marketed  high-
concentration hydrogen peroxide solutions over the internet for the treatment of SK and warts. These parties do not appear to
have regulatory authority, and we have not authorized them in any way to market these products. However, to date we have
refrained from seeking to enforce our intellectual property rights against these third parties due to the transient nature of their
activities.

Interference proceedings provoked by third parties or brought by us or declared by the USPTO may be necessary to
determine the priority of inventions with respect to our patents or patent applications. An unfavorable outcome could require
us to cease using the related technology or to attempt to license rights to it from the prevailing party. Our business could be
harmed if the prevailing party does not offer us a license on commercially reasonable terms.

43

 
 
 
 
 
 
Table of Contents

Furthermore,  because  of  the  substantial  amount  of  discovery  required  in  connection  with  intellectual  property
litigation, there is a risk that some of our confidential information could be compromised by disclosure during this type of
litigation.

With respect to ATI-501 and ATI-502, if we do not elect to exercise our first right to do so, Rigel may enforce the
licensed patents relating to ATI-501 and ATI-502 against any infringing third party in the field of dermatology. In addition,
Rigel has the first right, but not the obligation, to enforce the licensed patents relating to ATI-501 and ATI-502 against any
infringing  party  outside  of  the  field  of  dermatology.    With  respect  to  the  licensed  patents  from  Columbia  University,
Columbia University has the first right to initiate, control and defend any proceedings related to the validity, enforceability or
infringement of the licensed patent rights and in doing so, has no obligation to assert more than one licensed patent in one
jurisdiction against a third party.  With respect to the licensed patents from Columbia University, if Columbia University does
not  elect  to  exercise  its  first  right  to  do  so,  we  may  enforce  the  licensed  patent  rights  relating  to  an  infringement  of  the
licensed patent rights against any infringing third party.

If  we  breach  our  license  agreement  with  Rigel,  it  could  compromise  our  development  and  commercialization

efforts for our JAK inhibitors ATI-501 and ATI-502.

In August 2015, we entered into an exclusive license agreement with Rigel, which grants us the rights to certain patent
rights  and  other  intellectual  property  owned  by  them  relating  to  the  JAK  inhibitors  ATI-501  and  ATI-502  in  the  field  of
dermatology. If we materially breach or fail to perform any provision under this license agreement, including failure to make
payments to Rigel when due for royalties and failure to use commercially reasonable efforts to develop and commercialize a
JAK  inhibitor,  Rigel  has  the  right  to  terminate  our  license,  and  upon  the  effective  date  of  such  termination,  our  right  to
practice the licensed Rigel’s patent rights and other intellectual property would end. Any uncured, material breach under the
license agreement could result in our loss of rights to practice the patent rights and other intellectual property licensed to us
under the license agreement with Rigel. 

If  we  breach  our  agreement  with  the  selling  stockholders  of  Vixen,  it  could  compromise  our  development  and

commercialization efforts for our JAK inhibitors.

In  March  2016,  we  entered  into  a  stock  purchase  agreement  with  the  stockholders  of  Vixen,  pursuant  to  which  we
purchased  all  of  the  stock  of  Vixen  and  assumed  its  license  agreement  with  Columbia  University.    If  we  fail  to  use
commercially  reasonable  efforts  to  develop  and  commercialize  a  JAK  inhibitor  for  AA  and  a  JAK  inhibitor  for  AGA,  the
license agreement with Columbia University will be transferred to the selling stockholders of Vixen following any adverse
resolution  of  any  dispute  relating  thereto.    Upon  the  effective  date  of  such  transfer,  our  right  to  practice  the  licensed
Columbia University patent rights and know-how would end. 

If  we  breach  our  agreement  with  Columbia  University,  it  could  compromise  our  development  and

commercialization efforts for our JAK inhibitors.

In  March  2016,  as  part  of  the  Vixen  acquisition,  we  assumed  a  license  agreement  with  Columbia  University,  which
grants  us  the  right  under  certain  patent  rights  and  know-how  owned  by  Columbia  University  relating  to  the  use  of  JAK
inhibitors to treat hair-loss disorders. If we materially breach or fail to perform any provision under this license agreement,
including  failure  to  make  payments  to  Columbia  University  when  due  for  royalties  and  failure  to  use  commercially
reasonable  efforts  to  develop  and  commercialize  a  licensed  product,  Columbia  University  has  the  right  to  terminate  our
license, and upon the effective date of such termination, our right to practice the licensed Columbia University patent rights
and  know-how  would  end.  Any  uncured,  material  breach  under  the  license  agreement  could  result  in  our  loss  of  rights  to
practice the patent rights and know-how licensed to us under the license agreement, and, to the extent such patent rights and
know-how relate to our JAK inhibitors, it could compromise our development and commercialization efforts for ATI-501 or
ATI-502. 

44

 
 
 
 
 
 
 
 
 
Table of Contents

We may not be able to protect our intellectual property rights throughout the world.

Filing,  prosecuting  and  defending  patents  on  our  drug  candidates  in  all  countries  throughout  the  world  would  be
prohibitively expensive, and our intellectual property rights in some countries outside the United States can be less extensive
than  those  in  the  United  States.  For  example,  the  use  of  ESKATA  for  the  treatment  of  raised  SKs  is  currently  covered  by
patents in the United States, Australia, India and New Zealand, but not in the European Union or other countries. The use of
A-101 45% Topical Solution for the treatment of warts is currently covered by issued patents in the United States, Australia,
India and New Zealand, but not in the European Union or other countries.  A U.S. patent is issued, and patent applications are
pending  in  the  United  States,  the  European  Union  and  other  foreign  countries  directed  to  high-concentration  hydrogen
peroxide formulations, including ESKATA and A-101 45% Topical Solution and methods of use.  Our JAK inhibitors, ATI-
501 and ATI-502, are currently covered in patents and applications in the United States, the European Union, and other major
foreign  markets.    Additionally,  U.S.  and  Japanese  patents  have  issued  in  the  patent  portfolio  licensed  from  Columbia
University,  which  are  directed  to  the  use  of  certain  third  party  JAK  inhibitors  for  the  treatment  of  hair  loss  disorders  and
applications are pending in the United States, the European Union, Japan and South Korea.  In addition, the laws of some
foreign  countries  do  not  protect  intellectual  property  rights  to  the  same  extent  as  federal  and  state  laws  in  the  United
States.    Consequently,  we  may  not  be  able  to  prevent  third  parties  from  practicing  our  invention  in  such  countries.
Competitors  may  use  our  technologies  in  jurisdictions  where  we  have  not  obtained  patent  protection  to  develop  their  own
products and may export otherwise infringing products to territories where we have patent protection, but enforcement rights
are not as strong as those in the United States.  These products may compete with our drug candidates and our patents or
other intellectual property rights may not be effective or sufficient to prevent them from competing.

Many companies have encountered significant problems in protecting and defending intellectual property rights in
foreign  jurisdictions.  The  legal  systems  of  some  countries  do  not  favor  the  enforcement  of  patents  and  other  intellectual
property  protection,  which  could  make  it  difficult  for  us  to  stop  the  infringement  of  our  patents  generally.  Proceedings  to
enforce  our  patent  rights  in  foreign  jurisdictions  could  result  in  substantial  costs  and  divert  our  efforts  and  attention  from
other  aspects  of  our  business,  could  put  our  patents  at  risk  of  being  invalidated  or  interpreted  narrowly  and  our  patent
applications  at  risk  of  not  issuing  and  could  provoke  third  parties  to  assert  claims  against  us.  We  may  not  prevail  in  any
lawsuits that we initiate, and the damages or other remedies awarded, if any, may not be commercially meaningful.

Many  countries,  including  European  Union  countries,  India,  Japan  and  China,  have  compulsory  licensing  laws
under  which  a  patent  owner  may  be  compelled  under  specified  circumstances  to  grant  licenses  to  third  parties.  In  those
countries, we may have limited remedies if patents are infringed or if we are compelled to grant a license to a third party,
which could materially diminish the value of those patents. This could limit our potential revenue opportunities. Accordingly,
our efforts to enforce our intellectual property rights around the world may be inadequate to obtain a significant commercial
advantage from the intellectual property that we develop or license.

We may need to license intellectual property from third parties, and such licenses may not be available or may

not be available on commercially reasonable terms.

A  third  party  may  hold  intellectual  property,  including  patent  rights  that  are  important  or  necessary  to  the
development  of  our  drug  candidates.  For  example,  we  exclusively  licensed  intellectual  property  from  Rigel  in  the  field  of
dermatology related to our JAK inhibitors,  ATI-501 and ATI-502.  We also exclusively licensed intellectual property from
Columbia University related to the use of JAK inhibitors for the treatment of hair loss disorders.  It may be necessary for us
to use the patented or proprietary technology of third parties to commercialize our drug candidates, in which case we would
be required to obtain a license from these third parties on commercially reasonable terms, or our business could be harmed,
possibly materially. 

45

 
 
 
 
 
 
 
Table of Contents

Our third-party licensors may develop JAK inhibitors, including those related to our drug candidates, outside of

the field of dermatology.

We  exclusively  licensed  intellectual  property  from  Rigel  in  order  to  develop,  use,  manufacture,  sell  and
commercialize  ATI-501  and  ATI-502  in  the  field  of  dermatology.  Rigel  has  retained  the  rights  under  such  intellectual
property to develop, use, manufacture, sell and commercialize ATI-501 and ATI-502 outside of the field of dermatology. If
Rigel were to commercialize such JAK inhibitors outside the field of dermatology, such a product could possibly be used off-
label  for  a  dermatology  indication,  which  could  negatively  impact  sales  of  our  drug  candidates,  if  approved.  Rigel  also
retained the intellectual property rights to develop, use, manufacture, sell and commercialize other structurally similar JAK
inhibitors. If Rigel commercializes a structurally similar JAK inhibitor, such a product could directly compete with our drug
candidates, if approved. 

Third parties may initiate legal proceedings alleging that we are infringing their intellectual property rights, the

outcome of which would be uncertain and could have a material adverse effect on the success of our business.

Our commercial success depends upon our ability to develop, manufacture, market and sell our drug candidates and
use our proprietary technologies without infringing the proprietary rights of third parties. There is considerable intellectual
property litigation in the biotechnology and pharmaceutical industries. We may become party to, or threatened with, future
adversarial proceedings or litigation regarding intellectual property rights with respect to our drugs and technology, including
interference  or  derivation  proceedings  before  the  USPTO.  Numerous  U.S.  and  foreign  issued  patents  and  pending  patent
applications  owned  by  third  parties  exist  in  the  fields  in  which  we  are  developing  our  drug  candidates.  Third  parties  may
assert infringement claims against us based on existing patents or patents that may be granted in the future.

If we are found to infringe a third party’s intellectual property rights, we could be required to obtain a license from
such third party to continue developing and marketing our drugs and technology. However, we may not be able to obtain any
required  license  on  commercially  reasonable  terms  or  at  all.  Even  if  we  were  able  to  obtain  a  license,  it  could  be  non-
exclusive, thereby giving our competitors access to the same technologies licensed to us. We could be forced, including by
court order, to cease commercializing the infringing technology or drug. In addition, we could be found liable for monetary
damages,  including  treble  damages  and  attorneys’  fees  if  we  are  found  to  have  willfully  infringed  a  patent.  A  finding  of
infringement  could  prevent  us  from  commercializing  our  drug  candidates  or  force  us  to  cease  some  of  our  business
operations. In the event of a successful claim of infringement against us, we may have to pay substantial damages, including
treble damages and attorneys’ fees for willful infringement, pay royalties, redesign our infringing product or obtain one or
more licenses from third parties, which may be impossible or require substantial time and monetary expenditure. Claims that
we have misappropriated the confidential information or trade secrets of third parties could have a similar negative impact on
our business.

We  may  be  subject  to  claims  by  third  parties  asserting  that  we,  our  employees  or  our  licensors  have

misappropriated their intellectual property, or claiming ownership of what we regard as our own intellectual property.

Many  of  our  employees  and  our  licensor’s  employees  were  previously  employed  at  other  biotechnology  or
pharmaceutical companies. Although we and our licensor try to ensure that our employees and our licensors’ employees do
not use the proprietary information or know-how of others in their work for us, we or our licensors may be subject to claims
that  these  employees,  our  licensors  or  we  have  used  or  disclosed  intellectual  property,  including  trade  secrets  or  other
proprietary  information,  of  any  such  employee’s  former  employer.  Litigation  may  be  necessary  to  defend  against  these
claims. 

In addition, while it is our policy to require our employees and contractors who may be involved in the development
of intellectual property to execute agreements assigning such intellectual property to us, we may be unsuccessful in executing
such  an  agreement  with  each  party  who  in  fact  develops  intellectual  property  that  we  regard  as  our  own.  Our  and  their
assignment agreements may not be self-executing or may be breached, and we may be forced to bring claims against third
parties,  or  defend  claims  they  may  bring  against  us,  to  determine  the  ownership  of  what  we  regard  as  our  intellectual
property.

46

 
 
 
 
 
 
 
 
 
Table of Contents

If we or our licensors fail in prosecuting or defending any such claims, in addition to paying monetary damages, we
may  lose  valuable  intellectual  property  rights  or  personnel.  Even  if  we  and  our  licensors  are  successful  in  prosecuting  or
defending against such claims, litigation could result in substantial costs and be a distraction to management. 

Intellectual  property  litigation  could  cause  us  to  spend  substantial  resources  and  distract  our  personnel  from

their normal responsibilities.

Even if resolved in our favor, litigation or other legal proceedings relating to intellectual property claims may cause
us  to  incur  significant  expenses,  and  could  distract  our  technical  and  management  personnel  from  their  normal
responsibilities.  In  addition,  there  could  be  public  announcements  of  the  results  of  hearings,  motions  or  other  interim
proceedings  or  developments  and  if  securities  analysts  or  investors  perceive  these  results  to  be  negative,  it  could  have  a
substantial adverse effect on the price of our common stock. Such litigation or proceedings could substantially increase our
operating losses and reduce the resources available for development activities or any future sales, marketing or distribution
activities. We may not have sufficient financial or other resources to conduct such litigation or proceedings adequately. Some
of our competitors may be able to sustain the costs of such litigation or proceedings more effectively than we can because of
their  greater  financial  resources.  Some  of  our  competitors  are  larger  than  we  are  and  have  substantially  greater  resources.
They  are,  therefore,  likely  to  be  able  to  sustain  the  costs  of  complex  patent  litigation  longer  than  we  could.  Accordingly,
despite  our  efforts,  we  may  not  be  able  to  prevent  third  parties  from  infringing  upon  or  misappropriating  our  intellectual
property. Litigation could result in substantial costs and diversion of management resources, which could harm our business.
In addition, the uncertainties associated with litigation could compromise our ability to raise the funds necessary to continue
our clinical trials, continue our internal research programs, or in-license needed technology or other drug candidates. There
could also be public announcements of the results of the hearing, motions, or other interim proceedings or developments. If
securities analysts or investors perceive those results to be negative, it could cause the price of shares of our common stock to
decline.    Uncertainties  resulting  from  the  initiation  and  continuation  of  patent  litigation  or  other  proceedings  could
compromise  our  ability  to  compete  in  the  marketplace,  including  compromising  our  ability  to  raise  the  funds  necessary  to
continue  our  clinical  trials,  continue  our  research  programs,  license  necessary  technology  from  third  parties,  or  enter  into
development collaborations that would help us commercialize our drug candidates. 

If we are unable to protect the confidentiality of our trade secrets, our business and competitive position would be

harmed.

In  addition  to  seeking  patents  for  our  drug  candidates,  we  also  rely  on  trade  secrets,  including  unpatented  know-
how, technology and other proprietary information, to maintain our competitive position. We seek to protect our trade secrets,
in  part,  by  entering  into  non-disclosure  and  confidentiality  agreements  with  parties  who  have  access  to  them,  such  as  our
employees, corporate collaborators, outside scientific collaborators, contract manufacturers, consultants, advisors and other
third  parties.  We  also  enter  into  confidentiality  and  invention  or  patent  assignment  agreements  with  our  employees  and
consultants. Despite these efforts, any of these parties may breach the agreements and disclose our proprietary information,
including our trade secrets, and we may not be able to obtain adequate remedies for such breaches. Enforcing a claim that a
party  illegally  disclosed  or  misappropriated  a  trade  secret  is  difficult,  expensive  and  time-consuming,  and  the  outcome  is
unpredictable.  In  addition,  some  courts  inside  and  outside  the  United  States  are  less  willing  or  unwilling  to  protect  trade
secrets. If any of our trade secrets were to be lawfully obtained or independently developed by a competitor, we would have
no right to prevent them, or those to whom they communicate it, from using that technology or information to compete with
us. If any of our trade secrets were to be disclosed to or independently developed by a competitor, our competitive position
would be harmed. 

The validity, scope and enforceability of any of our patents that cover ESKATA, A-101 45% Topical Solution or

any of our other drug candidates can be challenged by competitors.

The likelihood that a third party will challenge our patents covering ESKATA is increased now that it has received
marketing approval from the FDA.  The challenge may come in the form of a patent office proceeding, such as an inter partes
review, challenging the validity of the patents or a district court proceeding, such as a paragraph IV litigation arising out of
the filing of an Abbreviated New Drug Application, or ANDA. 

47

 
 
 
 
 
 
 
 
Table of Contents

If  a  third  party  files  an  ANDA  for  a  generic  drug  containing  ESKATA,  and  relies  in  whole  or  in  part  on  studies
conducted by or for us, the third party will be required to certify to the FDA that either: (1) there is no patent information
listed in the FDA’s Orange Book with respect to our NDA for the applicable approved drug candidate; (2) the patents listed in
the Orange Book have expired; (3) the listed patents have not expired, but will expire on a particular date and approval is
sought after patent expiration; or (4) the listed patents are invalid or will not be infringed by the manufacture, use or sale of
the  third  party’s  generic  drug.  A  certification  that  the  new  drug  will  not  infringe  the  Orange  Book-listed  patents  for  the
applicable approved drug candidate, or that such patents are invalid, is called a paragraph IV certification. If the third party
submits a paragraph IV certification to the FDA, a notice of the paragraph IV certification must also be sent to us once the
third party’s ANDA is accepted for filing by the FDA. We may then initiate a lawsuit to defend the patents identified in the
notice. The filing of a patent infringement lawsuit within 45 days of receipt of the notice automatically prevents the FDA
from approving the third party’s ANDA until the earliest of 30 months or the date on which the patent expires, the lawsuit is
settled,  or  the  court  reaches  a  decision  in  the  infringement  lawsuit  in  favor  of  the  third  party.  If  we  do  not  file  a  patent
infringement lawsuit within the required 45-day period, the third party’s ANDA will not be subject to the 30-month stay of
FDA  approval.  Litigation  or  other  proceedings  to  enforce  or  defend  intellectual  property  rights  are  often  very  complex  in
nature, may be very expensive and time-consuming, may divert our management’s attention from our core business, and may
result in unfavorable results that could limit our ability to prevent third parties from competing with ESKATA. 

If  A-101  45%  Topical  Solution,  our  JAK  inhibitors,  or  any  of  our  other  drug  candidates  advance  through
development  or  is  approved  by  the  FDA,  one  or  more  third  parties  may  challenge  the  current  patents,  or  patents  that  may
issue in the future, within our portfolio covering these drug candidates. Any such challenge could result in the invalidation of,
or render unenforceable, some or all of the relevant patent claims or a finding of non-infringement.

If  we  do  not  obtain  protection  under  the  Hatch-Waxman  Act  by  extending  the  patent  term  and  obtaining  data

exclusivity for our drug candidates, our business may be materially harmed.

Our  commercial  success  will  largely  depend  on  our  ability  to  obtain  and  maintain  patent  and  other  intellectual
property in the United States and other countries with respect to our proprietary technology, drug candidates and our target
indications.  Our issued U.S. patent with claims directed to treatment of SK with ESKATA is scheduled to expire in 2022 and
our  issued  U.S.  formulation  patent  with  claims  directed  to  high-concentration  hydrogen  peroxide  formulations,  including
ESKATA and A-101 45% Topical Solution, and methods of use is scheduled to expire in 2035.  Certain issued U.S. patents
relating to our JAK inhibitors, ATI-501 and ATI-502, are scheduled to expire in 2023 and additional U.S. patents, with claims
specifically directed to such JAK inhibitors, are scheduled to expire in 2030.  The issued U.S. and Japanese patents licensed
from  Columbia  University  relating  to  the  use  of  certain  third  party  JAK  inhibitor  for  the  treatment  of  hair  loss  disorders,
including AA and AGA, and inducing hair growth, expire in 2031.  Given the amount of time required for the development,
testing and regulatory review of new drug candidates, patents protecting our drug candidates might expire before or shortly
after such candidates begin to be commercialized. We expect to seek extensions of patent terms in the United States and, if
available, in other countries where we are prosecuting patents.

Depending upon the timing, duration and specifics of FDA marketing approval of our drug candidates, one or more
of  our  U.S.  patents  may  be  eligible  for  limited  patent  term  extension  under  the  Drug  Price  Competition  and  Patent  Term
Restoration  Act  of  1984,  referred  to  as  the  Hatch-Waxman  Act,  for  a  drug  candidate.  The  Hatch-Waxman  Act  permits  a
patent  extension  term  of  up  to  five  years  beyond  the  normal  expiration  of  the  patent  as  compensation  for  patent  term  lost
during development and the FDA regulatory review process, which is limited to the approved indication (or any additional
indications  approved  during  the  period  of  extension).  This  extension  is  limited  to  only  one  patent  per  regulatory  review
period  that  covers  the  approved  product.  However,  the  applicable  authorities,  including  the  FDA  and  the  USPTO  in  the
United States, and any equivalent regulatory authority in other countries, may not agree with our assessment of whether such
extensions are available, and may refuse to grant extensions to our patents, or may grant more limited extensions than we
request. We may not be granted an extension because of, for example, failing to apply within applicable deadlines, failing to
apply prior to expiration of relevant patents or otherwise failing to satisfy applicable requirements. Moreover, the applicable
time period or the scope of patent protection afforded could be less than we request. We believe that ESKATA is eligible for
patent term extension and we have filed an application with the USPTO requesting patent term extension for one patent that
covers ESKATA; however, the USPTO and/or the FDA may disagree with our interpretation.    

48

 
 
 
 
 
 
Table of Contents

If we are unable to extend the expiration date of our existing patents or obtain new patents with longer expiry dates,
our competitors may be able to take advantage of our investment in development and clinical trials by referencing our clinical
and preclinical data to obtain approval of competing products following our patent expiration and launch their product earlier
than might otherwise be the case.  For example, even if we obtain new chemical entity, or NCE, exclusivity for ESKATA, we
could be subject to generic competition as early as the end of the applicable exclusivity period, if our patent portfolio does
not have sufficient term or scope to prevent such generic competition.

Any trademarks we have obtained or may obtain may be infringed or successfully challenged, resulting in harm

to our business.

We  expect  to  rely  on  trademarks  as  one  means  to  distinguish  any  of  our  drug  candidates  that  are  approved  for
marketing from the products of our competitors. Once we select new trademarks and apply to register them, our trademark
applications may not be approved. Third parties may oppose or attempt to cancel our trademark applications or trademarks,
or otherwise challenge our use of the trademarks. In the event that our trademarks are successfully challenged, we could be
forced  to  rebrand  our  drugs,  which  could  result  in  loss  of  brand  recognition  and  could  require  us  to  devote  resources  to
advertising  and  marketing  new  brands.  Our  competitors  may  infringe  our  trademarks  and  we  may  not  have  adequate
resources to enforce our trademarks.

Outside  of  the  United  States  we  cannot  be  certain  that  any  country’s  patent  or  trademark  office  will  not
implement new rules that could seriously affect how we draft, file, prosecute and maintain patents, trademarks and patent
and trademark applications.

We cannot be certain that the patent or trademark offices of countries outside the United States will not implement
new rules that increase costs for drafting, filing, prosecuting and maintaining patents, trademarks and patent and trademark
applications or that any such new rules will not restrict our ability to file for patent protection. For example, we may elect not
to  seek  patent  protection  in  some  jurisdictions  or  for  some  drug  candidates  in  order  to  save  costs.  We  may  be  forced  to
abandon or return the rights to specific patents due to a lack of financial resources.

Intellectual property rights do not necessarily address all potential threats to our competitive advantage.

The degree of future protection afforded by our intellectual property rights is uncertain because intellectual property
rights have limitations, and may not adequately protect our business, or permit us to maintain our competitive advantage. The
following examples are illustrative:

·

·

·

·
·

·
·

·

·

others may be able to make formulations or compositions that are the same as or similar to ESKATA and A-101
45% Topical Solution but that are not covered by the claims of the patents that we own;
others may be able to make a JAK inhibitor that is similar to the JAK inhibitors we intend to commercialize that is
not covered by the patents that we exclusively licensed and have the right to enforce;
we, our licensor or any collaborators might not have been the first to make the inventions covered by the issued
patents or pending patent applications that we own;
we, our licensor might not have been the first to file patent applications covering certain of our inventions;
others may independently develop similar or alternative technologies or duplicate any of our technologies without
infringing our intellectual property rights;
it is possible that our pending patent applications will not lead to issued patents;
issued patents that we own may not provide us with any competitive advantages, or may be held invalid or
unenforceable as a result of legal challenges;
our competitors might conduct research and development activities in the United States and other countries that
provide a safe harbor from patent infringement claims for certain research and development activities, as well as in
countries where we do not have patent rights, and then use the information learned from such activities to develop
competitive products for sale in our major commercial markets; and
we may not develop additional proprietary technologies that are patentable.

49

 
 
 
 
 
 
 
 
 
Table of Contents

Risks Related to Regulatory Approval of Our Drug Candidates and Other Legal Compliance Matters

If we are not able to obtain, or if there are delays in obtaining, required regulatory approvals, we will not be able

to commercialize our drug candidates, and our ability to generate revenue will be materially impaired.

Our  drug  candidates  and  the  activities  associated  with  their  development  and  commercialization,  including  their
design,  testing,  manufacture,  safety,  efficacy,  recordkeeping,  labeling,  storage,  approval,  advertising,  promotion,  sale  and
distribution, are subject to comprehensive regulation by the FDA and other regulatory agencies in the United States and by
the European Commission and EU Member State Competent Authorities and similar regulatory authorities outside the United
States. Failure to obtain marketing approval for a drug candidate will prevent us from commercializing the drug candidate.
Other than the approval of ESKATA in the United States, we have not received approval to market any of our drug candidates
from  regulatory  authorities  in  any  jurisdiction.  We  have  only  limited  experience  in  filing  and  supporting  the  applications
necessary  to  gain  marketing  approvals.  Securing  marketing  approval  requires  the  submission  of  extensive  preclinical  and
clinical  data  and  supporting  information  to  regulatory  authorities  for  each  therapeutic  indication  to  establish  the  drug
candidate’s  safety  and  efficacy.  Securing  marketing  approval  also  requires  the  submission  of  information  about  the  drug
manufacturing process to, and inspection of manufacturing facilities by, the regulatory authorities. Our drug candidates may
not be effective, may be only moderately effective or may prove to have undesirable or unintended side effects, toxicities or
other characteristics that may preclude our obtaining marketing approval or prevent or limit commercial use. If any of our
drug  candidates  receive  marketing  approval,  the  accompanying  label  may  limit  the  approved  use  of  our  drug  in  this  way,
which could limit sales of the drug. 

The  process  of  obtaining  marketing  approvals,  both  in  the  United  States  and  abroad,  is  expensive  and  may  take
many  years  if  additional  clinical  trials  are  required,  if  approval  is  obtained  at  all,  and  can  vary  substantially  based  upon  a
variety  of  factors,  including  the  type,  complexity  and  novelty  of  the  drug  candidates  involved.  Changes  in  marketing
approval policies during the development period, changes in or the enactment of additional statutes or regulations, or changes
in  regulatory  review  for  each  submitted  drug  application,  may  cause  delays  in  the  approval  or  rejection  of  an  application.
Regulatory authorities have substantial discretion in the approval process and may refuse to accept any application or may
decide  that  our  data  is  insufficient  for  approval  and  require  additional  preclinical,  clinical  or  other  studies.  In  addition,
varying  interpretations  of  the  data  obtained  from  preclinical  and  clinical  testing  could  delay,  limit  or  prevent  marketing
approval of a drug candidate. Any marketing approval we ultimately obtain may be limited or subject to restrictions or post-
approval commitments that render the approved drug not commercially viable.

If we experience delays in obtaining approval or if we fail to obtain approval of our drug candidates, the commercial

prospects for our drug candidates may be harmed and our ability to generate revenue will be materially impaired.

Failure  to  obtain  marketing  approval  in  international  jurisdictions  would  prevent  our  drug  candidates  from

being marketed abroad.

In order to market and sell our drugs in the European Union and any other jurisdictions, we must obtain separate
marketing approvals and comply with numerous and varying regulatory requirements. The approval procedure varies among
countries and can involve additional testing. The time required to obtain approval may differ substantially from that required
to  obtain  FDA  approval.  The  regulatory  approval  process  outside  the  United  States  generally  includes  all  of  the  risks
associated with obtaining FDA approval. In addition, in many countries outside the United States, it is required that the drug
be approved for reimbursement before the drug can be approved for sale in that country. We may not obtain approvals from
regulatory authorities outside the United States on a timely basis, if at all. Approval by the FDA does not ensure approval by
regulatory authorities in other countries or jurisdictions, and approval by one regulatory authority outside the United States
does  not  ensure  approval  by  regulatory  authorities  in  other  countries  or  jurisdictions  or  by  the  FDA.  However,  failure  to
obtain  approval  in  one  jurisdiction  may  impact  our  ability  to  obtain  approval  elsewhere.  We  may  not  be  able  to  file  for
marketing approvals and may not receive necessary approvals to commercialize our drugs in any market.

50

 
 
 
 
 
 
 
 
Table of Contents

A variety of risks associated with marketing our drug candidates internationally could harm our business.

We  are  seeking  marketing  approval  for  ESKATA  outside  of  the  United  States,  and  we  may  also  seek  marketing
approval for our drug candidates currently in development and, accordingly, we expect that we will be subject to additional
risks related to operating in foreign countries if we obtain the necessary approvals, including:

·
·

·
·
·
·
·
·

·
·
·
·

·
·
·

differing regulatory requirements in foreign countries;
the potential for so-called parallel importing, which is what happens when a local seller, faced with high or higher
local prices, opts to import goods from a foreign market (with low or lower prices) rather than buying them locally;
unexpected changes in tariffs, trade barriers, price and exchange controls and other regulatory requirements;
economic weakness, including inflation, or political instability in particular foreign economies and markets;
foreign reimbursement, pricing and insurance regimes;
compliance with tax, employment, immigration and labor laws for employees living or traveling abroad;
foreign taxes, including withholding of payroll taxes;
foreign currency fluctuations, which could result in increased operating expenses and reduced revenue, and other
obligations incident to doing business in another country;
difficulties staffing and managing foreign operations;
workforce uncertainty in countries where labor unrest is more common than in the United States;
potential liability under the Foreign Corrupt Practices Act of 1977 or comparable foreign regulations;
challenges enforcing our contractual and intellectual property rights, especially in those foreign countries that do not
respect and protect intellectual property rights to the same extent as the United States;
production shortages resulting from any events affecting raw material supply or manufacturing capabilities abroad;
logistical challenges resulting from distributing ESKATA or our drug candidates to foreign countries; and
business interruptions resulting from geo-political actions, including war and terrorism.

These and other risks associated with our international operations may compromise our ability to achieve or

maintain profitability.

ESKATA,  or  any  drug  candidate  for  which  we  obtain  marketing  approval,  could  be  subject  to  post-marketing
restrictions  or  recall  or  withdrawal  from  the  market,  and  we  may  be  subject  to  penalties  if  we  fail  to  comply  with
regulatory requirements or if we experience unanticipated problems with our drug candidates, when and if any of them
are approved.

ESKATA, or any drug candidate for which we obtain marketing approval, along with the manufacturing processes,
post-approval  clinical  data,  labeling,  advertising  and  promotional  activities  for  such  drug  candidate,  will  be  subject  to
continual requirements of and review by the FDA and other regulatory authorities. These requirements include submissions
of safety and other post-marketing information and reports, registration and listing requirements, cGMP requirements relating
to manufacturing, quality control, quality assurance and corresponding maintenance of records and documents, requirements
regarding  the  distribution  of  samples  to  physicians  and  recordkeeping.  Even  if  marketing  approval  of  a  drug  candidate  is
granted, the approval may be subject to limitations on the indicated uses for which the drug candidate may be marketed or to
the conditions of approval, including the requirement to implement a risk evaluation and mitigation strategy. If any of our
drug candidates receives marketing approval, the accompanying label may limit the approved use of our drug, which could
limit sales of the drug.

The  FDA  may  also  impose  requirements  for  costly  post-marketing  studies  or  clinical  trials  and  surveillance  to
monitor the safety or efficacy of the drug. The FDA closely regulates the post-approval marketing and promotion of drugs to
ensure drugs are marketed only for the approved indications and in accordance with the provisions of the approved labeling.
The FDA imposes stringent restrictions on manufacturers’ communications regarding off-label use and if we do not market
our drugs for their approved indications, we may be subject to enforcement action for off-label marketing. Violations of the
Federal  Food,  Drug,  and  Cosmetic  Act  relating  to  the  promotion  of  prescription  drugs  may  lead  to  investigations  alleging
violations of federal and state healthcare fraud and abuse laws, as well as state consumer protection laws.

51

 
 
 
 
 
 
 
 
Table of Contents

In addition, later discovery of previously unknown adverse events or other problems with our drugs, manufacturers

or manufacturing processes, or failure to comply with regulatory requirements, may have negative consequences, including:

·
·
·
·
·
·
·
·
·
·
·
·
·

restrictions on such drugs, manufacturers or manufacturing processes;
restrictions on the labeling or marketing of a drug;
restrictions on drug distribution or use;
requirements to conduct post-marketing studies or clinical trials;
warning letters;
recall or withdrawal of the drugs from the market;
refusal to approve pending applications or supplements to approved applications that we submit;
clinical holds;
fines, restitution or disgorgement of profits or revenue;
suspension or withdrawal of marketing approvals;
refusal to permit the import or export of our drugs;
drug seizure; or
injunctions or the imposition of civil or criminal penalties.

Non-compliance  with  the  European  Union’s  requirements  regarding  safety  monitoring  or  pharmacovigilance,  and
with  requirements  related  to  the  development  of  drugs  for  the  pediatric  population,  can  also  result  in  significant  financial
penalties.  Similarly,  failure  to  comply  with  the  European  Union’s  requirements  regarding  the  protection  of  personal
information can also lead to significant penalties and sanctions.

Our  current  and  future  relationships  with  third-party  payors,  health  care  professionals  and  customers  in  the
United  States  and  elsewhere  may  be  subject,  directly  or  indirectly,  to  applicable  anti-kickback,  fraud  and  abuse,  false
claims,  physician  payment  transparency,  health  information  privacy  and  security  and  other  healthcare  laws  and
regulations, which could expose us to significant penalties.

Healthcare providers, physicians and third-party payors in the United States and elsewhere will play a primary role
in  the  recommendation  and  prescription  of  any  drug  candidates  for  which  we  obtain  marketing  approval.  Our  current  and
future  arrangements  with  third-party  payors,  health  care  professionals  and  customers  may  expose  us  to  broadly  applicable
fraud and abuse and other healthcare laws and regulations, including, without limitation, the federal Anti-Kickback Statute
and the federal civil False Claims Act, that may constrain the business or financial arrangements and relationships through
which we sell, market and distribute any drugs for which we obtain marketing approval. In addition, we may be subject to
transparency laws and patient privacy regulation by the federal government and by the U.S. states and foreign jurisdictions in
which we conduct our business. The applicable federal, state and foreign healthcare laws and regulations that may affect our
ability to operate include the following:

·

the  federal  Anti-Kickback  Statute,  which  prohibits,  among  other  things,  persons  and  entities  from  knowingly  and
willfully soliciting, offering, receiving or providing remuneration, directly or indirectly, in cash or in kind, to induce
or reward, or in return for, either the referral of an individual for, or the purchase, order or recommendation of, any
good or service, for which payment may be made under federal and state healthcare programs such as Medicare and
Medicaid. A person or entity does not need to have actual knowledge of the statute or specific intent to violate it to
have committed a violation.  Further, several courts have interpreted the statute's intent requirement to mean that if
any  one  purpose  of  an  arrangement  involving  remuneration  is  to  induce  referrals  of  federal  healthcare  covered
business, the Anti-Kickback Statute has been violated.  The intent standard was further amended by the Affordable
Care Act, to a stricter standard such that a person or entity no longer needs to have actual knowledge of the statute
or specific intent to violate it in order to have committed a violation.  Moreover, the government may assert that a
claim including items or services resulting from a violation of the federal Anti-Kickback Statute constitutes a false
or fraudulent claim for purposes of the False Claims Act;

52

 
 
 
 
 
 
 
Table of Contents

·

·

·

·

·

federal civil and criminal false claims laws, including, without limitation, the federal civil False Claims Act (that
can be enforced through civil whistleblower or qui tam actions), and the civil monetary penalties law, which impose
criminal and civil penalties, against individuals or entities for knowingly presenting, or causing to be presented, to
the  federal  government,  including  the  Medicare  and  Medicaid  programs,  claims  for  payment  that  are  false  or
fraudulent  or  making  a  false  statement  to  avoid,  decrease  or  conceal  an  obligation  to  pay  money  to  the  federal
government;

HIPAA,  which  imposes  criminal  and  civil  liability  for,  among  other  things,  executing  a  scheme  to  defraud  any
healthcare  benefit  program  or  making  false  statements  relating  to  healthcare  matters.  Similar  to  the  federal  Anti-
Kickback  Statute,  a  person  or  entity  does  not  need  to  have  actual  knowledge  of  the  statute  or  specific  intent  to
violate it to have committed a violation;

HIPAA,  as  amended  by  HITECH,  and  their  respective  implementing  regulations,  which  impose  obligations  on
covered healthcare providers, health plans, and healthcare clearinghouses, as well as their business associates that
create, receive, maintain or transmit individually identifiable health information for or on behalf of a covered entity,
with respect to safeguarding the privacy, security and transmission of individually identifiable health information;

the federal Open Payments program, created under Section 6002 of the Affordable Care Act and its implementing
regulations,  which  requires  specified  manufacturers  of  drugs,  devices,  biologics  and  medical  supplies  for  which
payment  is  available  under  Medicare,  Medicaid  or  the  Children’s  Health  Insurance  Program,  with  specific
exceptions,  to  report  annually  to  the  Centers  for  Medicare  &  Medicaid  Services,  or  CMS,  information  related  to
payments  or  other  “transfers  of  value”  made  to  physicians,  which  is  defined  to  include  doctors,  dentists,
optometrists, podiatrists and chiropractors, and teaching hospitals and applicable manufacturers to report annually to
CMS ownership and investment interests held by physicians and their immediate family members by the 90  day of
each calendar year. All such reported information is publicly available; and

th

analogous  state  and  foreign  laws  and  regulations,  such  as  state  anti-kickback  and  false  claims  laws,  which  may
apply  to  sales  or  marketing  arrangements  and  claims  involving  healthcare  items  or  services  reimbursed  by  non-
governmental  third-party  payors,  including  private  insurers;  state  and  foreign  laws  that  require  pharmaceutical
companies  to  comply  with  the  pharmaceutical  industry’s  voluntary  compliance  guidelines  and  the  relevant
compliance guidance promulgated by the federal government or otherwise restrict payments that may be made to
healthcare providers; state, local and foreign laws that require drug manufacturers to report information related to
payments and other transfers of value to physicians and other healthcare providers or marketing expenditures; and/or
that require registration of certain employees engaged in marketing activities in the location; and state and foreign
laws governing the privacy and security of health information in certain circumstances, many of which differ from
each other in significant ways and often are not preempted by HIPAA, thus complicating compliance efforts.

Efforts to ensure that our business arrangements with third parties will comply with applicable healthcare laws and
regulations  may  involve  substantial  costs.  It  is  possible  that  governmental  authorities  will  conclude  that  our  business
practices,  including  our  relationships  with  physicians  and  other  healthcare  providers,  some  of  whom  may  recommend,
purchase  and/or  prescribe  our  drug  candidates,  may  not  comply  with  current  or  future  statutes,  regulations  or  case  law
involving applicable fraud and abuse or other healthcare laws and regulations. By way of example, some of our consulting
arrangements  with  physicians  may  not  meet  all  of  the  criteria  of  the  personal  services  safe  harbor  under  the  federal  Anti-
Kickback  Statute.  Accordingly,  they  may  not  qualify  for  safe  harbor  protection  from  government  prosecution.  A  business
arrangement  that  does  not  substantially  comply  with  a  safe  harbor,  however,  is  not  necessarily  illegal  under  the  Anti-
Kickback Statute, but may be subject to additional scrutiny by the government.

53

 
 
 
 
 
 
 
Table of Contents

If our operations are found to be in violation of any of these laws or any other governmental regulations that may
apply  to  us,  we  may  be  subject  to  significant  civil,  criminal  and  administrative  penalties,  including,  without  limitation,
damages,  fines,  disgorgement,  individual  imprisonment,  exclusion  from  participation  in  government  healthcare  programs,
such as Medicare and Medicaid, additional reporting requirements and oversight if we become subject to a corporate integrity
agreement or similar agreement to resolve allegations of non-compliance with these laws and the curtailment or restructuring
of our operations, which could have a material adverse effect on our business. If any of the physicians or other healthcare
providers or entities with whom we expect to do business is found not to be in compliance with applicable laws, it may be
subject  to  criminal,  civil  or  administrative  sanctions,  including  exclusions  from  participation  in  government  healthcare
programs, which could also materially affect our business.

Recently enacted and future legislation may increase the difficulty and cost for us to obtain marketing approval

of and commercialize our drug candidates and affect the prices we may obtain.

In the United States, and some foreign jurisdictions, there have been a number of legislative and regulatory changes
and proposed changes regarding the healthcare system that could prevent or delay marketing approval of our drug candidates,
restrict or regulate post-approval activities and affect our ability to profitably sell any drug candidates for which we obtain
marketing approval.

Among  policy  makers  and  payors  in  the  United  States  and  elsewhere,  there  is  significant  interest  in  promoting
changes  in  healthcare  systems  with  the  stated  goals  of  containing  healthcare  costs,  improving  quality  and/or  expanding
access.  In  the  United  States,  the  pharmaceutical  industry  has  been  a  particular  focus  of  these  efforts  and  has  been
significantly affected by major legislative initiatives.  The Affordable Care Act, which was signed into law in March 2010, is
a  sweeping  law  intended  to  broaden  access  to  health  insurance,  reduce  or  constrain  the  growth  of  healthcare  spending,
enhance  remedies  against  fraud  and  abuse,  add  new  transparency  requirements  for  the  healthcare  and  health  insurance
industries, impose new taxes and fees on the health industry and impose additional health policy reforms.

Among the provisions of the Affordable Care Act of importance to our potential drug candidates are the following:

·

·

·

·

·

·

·
·
·
·

an annual, nondeductible fee on any entity that manufactures or imports certain branded prescription drugs and
biologic agents, apportioned among these entities according to their market share in certain government healthcare
programs;
an increase in the statutory minimum rebates a manufacturer must pay under the Medicaid Drug Rebate Program to
23.1% and 13.0% of the average manufacturer price for branded and generic drugs, respectively;
expansion of healthcare fraud and abuse laws, including the False Claims Act and the Anti-Kickback Statute, which
include, among other things, new government investigative powers and enhanced penalties for non-compliance;
a new Medicare Part D coverage gap discount program, in which manufacturers must agree to offer 50% (and 70%
commencing January 1, 2019) point-of-sale discounts off negotiated prices of applicable brand drugs to eligible
beneficiaries during their coverage gap period, as a condition for the manufacturer’s outpatient drugs to be covered
under Medicare Part D;
extension of manufacturers’ Medicaid rebate liability to covered drugs dispensed to individuals who are enrolled in
Medicaid managed care organizations;
expansion of eligibility criteria for Medicaid programs by, among other things, allowing states to offer Medicaid
coverage to additional individuals, thereby potentially increasing manufacturers’ Medicaid rebate liability;
expansion of the entities eligible for discounts under the Public Health Service pharmaceutical pricing program;
the new requirements under the federal Open Payments program and its implementing regulations;
a new requirement to annually report drug samples that manufacturers and distributors provide to physicians; and
a new Patient-Centered Outcomes Research Institute to oversee, identify priorities in, and conduct comparative
clinical effectiveness research, along with funding for such research.

54

 
 
 
 
 
 
 
Table of Contents

Since  its  enactment  there  have  been  judicial  and  Congressional  challenges  to,  as  well  efforts  by  the  Trump
Administration  to  repeal  or  replace  certain  aspects  of  the  Affordable  Care  Act.  As  a  result,  there  have  been  delays  in  the
implementation  of,  and  action  taken  to  repeal  or  replace,  certain  aspects  of  the  Affordable  Care  Act.    For  example,  since
January 2017, President Trump has signed two executive orders and other directives designed to delay, circumvent, or loosen
certain  requirements  mandated  by  the  Affordable  Care  Act.  Concurrently,  Congress  has  considered  legislation  that  would
repeal  or  repeal  and  replace  all  or  part  of  the  Affordable  Care  Act.  While  Congress  has  not  passed  comprehensive  repeal
legislation two bills affecting the implementation of certain taxes under the Affordable Care Act have been signed into law.
The  Tax  Cuts  and  Jobs  Act  of  2017  includes  a  provision  repealing,  effective  January  1,  2019,  the  tax-based  shared
responsibility  payment  imposed  by  the  Affordable  Care  Act  on  certain  individuals  who  fail  to  maintain  qualifying  health
coverage  for  all  or  part  of  a  year  that  is  commonly  referred  to  as  the  “individual  mandate”.   Additionally,  on  January  22,
2018, President Trump signed a continuing resolution on appropriations for fiscal year 2018 that delayed the implementation
of  certain  Affordable  Care  Act-mandated  fees,  including  the  so-called  “Cadillac”  tax  on  certain  high  cost  employer-
sponsored  insurance  plans,  the  annual  fee  imposed  on  certain  health  insurance  providers  based  on  market  share,  and  the
medical device excise tax on non-exempt medical devices. Further, the Bipartisan Budget Act of 2018, or the BBA, among
other things, amends the Affordable Care Act, effective January 1, 2019, to close the coverage gap in most Medicare drug
plans, commonly referred to as the “donut hole”.  Congress may consider other legislation to repeal or replace elements of
the Affordable Care Act. We continue to evaluate the impact of the Affordable Care Act and efforts to repeal or replace the
Affordable Care Act on our business. 

In addition, other legislative changes have been proposed and adopted since the Affordable Care Act was enacted.
These changes included aggregate reductions to Medicare payments to providers of 2% per fiscal year that became effective
on April 1, 2013 and, due to subsequent legislative amendments to the statute, including the BBA, will stay in effect through
2027 unless additional Congressional action is taken.  The American Taxpayer Relief Act of 2012, which was signed into law
in January 2013, among other things, further reduced Medicare payments to several providers, and increased the statute of
limitations period for the government to recover overpayments to providers from three to five years. Any similar new laws
may result in additional reductions in Medicare and other healthcare funding, which could have a material adverse effect on
customers for ESKATA and, if approved, our drug candidates, and, accordingly, our financial operations.

We  expect  that  the  Affordable  Care  Act,  as  well  as  other  healthcare  reform  measures  that  may  be  adopted  in  the
future, may result in more rigorous coverage criteria and in additional downward pressure on the price that we receive for any
approved  drug.  Any  reduction  in  reimbursement  from  Medicare  or  other  government  programs  may  result  in  a  similar
reduction in payments from private payors. The implementation of cost containment measures or other healthcare reforms
may prevent us from being able to generate revenue, attain profitability, or commercialize our drugs.

Legislative  and  regulatory  proposals  have  been  made  to  expand  post-approval  requirements  and  restrict  sales  and
promotional  activities  for  drugs.    In  addition,  there  has  been  heightened  governmental  scrutiny  in  the  United  States  of
pharmaceutical pricing practices in light of the rising cost of prescription drugs and biologics. Such scrutiny has resulted in
several  recent  Congressional  inquiries  and  proposed  and  enacted  federal  and  state  legislation  designed  to,  among  other
things,  bring  more  transparency  to  product  pricing,  review  the  relationship  between  pricing  and  manufacturer  patient
programs,  and  reform  government  program  reimbursement  methodologies  for  products.  At  the  federal  level,  the  Trump
Administration’s  budget  proposal  for  fiscal  year  2019  contains  further  drug  price  control  measures  that  could  be  enacted
during the 2019 budget process or in other future legislation, including, for example, measures to permit Medicare Part D
plans  to  negotiate  the  price  of  certain  drugs  under  Medicare  Part  B,  to  allow  some  states  to  negotiate  drug  prices  under
Medicaid, and to eliminate cost sharing for generic drugs for low-income patients. While any proposed measures will require
authorization  through  additional  legislation  to  become  effective,  Congress  and  the  Trump  Administration  have  both  stated
that  they  will  continue  to  seek  new  legislative  and/or  administrative  measures  to  control  drug  costs.  At  the  state  level,
legislatures  have  become  increasingly  aggressive  in  passing  legislation  and  implementing  regulations  designed  to  control
pharmaceutical and biological product pricing, including price or patient reimbursement constraints, discounts, restrictions on
certain product access and marketing cost disclosure and transparency measures, and, in some cases, designed to encourage
importation  from  other  countries  and  bulk  purchasing    We  cannot  be  sure  whether  additional  legislative  changes  will  be
enacted, or whether the FDA regulations, guidance or interpretations will be changed, or what the impact of such changes on
the marketing approvals of our drug candidates, if any, may be. In addition, increased scrutiny by the U.S. Congress of the
FDA’s approval process may significantly delay or prevent marketing approval, as well as subject us to more stringent drug
labeling and post-marketing testing and other requirements.

55

 
 
 
 
 
Table of Contents

If ESKATA is not granted NCE exclusivity from the FDA, our period of marketing exclusivity for ESKATA will

be shorter than previously anticipated, and our business could be harmed. 

Under the Food, Drug and Cosmetic Act, or FDCA, as amended by the Hatch-Waxman Act, a drug that is granted
regulatory approval may be eligible for five years of marketing exclusivity in the United States following regulatory approval
if that drug is classified as an NCE.  A drug can be classified as an NCE if the FDA has not previously approved any other
drug containing the same active moiety. 

The  FDA  published  a  determination  on  the  marketing  exclusivity  of  ESKATA  in  a  cumulative  supplement  to  its
Orange Book and determined that ESKATA is eligible for a three-year period of exclusivity for a new product, which would
continue until December 14, 2020, rather than the five-year exclusivity for an NCE.  While we believe we are entitled to an
NCE determination for ESKATA, to date the FDA has not agreed with our position.  We are in the process of reviewing our
options  as  it  relates  to  the  FDA’s  determination.    Even  if  we  appeal  the  FDA’s  decision,  there  can  be  no  assurance  that
ESKATA will be granted NCE exclusivity, or that the FDA will make a determination on any such appeal of their exclusivity
decision in a timely manner. 

NCE marketing exclusivity, if granted, would preclude approval during the five-year exclusivity period of certain
505(b)(2)  applications  or  abbreviated  new  drug  applications  that  rely  upon  the  FDA’s  findings  of  safety  and  efficacy  for
ESKATA.  However, such an application may be submitted after four years if it contains a certification of patent invalidity or
non-infringement. In this case, we may be afforded the benefit of a 30-month stay against the launch of such a competitive
product that would extend from the end of the five-year exclusivity period, and may also be afforded other extensions under
applicable regulations, including a judicial extension if applicable requirements are met. If we are not able to gain or exploit
the  period  of  marketing  exclusivity,  we  may  face  significant  competitive  threats  from  other  manufacturers,  including  the
manufacturers of generic alternatives. Further, even if ESKATA is considered to be an NCE and we are able to gain five-year
marketing exclusivity, another company could challenge that decision to seek to overturn the FDA’s determination.

ESKATA has been granted three years of new product exclusivity under the Hatch-Waxman Amendments. A three-
year period of exclusivity is granted under the Hatch-Waxman Amendments for a drug product that contains an active moiety
that  has  been  previously  approved  when  the  application  contains  reports  of  new  clinical  investigations  (other  than
bioavailability  studies)  conducted  by  the  sponsor  that  were  essential  to  approval  of  the  application.    Our  clinical  trials  of
ESKATA were new clinical investigations that were essential to the approval of our NDA.  We are entitled to at least three-
year exclusivity even if the FDA determines that the hydrogen peroxide moiety was previously approved because our clinical
investigations were essential for the approval of our new drug product, ESKATA. 

Such  three-year  exclusivity  protection  precludes  the  FDA  from  approving  a  marketing  application  for  505(b)(2)
NDA or ANDA for the same conditions of approval as ESKATA for a period of three years from the date of ESKATA’s FDA
approval, i.e., through December 14, 2020 although the FDA may accept and commence review of such applications during
the exclusivity period. This three-year form of exclusivity may also not prevent the FDA from approving an NDA that relies
only  on  its  own  data  to  support  the  change  or  innovation.    Any  loss  of  exclusive  marketing  rights  to  ESKATA  through
introduction of generic or competing products would harm our financial position.

Governments  outside  the  United  States  tend  to  impose  strict  price  controls,  which  may  adversely  affect  our

revenue, if any.

In some countries, particularly the countries of the European Union, the pricing of prescription pharmaceuticals is
subject to governmental control. In these countries, pricing negotiations with governmental authorities can take considerable
time after the receipt of marketing approval for a drug. To obtain coverage and reimbursement or pricing approval in some
countries, we may be required to conduct a clinical trial that compares the cost-effectiveness of our drug candidate to other
available  procedures.  If  reimbursement  of  our  drugs  is  unavailable  or  limited  in  scope  or  amount,  or  if  pricing  is  set  at
unsatisfactory levels, our business could be harmed, possibly materially. 

56

 
 
 
 
 
 
 
 
 
Table of Contents

If we fail to comply with environmental, health and safety laws and regulations, we could become subject to fines

or penalties or incur costs that could harm our business.

We  are  subject  to  numerous  environmental,  health  and  safety  laws  and  regulations,  including  those  governing
laboratory  procedures  and  the  handling,  use,  storage,  treatment  and  disposal  of  hazardous  materials  and  wastes.  Our
operations  involve  the  use  of  hazardous  and  flammable  materials,  including  chemicals  and  biological  materials.  Our
operations also produce hazardous waste products. We generally contract with third parties for the disposal of these materials
and wastes. We cannot eliminate the risk of contamination or injury from these materials. In the event of contamination or
injury  resulting  from  our  use  of  hazardous  materials,  we  could  be  held  liable  for  any  resulting  damages,  and  any  liability
could  exceed  our  resources.  We  also  could  incur  significant  costs  associated  with  civil  or  criminal  fines  and  penalties  for
failure to comply with such laws and regulations. 

Although  we  maintain  workers’  compensation  insurance  to  cover  us  for  costs  and  expenses  we  may  incur  due  to
injuries to our employees resulting from the use of hazardous materials, this insurance may not provide adequate coverage
against potential liabilities. We do not maintain insurance for environmental liability or toxic tort claims that may be asserted
against us in connection with our storage or disposal of biological, hazardous or radioactive materials.

In  addition,  we  may  incur  substantial  costs  in  order  to  comply  with  current  or  future  environmental,  health  and
safety laws and regulations. These current or future laws and regulations may impair our development or production efforts.
Our failure to comply with these laws and regulations also may result in substantial fines, penalties or other sanctions. 

The inherent dangers in production and transportation of hydrogen peroxide could cause disruptions and could

expose us to potentially significant losses, costs or liabilities.

Our operations are subject to significant hazards and risks inherent in the use and transport of hydrogen peroxide,
the active ingredient of ESKATA and A-101 45% Topical Solution. Hydrogen peroxide can decompose in the presence of
organic materials and is categorized as an oxidizer and is corrosive. Hydrogen peroxide should be stored in cool, dry, well-
ventilated areas and away from any flammable or combustible substances. The hazards and risks associated with producing
and transporting hydrogen peroxide include fires, explosions, third-party interference (including terrorism) and mechanical
failure of equipment at our facilities or those of our supplier of hydrogen peroxide. The occurrence of any of these events
could  result  in  production  and  distribution  difficulties  and  disruptions,  personal  injury  or  wrongful  death  claims  and  other
damage to properties.

We are subject to governmental economic sanctions and export and import controls that could impair our ability

to compete in international markets or subject us to liability if we are not in compliance with applicable laws.

As a U.S. company, we are subject to U.S. import and export controls and economic sanctions laws and regulations,
and we are required to import and export our product and drug candidates, technology and services in compliance with those
laws and regulations, including the U.S. Export Administration Regulations, the International Traffic in Arms Regulations,
and  economic  embargo  and  trade  sanction  programs  administered  by  the  Treasury  Department’s  Office  of  Foreign  Assets
Control. 

U.S.  economic  sanctions  and  export  control  laws  and  regulations  prohibit  the  shipment  of  certain  products  and
services  to  countries,  governments  and  persons  targeted  by  U.S.  sanctions.  While  we  are  currently  taking  precautions  to
prevent doing any business, directly or indirectly, with countries, governments and persons targeted by U.S. sanctions and to
ensure that our drug candidates, are not exported or used by countries, governments and persons targeted by U.S. sanctions,
such measures may be circumvented. 

Furthermore, if we export our drug candidates, the exports may require authorizations, including a license, a license
exception  or  other  appropriate  government  authorization.  Complying  with  export  control  and  sanctions  regulations  for  a
particular  sale  may  be  time-consuming  and  may  result  in  the  delay  or  loss  of  sales  opportunities.  Failure  to  comply  with
export control and sanctions regulations for a particular sale may expose us to government investigations and penalties. 

57

 
 
 
 
 
 
 
 
 
 
 
Table of Contents

If  we  are  found  to  be  in  violation  of  U.S.  sanctions  or  import  or  export  control  laws,  it  could  result  in  civil  and
criminal,  monetary  and  non-monetary  penalties,  including  possible  incarceration  for  those  individuals  responsible  for  the
violations, the loss of export or import privileges and reputational harm.

We  are  subject  to  anti-corruption  and  anti-money  laundering  laws  with  respect  to  our  operations  and  non-

compliance with such laws can subject us to criminal and/or civil liability and harm our business.

We  are  subject  to  the  U.S.  Foreign  Corrupt  Practices  Act  of  1977,  as  amended,  or  the  FCPA,  the  U.S.  domestic
bribery statute contained in 18 U.S.C. § 201, the U.S. Travel Act, the USA PATRIOT Act and possibly other anti-bribery and
anti-money  laundering  laws  in  countries  in  which  we  conduct  activities.  Anti-corruption  laws  are  interpreted  broadly  and
prohibit  companies  and  their  employees  and  third-party  intermediaries  from  authorizing,  offering  or  providing,  directly  or
indirectly,  improper  payments  or  benefits  to  recipients  in  the  public  or  private  sector.  As  we  commercialize  our  drug
candidates  and  eventually  commence  international  sales  and  business,  we  may  engage  with  collaborators  and  third-party
intermediaries to sell our products abroad and to obtain necessary permits, licenses and other regulatory approvals. We or our
third-party intermediaries may have direct or indirect interactions with officials and employees of government agencies or
state-owned  or  affiliated  entities.  We  can  be  held  liable  for  the  corrupt  or  other  illegal  activities  of  these  third-party
intermediaries, our employees, representatives, contractors, partners and agents, even if we do not explicitly authorize such
activities. 

Noncompliance with anti-corruption and anti-money laundering laws could subject us to whistleblower complaints,
investigations,  sanctions,  settlements,  prosecution,  other  enforcement  actions,  disgorgement  of  profits,  significant  fines,
damages,  other  civil  and  criminal  penalties  or  injunctions,  suspension  and/or  debarment  from  contracting  with  certain
persons,  the  loss  of  export  privileges,  reputational  harm,  adverse  media  coverage  and  other  collateral  consequences.
Responding to any action will likely result in a materially significant diversion of management’s attention and resources and
significant defense costs and other professional fees.

Risks Related to Employee Matters and Managing Our Growth

Our future success depends on our ability to retain key executives and to attract, retain and motivate qualified

personnel.

We  are  highly  dependent  on  the  management,  development,  clinical,  financial,  legal  and  business  development
expertise  of  Dr.  Neal  Walker,  our  Chief  Executive  Officer,  Christopher  Powala,  our  Chief  Regulatory  and  Development
Officer,  Dr.  Stuart  Shanler,  our  Chief  Scientific  Officer,  Frank  Ruffo,  our  Chief  Financial  Officer,  Brett  Fair,  our  Chief
Commercial  Officer,  and  Kamil  Ali-Jackson,  our  Chief  Legal  Officer,  as  well  as  the  other  members  of  our  scientific  and
clinical  teams.  Although  we  have  entered  into  employment  agreements  with  our  executive  officers,  each  of  them  may
currently  terminate  their  employment  with  us  at  any  time.  We  do  not  maintain  “key  person”  insurance  for  any  of  our
executives or employees other than Dr. Walker and Mr. Powala. 

Recruiting and retaining qualified scientific and clinical personnel and, if we progress the development of our drug
pipeline toward scaling up for commercialization, manufacturing and sales and marketing personnel, will also be critical to
our success. The loss of the services of our executive officers or other key employees could impede the achievement of our
development  and  commercialization  objectives  and  seriously  harm  our  ability  to  successfully  implement  our  business
strategy. Furthermore, replacing executive officers and key employees may be difficult and may take an extended period of
time  because  of  the  limited  number  of  individuals  in  our  industry  with  the  breadth  of  skills  and  experience  required  to
successfully  develop,  gain  marketing  approval  of  and  commercialize  drugs.  Competition  to  hire  from  this  limited  pool  is
intense, and we may be unable to hire, train, retain or motivate these key personnel on acceptable terms given the competition
among numerous pharmaceutical and biotechnology companies for similar personnel. We also experience competition for the
hiring of scientific and clinical personnel from universities and research institutions. In addition, we rely on consultants and
advisors,  including  scientific  and  clinical  advisors,  to  assist  us  in  formulating  our  development  and  commercialization
strategy.  Our  consultants  and  advisors  may  be  employed  by  employers  other  than  us  and  may  have  commitments  under
consulting  or  advisory  contracts  with  other  entities  that  may  limit  their  availability  to  us.  If  we  are  unable  to  continue  to
attract and retain high quality personnel, our ability to pursue our growth strategy will be limited. 

58

 
 
 
 
 
 
 
 
 
Table of Contents

We  expect  to  expand  our  development  and  regulatory  capabilities  and  implement  sales,  marketing  and
distribution capabilities, and as a result, we may encounter difficulties in managing our growth, which could disrupt our
operations.

As of December 31, 2017, we had 96 full-time and part-time employees. As our development progresses, we expect
to experience significant growth in the number of our employees and the scope of our operations, particularly in the areas of
drug development, regulatory affairs, sales, marketing and distribution. To manage our anticipated future growth, we must
continue to implement and improve our managerial, operational and financial systems, expand our facilities and continue to
recruit  and  train  additional  qualified  personnel.  Due  to  our  limited  financial  resources  and  the  limited  experience  of  our
management  team  in  managing  a  company  with  such  anticipated  growth,  we  may  not  be  able  to  effectively  manage  the
expansion of our operations or recruit and train additional qualified personnel. The expansion of our operations may lead to
significant costs and may divert our management and business development resources. Any inability to manage growth could
delay the execution of our business plans or disrupt our operations.

Our  employees,  independent  contractors,  consultants,  commercial  collaborators,  principal  investigators,  CROs
and vendors may engage in misconduct or other improper activities, including non-compliance with regulatory standards
and requirements.

We  are  exposed  to  the  risk  that  our  employees,  independent  contractors,  consultants,  commercial  collaborators,
principal investigators, CROs and vendors may engage in fraudulent conduct or other illegal activity. Misconduct by these
parties could include intentional, reckless and/or negligent conduct or disclosure of unauthorized activities to us that violates
FDA  regulations,  including  those  laws  requiring  the  reporting  of  true,  complete  and  accurate  information  to  the  FDA,
manufacturing  standards,  federal  and  state  healthcare  laws  and  regulations,  and  laws  that  require  the  true,  complete  and
accurate reporting of financial information or data. In particular, sales, marketing and business arrangements in the healthcare
industry are subject to extensive laws and regulations intended to prevent fraud, kickbacks, self-dealing and other abusive
practices. These laws and regulations may restrict or prohibit a wide range of pricing, discounting, marketing and promotion,
sales  commission,  customer  incentive  programs  and  other  business  arrangements.  Misconduct  by  these  parties  could  also
involve the improper use of individually identifiable information, including, without limitation, information obtained in the
course of clinical trials, which could result in regulatory sanctions and serious harm to our reputation. We have adopted a
code of business conduct and ethics, but it is not always possible to identify and deter misconduct, and the precautions we
take  to  detect  and  prevent  this  activity  may  not  be  effective  in  controlling  unknown  or  unmanaged  risks  or  losses  or  in
protecting us from governmental investigations or other actions or lawsuits stemming from a failure to be in compliance with
such laws or regulations. If any such actions are instituted against us, and we are not successful in defending ourselves or
asserting  our  rights,  those  actions  could  have  a  significant  impact  on  our  business,  including  the  imposition  of  significant
civil,  criminal  and  administrative  penalties,  including,  without  limitation,  damages,  fines,  disgorgement,  imprisonment,
exclusion  from  participation  in  government  healthcare  programs,  such  as  Medicare  and  Medicaid,  additional  reporting
obligations  and  oversight  if  we  are  subject  to  a  corporate  integrity  agreement  or  other  agreement  to  resolve  allegations  of
non-compliance with these laws, and the curtailment or restructuring of our operations.

We may not realize the anticipated benefits of our acquisition of Confluence.

In  August  2017,  we  acquired  Confluence  Life  Sciences,  Inc.,  or  Confluence,  including  several  preclinical  drug
candidates and Confluence’s contract research services business. Acquisitions are inherently risky, and we may not realize
the anticipated benefits of the acquisition of Confluence.  Specifically, we are subject to the risks that:

·

·
·

·

we fail to successfully develop or integrate Confluence’s preclinical drug candidates into our pipeline in order to
achieve our strategic objectives;
we are unable to adequately integrate or continue operating Confluence’s contract research services business;
we receive inadequate or unfavorable data from preclinical studies or clinical trials evaluating the acquired
preclinical drug candidates; and
our due diligence processes in connection with the acquisition failed to identify significant problems, liabilities or
other shortcomings or challenges of Confluence, including problems, liabilities or other shortcomings or challenges
with respect to intellectual property, product quality and safety and other known and unknown liabilities. 

59

 
 
 
 
 
 
 
 
Table of Contents

If we are unable to successfully integrate Confluence’s business and employees, it could have an adverse effect

on our future results and the market price of our common stock. 

The success of our acquisition of Confluence will depend, in large part, on our ability to realize operating synergies
from  combining  our  business  with  Confluence’s  business.  To  realize  these  anticipated  benefits,  we  must  successfully
integrate Confluence’s business and employees. This integration will be complex and time-consuming. 

The failure to successfully integrate and manage the challenges presented by the integration process may result in
our failure to achieve some or all of the anticipated benefits of the merger. Potential difficulties that may be encountered in
the integration process include the following:

·
·
·

·

·
·

complexities associated with managing the larger combined company with distant business locations;
integrating personnel from the two companies;
current and prospective employees may experience uncertainty regarding their future roles with our company, which
might adversely affect our ability to retain, recruit and motivate key personnel;
lost revenue and customers as a result of customers of Confluence’s contract research services business deciding not
to do business with the combined company;
potential unknown liabilities and unforeseen expenses associated with the merger; and
performance shortfalls at one or both of the companies as a result of the diversion of management’s attention caused
by completing the merger and integrating the companies’ operations.

If any of these events were to occur, the ability of the combined company to maintain relationships with customers,
suppliers and employees or our ability to achieve the anticipated benefits of the merger could be adversely affected, or could
reduce our future earnings or otherwise adversely affect our business and financial results and, as a result, adversely affect
the market price of our common stock.

Charges to earnings resulting from the acquisition of Confluence may cause our operating results to suffer. 

Under  accounting  principles,  we  will  allocate  the  total  purchase  price  of  the  merger  to  Confluence’s  net  tangible
assets  and  intangible  assets  based  on  their  fair  values  as  of  the  date  of  the  merger,  and  we  will  record  the  excess  of  the
purchase price over those fair values as goodwill. Our management’s estimates of fair value will be based upon assumptions
that  they  believe  to  be  reasonable  but  that  are  inherently  uncertain.  The  following  factors,  among  others,  could  result  in
material charges that would cause our financial results to be negatively impacted:

·
·
·

impairment of goodwill;
charges for the amortization of identifiable intangible assets and for stock-based compensation; and
accrual of newly identified pre-merger contingent liabilities that are identified subsequent to the finalization of the
purchase price allocation.

Additional costs may include costs of employee redeployment, relocation and retention, including salary increases
or bonuses, taxes and termination of contracts that provide redundant or conflicting services. Some of these costs may have to
be accounted for as expenses that would negatively impact our results of operations.  

Risks Related to Ownership of Our Common Stock

An active trading market for our common stock may not continue to develop or be sustained.

Prior to our initial public offering in October 2015, there was no public market for our common stock. Although our
common  stock  is  listed  on  The  Nasdaq  Global  Select  Market,  we  cannot  assure  you  that  an  active  trading  market  for  our
shares will continue to develop or be sustained. If an active market for our common stock does not continue to develop or is
not sustained, it may be difficult for investors in our common stock to sell shares without depressing the market price for the
shares or to sell the shares at all. 

60

 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

The trading price of the shares of our common stock has been and is likely to continue to be volatile.

Since our initial public offering, our stock price has been and is likely to continue to be volatile. The stock market in
general  and  the  market  for  biotechnology  companies  in  particular  have  experienced  extreme  volatility  that  has  often  been
unrelated to the operating performance of particular companies. As a result of this volatility, investors may not be able to sell
their common stock at or above the price paid for the shares. The market price for our common stock may be influenced by
many factors, including:

·

·

·
·
·
·
·
·
·

·

·
·
·
·
·
·
·

·
·
·

the commencement, enrollment or results of any clinical trials we may conduct, or changes in the development
status of our drug candidates;
any delay in our regulatory filings for any of our drug candidates and any adverse development or perceived adverse
development with respect to the applicable regulatory authority’s review of such filings, including without limitation
the FDA’s issuance of a “refusal to file” letter or a request for additional information;
adverse results from, delays in or termination of clinical trials;
adverse regulatory decisions, including failure to receive marketing approval of our drug candidates;
unanticipated serious safety concerns related to the use of ESKATA or any other drug candidate;
changes in financial estimates by us or by any securities analysts who might cover our stock;
conditions or trends in our industry;
changes in the market valuations of similar companies;
stock market price and volume fluctuations of comparable companies and, in particular, those that operate in the
biotechnology industry;
publication of research reports about us or our industry or positive or negative recommendations or withdrawal of
research coverage by securities analysts;
announcements by us or our competitors of significant acquisitions, strategic partnerships or divestitures;
announcements of investigations or regulatory scrutiny of our operations or lawsuits filed against us;
investors’ general perception of our company and our business;
recruitment or departure of key personnel;
overall performance of the equity markets;
trading volume of our common stock;
disputes or other developments relating to proprietary rights, including patents, litigation matters and our ability to
obtain patent protection for our technologies;
significant lawsuits, including patent or stockholder litigation;
general political and economic conditions; and
other events or factors, many of which are beyond our control.

In addition, in the past, stockholders have initiated class action lawsuits against pharmaceutical and biotechnology
companies following periods of volatility in the market prices of these companies’ stock. Such litigation, if instituted against
us, could cause us to incur substantial costs and divert management’s attention and resources from our business.

If equity research analysts do not publish research or reports, or publish unfavorable research or reports, about

us, our business or our market, our stock price and trading volume could decline.

The  trading  market  for  our  common  stock  is  influenced  by  the  research  and  reports  that  equity  research  analysts
publish  about  us  or  our  business,  our  market  and  our  competitors.  Equity  research  analysts  may  elect  not  to  initiate  or
continue to provide research coverage of our common stock, and such lack of research coverage may adversely affect the
market price of our common stock. Even if we have equity research analyst coverage, we will not have any control over the
analysts  or  the  content  and  opinions  included  in  their  reports.  The  price  of  our  stock  could  decline  if  one  or  more  equity
research  analysts  downgrade  our  stock  or  issue  other  unfavorable  commentary  or  research.  If  one  or  more  equity  research
analysts  ceases  coverage  of  our  company  or  fails  to  publish  reports  on  us  regularly,  demand  for  our  stock  could  decrease,
which in turn could cause our stock price or trading volume to decline. 

61

 
 
 
 
 
 
 
Table of Contents

The  issuance  of  additional  stock  in  connection  with  financings,  acquisitions,  investments,  our  equity  incentive

plan or otherwise will dilute all other stockholders.

Our  certificate  of  incorporation  authorizes  us  to  issue  up  to  100,000,000  shares  of  common  stock  and  up  to
10,000,000  shares  of  preferred  stock  with  such  rights  and  preferences  as  may  be  determined  by  our  board  of  directors.
Subject  to  compliance  with  applicable  rules  and  regulations,  we  may  issue  our  shares  of  common  stock  or  securities
convertible  into  our  common  stock  from  time  to  time  in  connection  with  a  financing,  acquisition,  investment,  our  equity
incentive plan or otherwise. Any such issuance could result in substantial dilution to our existing stockholders and cause the
trading price of our common stock to decline. 

Sales of a substantial number of shares of our common stock into the market could cause the market price of our

common stock to drop significantly, even if our business is doing well.

Sales of a substantial number of shares of our common stock in the public market could occur at any time. If our
stockholders sell, or the market perceives that our stockholders intend to sell, substantial amounts of our common stock in the
public market, the market price of our common stock could decline significantly.

In addition, we have filed registration statements on Form S-8 under the Securities Act registering the issuance of
shares  of  common  stock  subject  to  options  or  other  equity  awards  issued  or  reserved  for  future  issuance  under  our  equity
incentive  plans.  Shares  registered  under  these  registration  statements  are  available  for  sale  in  the  public  market  subject  to
vesting  arrangements  and  exercise  of  options,  and  the  restrictions  of  Rule  144  under  the  Securities  Act  in  the  case  of  our
affiliates.

Additionally,  certain  holders  of  shares  of  our  common  stock,  or  their  transferees,  have  rights,  subject  to  some
conditions,  to  require  us  to  file  one  or  more  registration  statements  covering  their  shares  or  to  include  their  shares  in
registration statements that we may file for ourselves or other stockholders. If we were to register the resale of these shares,
they could be freely sold in the public market. If these additional shares are sold, or if it is perceived that they will be sold, in
the public market, the trading price of our common stock could decline.

Provisions in our corporate charter documents and under Delaware law may prevent or frustrate attempts by our
stockholders to change our management and hinder efforts to acquire a controlling interest in us, and the market price of
our common stock may be lower as a result.

There  are  provisions  in  our  certificate  of  incorporation  and  bylaws  that  may  make  it  difficult  for  a  third  party  to
acquire, or attempt to acquire, control of our company, even if a change of control was considered favorable by some or all of
our stockholders. For example, our board of directors has the authority to issue up to 10,000,000 shares of preferred stock.
The  board  of  directors  can  fix  the  price,  rights,  preferences,  privileges,  and  restrictions  of  the  preferred  stock  without  any
further vote or action by our stockholders. The issuance of shares of preferred stock may delay or prevent a change of control
transaction. As a result, the market price of our common stock and the voting and other rights of our stockholders may be
adversely affected. An issuance of shares of preferred stock may result in the loss of voting control to other stockholders.

Our charter documents also contain other provisions that could have an anti-takeover effect, including:

·
·
·
·
·

only one of our three classes of directors is elected each year;
stockholders are not entitled to remove directors other than by a 66 % vote and only for cause;
stockholders are not permitted to take actions by written consent;
stockholders cannot call a special meeting of stockholders; and
stockholders must give advance notice to nominate directors or submit proposals for consideration at stockholder
meetings.

2/3

In addition, we are subject to the anti-takeover provisions of Section 203 of the Delaware General Corporation Law,
which  regulates  corporate  acquisitions  by  prohibiting  Delaware  corporations  from  engaging  in  specified  business
combinations  with  particular  stockholders  of  those  companies.  These  provisions  could  discourage  potential  acquisition
proposals and could delay or prevent a change of control transaction. They could also have the effect of discouraging others
from making tender offers for our common stock, including transactions that may be in your best interests. These provisions
may also prevent changes in our management or limit the price that investors are willing to pay for our stock.

62

 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Concentration of ownership of our common stock among our existing executive officers, directors and principal

stockholders may prevent new investors from influencing significant corporate decisions.

Our  executive  officers,  directors  and  current  beneficial  owners  of  5%  or  more  of  our  common  stock  and  their
respective affiliates beneficially own a substantial portion of our common stock. As a result, these persons, acting together,
would  be  able  to  significantly  influence  all  matters  requiring  stockholder  approval,  including  the  election  and  removal  of
directors, any merger, consolidation, sale of all or substantially all of our assets, or other significant corporate transactions.
The interests of this group of stockholders may not coincide with our interests or the interests of other stockholders.

We are an “emerging growth company” and, as a result of the reduced disclosure and governance requirements

applicable to emerging growth companies, our common stock may be less attractive to investors.

We are an “emerging growth company” as defined in the Jumpstart Our Business Startups Act of 2012, or the JOBS
Act,  and  we  intend  to  take  advantage  of  some  of  the  exemptions  from  reporting  requirements  that  are  applicable  to  other
public companies that are not emerging growth companies, including:

·

·

·

·

·

being permitted to provide only two years of audited financial statements, in addition to any required unaudited
interim financial statements, with correspondingly reduced “Management’s Discussion and Analysis of Financial
Condition and Results of Operations” disclosure in this report;
not being required to comply with the auditor attestation requirements in the assessment of our internal control over
financial reporting;
not being required to comply with any requirement that may be adopted by the Public Company Accounting
Oversight Board regarding mandatory audit firm rotation or a supplement to the auditor’s report providing
additional information about the audit and the financial statements;
reduced disclosure obligations regarding executive compensation in our periodic reports, proxy statements and
registration statements; and
not being required to hold a nonbinding advisory vote on executive compensation and stockholder approval of any
golden parachute payments not previously approved.

We cannot predict if investors will find our common stock less attractive because we will rely on these exemptions.
If some investors find our common stock less attractive as a result, there may be a less active trading market for our common
stock and our stock price may be more volatile. We may take advantage of these reporting exemptions until we are no longer
an emerging growth company. We will remain an emerging growth company until the earlier of (1) December 31, 2020, (2)
the last day of the fiscal year in which we have total annual gross revenue of at least $1.07 billion, (3) the last day of the
fiscal year in which we are deemed to be a large accelerated filer, which means the market value of our common stock that is
held by non-affiliates exceeds $700 million as of the prior June 30th and (4) any date on which we have issued more than
$1.0 billion in non-convertible debt during the prior three-year period.

Under Section 107(b) of the JOBS Act, emerging growth companies can delay adopting new or revised accounting
standards until such time as those standards apply to private companies. We have irrevocably elected not to avail ourselves of
this  exemption  from  new  or  revised  accounting  standards  and,  therefore,  we  will  be  subject  to  the  same  new  or  revised
accounting standards as other public companies that are not emerging growth companies.

If we fail to maintain proper and effective internal controls, our ability to produce accurate financial statements

on a timely basis could be impaired.

We  are  subject  to  the  reporting  requirements  of  the  Exchange  Act,  the  Sarbanes-Oxley  Act  and  the  rules  and
regulations of the stock market on which our common stock is listed. The Sarbanes-Oxley Act requires, among other things,
that  we  maintain  effective  disclosure  controls  and  procedures  and  internal  control  over  financial  reporting,  and  perform
system and process evaluation and testing of our internal control over financial reporting to allow management to report on
the  effectiveness  of  our  internal  control  over  financial  reporting.  This  requires  that  we  incur  substantial  additional
professional  fees  and  internal  costs  to  expand  our  accounting  and  finance  functions  and  that  we  expend  significant
management efforts.

We may identify weaknesses in our system of internal financial and accounting controls and procedures that could

result in a material misstatement of our consolidated financial statements. Our internal control over financial reporting will

63

 
 
 
 
 
 
 
 
 
 
 
Table of Contents

not prevent or detect all errors and all fraud. A control system, no matter how well designed and operated, can provide only
reasonable, not absolute, assurance that the control system’s objectives will be met. Because of the inherent limitations in all
control systems, no evaluation of controls can provide absolute assurance that misstatements due to error or fraud will not
occur or that all control issues and instances of fraud will be detected.

If  we  are  unable  to  maintain  proper  and  effective  internal  controls,  we  may  not  be  able  to  produce  timely  and
accurate financial statements, and we may conclude that our internal control over financial reporting is not effective. If that
were to happen, the market price of our stock could decline, and we could be subject to sanctions or investigations by the
stock exchange on which our common stock is listed, the SEC, or other regulatory authorities.

We might not be able to utilize a significant portion of our net operating loss carryforwards and research and

development tax credit carryforwards.

As of December 31, 2017, we had federal and state net operating loss carryforwards of $77.2 million and $119.3
million,  respectively,  which  begin  to  expire  in  2032.    As  of  December  31,  2017,  we  also  had  federal  research  and
development tax credit carryforwards of $2.2 million which begin to expire in 2032, and state research and development tax
credit  carryforwards  of  $0.1  million  which  begin  to  expire  in  2022.  These  net  operating  loss  and  tax  credit  carryforwards
could expire unused and be unavailable to offset future income tax liabilities. In addition, under Section 382 of the Internal
Revenue  Code  of  1986,  as  amended,  and  corresponding  provisions  of  state  law,  if  a  corporation  undergoes  an  “ownership
change,” which is generally defined as a greater than 50% change, by value, in its equity ownership over a three-year period,
the corporation’s ability to use its pre-change net operating loss carryforwards and other pre-change tax attributes to offset its
post-change income may be limited.  We have completed an analysis under Section 382 for net operating loss carryforwards
generated from July 13, 2012 through December 31, 2016.  Although we have experienced Section 382 ownership changes
since 2012, we have concluded that we should have sufficient ability to utilize net operating loss carryforwards accumulated
during the periods tested.  We have not yet determined if a Section 382 ownership change has occurred during the year ended
December 31, 2017, or for Confluence prior to the acquisition.  In addition, we may experience ownership changes in the
future as a result of subsequent shifts in our stock ownership, some of which may be outside of our control. If we determine
that an ownership change has occurred and our ability to use our historical net operating loss and tax credit carryforwards is
materially limited, it would harm our future operating results by effectively increasing our future tax obligations. 

The recently passed comprehensive tax reform bill could adversely affect our business and financial condition.

On  December  22,  2017,  the  Tax  Cuts  and  Jobs  Act  was  signed  into  law  which  significantly  revised  the  Internal
Revenue Code of 1986, as amended.  The newly enacted federal income tax law, among other things, contains significant
changes to corporate taxation, including reduction of the corporate tax rate from a top marginal rate of 35% to a flat rate of
21%, limitation of the tax deduction for interest expense to 30% of adjusted earnings (except for certain small businesses),
limitation of the deduction for net operating losses to 80% of current year taxable income and elimination of net operating
loss carrybacks, one time taxation of offshore earnings at reduced rates regardless of whether they are repatriated, elimination
of U.S. tax on foreign earnings (subject to certain important exceptions), immediate deductions for certain new investments
instead  of  deductions  for  depreciation  expense  over  time,  and  modifying  or  repealing  many  business  deductions  and
credits.    Notwithstanding  the  reduction  in  the  corporate  income  tax  rate,  the  overall  impact  of  the  new  federal  tax  law  is
uncertain and our business and financial condition could be adversely affected.  In addition, it is uncertain how various states
will respond to the newly enacted federal tax law.  The impact of this tax reform on holders of our common stock is also
uncertain and could be adverse.  We urge our stockholders to consult with their legal and tax advisors with respect to this
legislation and the potential tax consequences of investing in or holding our common stock.

We have broad discretion in the use of proceeds from our equity financing transactions and may invest or spend

the proceeds in ways with which you do not agree and in ways that may not increase the value of your investment.

We have broad discretion over the use of proceeds from our equity financing transactions over the last several years.
You may not agree with our decisions, and our use of the proceeds may not yield any return on your investment. We expect to
use  the  net  proceeds  from  those  transactions  to  fund  our  research  and  development  expenses  and  for  working  capital  and
general  corporate  purposes.  Our  failure  to  apply  the  net  proceeds  effectively  could  compromise  our  ability  to  pursue  our
strategy and we might not be able to yield a significant return, if any, on our investment of these net proceeds. Stockholders
will not have the opportunity to influence our decisions on how to use these net proceeds.

64

 
 
 
 
 
 
 
 
 
Table of Contents

We  do  not  anticipate  paying  any  cash  dividends  on  our  common  stock  in  the  foreseeable  future  and  our  stock

may not appreciate in value.

We have not declared or paid cash dividends on our common stock to date. We currently intend to retain our future
earnings, if any, to fund the development and growth of our business. In addition, the terms of any existing or future debt
agreements may preclude us from paying dividends. There is no guarantee that shares of our common stock will appreciate in
value or that the price at which our stockholders have purchased their shares will be able to be maintained.

We will incur increased costs and demands upon management as a result of being a public company.

As a public company listed in the United States, we have begun, and will continue, particularly after we cease to be
an “emerging growth company,” to incur significant additional legal, accounting and other costs. These additional costs could
negatively affect our financial results. In addition, changing laws, regulations and standards relating to corporate governance
and public disclosure, including regulations implemented by the SEC and The Nasdaq Stock Market, may increase legal and
financial compliance costs and make some activities more time-consuming. These laws, regulations and standards are subject
to varying interpretations and, as a result, their application in practice may evolve over time as new guidance is provided by
regulatory and governing bodies. We intend to invest resources to comply with evolving laws, regulations and standards, and
this  investment  may  result  in  increased  general  and  administrative  expenses  and  a  diversion  of  management’s  time  and
attention from revenue-generating activities to compliance activities. If notwithstanding our efforts to comply with new laws,
regulations and standards, we fail to comply, regulatory authorities may initiate legal proceedings against us and our business
may be harmed.

Failure  to  comply  with  these  rules  might  also  make  it  more  difficult  for  us  to  obtain  some  types  of  insurance,
including  director  and  officer  liability  insurance,  and  we  might  be  forced  to  accept  reduced  policy  limits  and  coverage  or
incur substantially higher costs to obtain the same or similar coverage. The impact of these events could also make it more
difficult  for  us  to  attract  and  retain  qualified  persons  to  serve  on  our  board  of  directors,  on  committees  of  our  board  of
directors or as members of senior management.

Our  amended  and  restated  certificate  of  incorporation  provides  that  the  Court  of  Chancery  of  the  State  of
Delaware  is  the  exclusive  forum  for  certain  litigation  that  may  be  initiated  by  our  stockholders,  which  could  limit  our
stockholders’ ability to obtain a favorable judicial forum for disputes with us or our directors, officers or employees.

Our amended and restated certificate of incorporation provides that the Court of Chancery of the State of Delaware
is the exclusive forum for (i) any derivative action or proceeding brought on our behalf, (ii) any action asserting a claim for
breach of a fiduciary duty owed by any of our directors, officers or other employees to us or our stockholders, (iii) any action
asserting  a  claim  arising  pursuant  to  any  provision  of  the  Delaware  General  Corporation  Law,  our  amended  and  restated
certificate of incorporation or our amended and restated bylaws or (iv) any action asserting a claim governed by the internal
affairs doctrine. The choice of forum provision may limit a stockholder’s ability to bring a claim in a judicial forum that it
finds favorable for disputes with us or our directors, officers or other employees, which may discourage such lawsuits against
us  and  our  directors,  officers  and  other  employees.  Alternatively,  if  a  court  were  to  find  the  choice  of  forum  provision
contained in our amended and restated certificate of incorporation to be inapplicable or unenforceable in an action, we may
incur additional costs associated with resolving such action in other jurisdictions, which could adversely affect our business
and financial condition. 

Item 1B. Unresolved Staff Comments

None.

65

 
 
 
 
 
 
 
 
 
 
Table of Contents

Item 2. Properties

We  currently  sublease  33,019  square  feet  of  space  for  our  headquarters  in  Wayne,  Pennsylvania.    Subject  to  the
consent  of  Chesterbrook  Partners,  LP,  the  Landlord,  as  set  forth  in  the  lease  by  and  between  them  and  Auxilium
Pharmaceuticals,  LLC,  the  Sublandlord,  the  term  of  our  sublease  has  a  term  through  October  2023.    If  for  any  reason  the
lease between the Landlord and Sublandlord is terminated or expires prior to October 2023, our sublease will automatically
terminate.  We also lease an additional 2,534 square feet of space in Malvern, Pennsylvania with a term through November
2019, and we occupy 3,689 square feet of office and laboratory space in St. Louis, Missouri under the terms of an agreement
which expires in December 2018.  We believe that our facilities are suitable and adequate to meet our current needs. 

Item 3. Legal Proceedings

We are not subject to any material legal proceedings.

Item 4. Mine Safety Disclosures

Not applicable.

66

 
 
 
 
 
 
 
Table of Contents

PART II

Item  5.  Market  for  Registrant’s  Common  Equity,  Related  Stockholder  Matters  and  Issuer  Purchases  of  Equity
Securities

Market Information for Common Stock

Our common stock commenced trading on the Nasdaq Global Select Market under the symbol “ACRS” in October
2015. Prior to our initial public offering, there was no public market for our common stock.  The following table sets forth for
the periods indicated the high and low sales prices of our common stock as reported on the Nasdaq Global Select Market.

2017
First Quarter
Second Quarter
Third Quarter
Fourth Quarter

2016
First Quarter
Second Quarter
Third Quarter
Fourth Quarter

  $

  $

High 

Low 

33.25   $
33.10  
30.08  
28.62  

27.94   $
23.58  
25.76  
31.80  

24.83  
22.75  
22.31  
21.32  

14.12  
16.86  
17.90  
20.15  

On March 9, 2018, the last reported bid price for our common stock was $21.28 per share.

Dividend Policy

We have never declared or paid any dividends on our common stock. We anticipate that we will retain all of our
future earnings, if any, for use in the operation and expansion of our business and do not anticipate paying cash dividends in
the foreseeable future.

Stockholders

As of March 9, 2018, we had 30,901,492 shares of common stock outstanding held by 70 holders of record. The
actual  number  of  stockholders  is  greater  than  this  number  of  record  holders  and  includes  stockholders  who  are  beneficial
owners but whose shares are held in street name by brokers and other nominees. This number of holders of record also does
not include stockholders whose shares may be held in trust by other entities.

67

 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Performance Graph

The following graph compares the performance of our common stock since October 7, 2015, the date on which our
common  stock  commenced  trading  on  the  Nasdaq  Global  Select  Market,  with  the  performance  of  the  Nasdaq  Composite
Index (U.S.) and the Nasdaq Biotechnology Index. The comparison assumes a $100 investment on October 7, 2015 in our
common  stock,  the  stocks  comprising  the  Nasdaq  Composite  Index,  and  the  stocks  comprising  the  Nasdaq  Biotechnology
Index, and assumes reinvestment of the full amount of all dividends, if any. Historical stockholder return is not necessarily
indicative of the performance to be expected for any future periods. 

Comparison of Cumulative Total Return
Among Aclaris Therapeutics, Inc., the Nasdaq Composite Index and the Nasdaq Biotechnology Index

The  performance  graph  shall  not  be  deemed  to  be  incorporated  by  reference  by  means  of  any  general  statement
incorporating by reference this Form 10-K into any filing under the Securities Act of 1933, as amended or the Exchange Act,
except to the extent that we specifically incorporate such information by reference, and shall not otherwise be deemed filed
under such acts. 

Recent Sales of Unregistered Securities

None.

Purchases of Equity Securities by the Issuer and Affiliated Parties

None.

68

 
 
 
 
 
 
 
 
 
 
Table of Contents

Item 6. Selected Consolidated Financial Data

The following selected consolidated statement of operations data for the years ended December 31, 2017, 2016 and
2015,  and  consolidated  balance  sheet  data  as  of  December  31,  2017  and  2016  is  derived  from  our  audited  consolidated
financial statements included within this Annual Report. The consolidated balance sheet data as of December 31, 2015, 2014
and  2013,  and  the  consolidated  statement  of  operations  data  for  the  year  ended  December  31,  2014  and  2013  have  been
derived  from  our  audited  consolidated  financial  statements  which  are  not  included  herein.  Our  historical  results  are  not
necessarily indicative of the results to be expected in the future. The selected financial data should be read together with Item
7. “Management’s Discussion and Analysis of Financial Condition and Results of Operations” and in conjunction with the
consolidated financial statements, related notes, and other financial information included elsewhere in this Annual Report. 

Consolidated Statement of Operations
Data:
Revenue
Cost of revenue
Gross profit
Operating expenses:

Research and development
General and administrative
Total operating expenses

Loss from operations
Other income, net
Provision for (benefit from) income taxes
Net loss
Accretion of convertible preferred stock
Net loss attributable to common
stockholders
Net loss per share attributable to common
stockholders, basic and diluted
Weighted average common shares
outstanding, basic and diluted

Consolidated Balance Sheet Data:
Cash, cash equivalents and marketable
securities
Working capital 
Total assets
Convertible preferred stock
Total stockholders’ equity (deficit)

(a)

2017

2016

Year Ended December 31,
2015
(in thousands)

2014

2013

$

$

$

$

1,683  
1,207  
476  

 —   $
 —  
 —  

 —   $
 —  
 —  

 —   $
 —  
 —  

39,790  
33,109  
72,899  
(72,423) 
2,070  
(1,830) 
(68,523) 
 -  

(68,523) 

(2.44) 

33,476  
15,091  
48,567  
(48,567) 
488  
 —  
(48,079) 
 -  

15,339  
5,328  
20,667  
(20,667) 
104  
 —  
(20,563) 
(2,566) 

6,507  
2,026  
8,533  
(8,533) 
16  
 —  

(8,517) 
(2,054) 

$

$

(48,079) 

$ (23,129) 

$ (10,571) 

(2.25) 

$

(3.79) 

$

(6.15) 

$

$

 —  
 —  
 —  

3,488  
1,769  
5,257  
(5,257) 
21  
 —  
(5,236) 
(1,740) 

(6,976) 

(6.45) 

 28,102,386

 21,415,733

 6,107,042

 1,720,082

 1,081,347  

2017

2016

As of December 31,
2015
(in thousands)

2014

2013

$ 208,854  
  187,459  
  243,509  

$ 174,134  
  132,333  
  176,085  

 -

 -

$ 92,038  
  84,969  
  94,076  

 -

  225,262  

  169,490  

  92,521  

$

16,648  
  14,883  
  17,377  
  36,677  
  (20,755) 

$ 14,126  
  13,019  
  14,207  
  23,000  
  (9,163) 

(a) Working capital is defined as current assets minus current liabilities

69

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
         
           
           
           
           
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
 
 
 
 
 
           
           
           
           
           
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations

You  should  read  the  following  discussion  and  analysis  of  our  financial  condition  and  results  of  operations  in
conjunction with the consolidated financial statements and the related notes to those statements included later in this Annual
Report.  In  addition  to  historical  financial  information,  the  following  discussion  contains  forward‑looking  statements  that
reflect our plans, estimates, beliefs and expectations that involve risks and uncertainties. Our actual results and the timing of
events  could  differ  materially  from  those  discussed  in  these  forward‑looking  statements.  Factors  that  could  cause  or
contribute to these differences include those discussed below and elsewhere in this Annual Report, particularly in “Item 1A.
Risk Factors” and “Special Note Regarding Forward‑Looking Statements.”

Overview

We  are  a  dermatologist-led  biopharmaceutical  company  focused  on  identifying,  developing  and  commercializing
innovative  and  differentiated  therapies  to  address  significant  unmet  needs  in  medical  and  aesthetic  dermatology.  Our  lead
product  ESKATA  (hydrogen  peroxide)  topical  solution,  40%  (w/w),  or  ESKATA,  is  a  proprietary  formulation  of  high-
concentration hydrogen peroxide topical solution that has been approved by the U.S. Food and Drug Administration, or FDA,
as a prescription treatment for raised seborrheic keratosis, or SK, a common non-malignant skin tumor.  The FDA approved
our New Drug Application, or NDA, for ESKATA for the treatment of raised SKs in December 2017.  We also submitted a
Marketing Authorization Application, or MAA, for ESKATA in the European Union in July 2017.  We are also developing
another high-concentration formulation of hydrogen peroxide, A-101 45% Topical Solution, as a prescription treatment for
common warts, also known as verruca vulgaris.  Additionally, in 2015, we in-licensed exclusive, worldwide rights to certain
inhibitors of the Janus kinase, or JAK, family of enzymes, for specified dermatological conditions, including alopecia areata,
or AA, vitiligo and androgenetic alopecia, or AGA, also known as male or female pattern baldness.  In 2016, we acquired
additional  intellectual  property  rights  for  the  development  and  commercialization  of  certain  JAK  inhibitors  for  specified
dermatological  conditions.    We  intend  to  continue  to  in-license  or  acquire  additional  drug  candidates  and  technologies  to
build a fully integrated dermatology company. 

In  August  2017,  we  acquired  Confluence  Life  Sciences,  Inc.  or  Confluence.   The  acquisition  of  Confluence  adds
small molecule drug discovery and preclinical development capabilities which has allowed us to bring early-stage research
and development activities in-house that we previously outsourced to third parties.  Through the acquisition of Confluence,
we also acquired several preclinical product candidates, including inhibitors of the MK-2 signaling pathway, additional JAK
inhibitors known as “soft” JAK inhibitors, and inhibitors of interleukin-2-inducible T cell kinase, or ITK. 

Since our inception in July 2012, we have devoted substantially all of our resources to organizing and staffing our
company, business planning, raising capital, developing ESKATA for the treatment of raised SKs, building our intellectual
property portfolio, developing our supply chain and engaging in other discovery and clinical activities in dermatology. We
have  financed  our  operations  with  sales  of  our  convertible  preferred  stock,  as  well  as  net  proceeds  from  our  initial  public
offering, or IPO, in October 2015, a private placement of our common stock in June 2016, public offerings of our common
stock in November 2016 and August 2017, and an at-the-market facility with Cowen and Company LLC, or Cowen, that we
entered into in November 2016. 

Since our inception, we have incurred significant operating losses. Our net loss was $68.5 million for the year ended
December  31,  2017  and  $48.1  million  for  the  year  ended  December  31,  2016.  As  of  December  31,  2017,  we  had  an
accumulated  deficit  of  $159.4  million.    We  expect  to  incur  significant  expenses  and  operating  losses  related  to  product
manufacturing,  marketing,  sales  and  distribution  over  the  next  several  years  as  we  begin  to  commercialize  ESKATA.    In
addition, ESKATA and our other drug candidates, if approved, may not achieve commercial success.  Though ESKATA has
been approved by the FDA, we do not expect to generate substantial revenue from sales of ESKATA in the near term, if at
all.  We also expect to incur significant expenses and operating losses for the foreseeable future as we advance our other drug
candidates from discovery through preclinical development and clinical trials. In addition, if we obtain marketing approval
for  any  of  our  other  drug  candidates,  we  expect  to  incur  significant  commercialization  expenses  related  to  product
manufacturing,  marketing,  sales  and  distribution.    We  may  also  incur  expenses  in  connection  with  the  in-license  or
acquisition  of  additional  drug  candidates.  Furthermore,  we  have  incurred  and  expect  to  continue  to  incur  significant  costs
associated  with  operating  as  a  public  company,  including  legal,  accounting,  investor  relations  and  other  expenses.   As  a
result, we will need substantial additional funding to support our continuing operations and pursue our growth strategy.  Until
such time as we can generate significant revenue from product sales, if ever, we expect to finance our operations through the
sale  of  equity,  debt  financings  or  other  capital  sources,  including  potential  collaborations  with  other  companies  or  other
strategic transactions.  We may be unable to raise additional funds or enter into such other agreements

70

 
 
 
 
 
 
 
Table of Contents

or  arrangements  when  needed  on  commercially  acceptable  terms,  or  at  all.    If  we  fail  to  raise  capital  or  enter  into  such
agreements  as,  and  when,  needed,  we  may  have  to  significantly  delay,  scale  back  or  discontinue  the  development  and
commercialization of one or more of our drug candidates or delay our pursuit of potential in-licenses or acquisitions. 

License Agreement with Rigel

In  August  2015,  we  entered  into  an  exclusive,  worldwide  license  and  collaboration  agreement  with  Rigel
Pharmaceuticals,  Inc.,  or  Rigel,  for  the  development  and  commercialization  of  products  containing  two  specified  JAK
inhibitors. Under this agreement, we intend to develop these JAK inhibitors for the treatment of alopecia areata, or AA, and
potentially  for  other  dermatological  conditions.  We  paid  Rigel  an  upfront  nonrefundable  payment  of  $8.0  million  in
September 2015. In addition, we have agreed to make aggregate payments of up to $80.0 million upon the achievement of
specified pre-commercialization milestones, such as clinical trials and regulatory approvals. Further, we have agreed to pay
up to an additional $10.0 million to Rigel upon the achievement of a second set of development milestones. With respect to
any products we commercialize under the agreement, we will pay Rigel quarterly tiered royalties on our annual net sales of
each product at a high single digit percentage of annual net sales, subject to specified reductions until the date that all of the
patent  rights  for  that  product  have  expired,  as  determined  on  a  country-by-country  and  product-by-product  basis  or,  in
specified countries under specified circumstances, 10 years from the first commercial sale of such product.

The agreement terminates on the date of expiration of all royalty obligations unless earlier terminated by either party
for a material breach. We may also terminate the agreement without cause at any time upon advance written notice to Rigel.
Rigel, after consultation with us, will be responsible for maintaining and prosecuting the patent rights, and we will have final
decision-making  authority  regarding  such  patent  rights  for  a  product  in  the  United  States  and  the  European  Union.  To  the
extent  that  we  jointly  develop  intellectual  property,  we  will  confer  and  decide  which  party  will  be  responsible  for  filing,
prosecuting and maintaining those patent rights. The agreement also establishes a joint steering committee composed of an
equal number of representatives for each party, which will monitor progress in the development of products.

We accounted for the license and collaboration agreement with Rigel as an asset acquisition since the arrangement
did  not  meet  the  definition  of  a  business  pursuant  to  the  guidance  prescribed  in  Accounting  Standards  Codification  Topic
805,  Business  Combinations.  Accordingly,  we  recorded  the  $8.0  million  upfront  payment  as  research  and  development
expense in the year ended December 31, 2015. We will record contingent milestone payments and royalties as research and
development expense or cost of revenues, respectively, in the period in which such liabilities are incurred.

We concluded the licensing arrangement with Rigel did not meet the definition of a business because the transaction
principally  resulted  in  its  acquisition  of  intellectual  property.  As  part  of  the  transaction,  we  did  not  acquire  employees,
tangible assets, processes, protocols or operating systems. In addition, at the time of the acquisition, there were no activities
being  conducted  related  to  the  licensed  patents.  We  expensed  the  acquired  intellectual  property  asset  upon  acquisition
because we will use it in our research and development activities and believe it has no alternative future uses.

71

 
 
 
 
 
 
 
Table of Contents

Stock Purchase Agreement with Vixen Pharmaceuticals, Inc. and License Agreement with Columbia University

In March 2016, we entered into a stock purchase agreement with Vixen Pharmaceuticals, Inc., or Vixen, and JAK1,
LLC,  JAK2,  LLC  and  JAK3,  LLC,  all  together  with  Vixen,  the  Selling  Stockholders,  and  Shareholder  Representative
Services  LLC,  a  Colorado  limited  liability  company,  solely  in  its  capacity  as  the  representative  of  the  Selling
Stockholders.    Pursuant  to  the  Vixen  Agreement,  we  acquired  all  shares  of  Vixen’s  capital  stock  from  the  Selling
Stockholders, or the Vixen Acquisition. Following the Vixen Acquisition, Vixen became a wholly-owned subsidiary of us.
Pursuant to the Vixen Agreement, we paid $0.6 million upfront and issued an aggregate of 159,420 shares of our common
stock  to  the  Selling  Stockholders.  We  are  obligated  to  make  annual  payments  of  $0.1  million  on  March  24   of  each  year,
through March 2022, with such amounts being creditable against specified future payments that may be paid under the Vixen
Agreement. 

th

We  are  obligated  to  make  aggregate  payments  of  up  to  $18.0  million  to  the  Selling  Stockholders  upon  the
achievement of specified pre-commercialization milestones for three products in the United States, the European Union and
Japan,  and  aggregate  payments  of  up  to  $22.5  million  upon  the  achievement  of  specified  commercial  milestones.  With
respect to any commercialized products covered by the Vixen Agreement, we are obligated to pay low single-digit royalties
on net sales, subject to specified reductions, limitations and other adjustments, until the date that all of the patent rights for
that  product  have  expired,  as  determined  on  a  country-by-country  and  product-by-product  basis  or,  in  specified
circumstances, ten years from the first commercial sale of such product. If we sublicense any of Vixen’s patent rights and
know-how acquired pursuant to the Vixen Agreement, we will be obligated to pay a portion of any consideration we receive
from such sublicenses in specified circumstances. 

As a result of the transaction with Vixen, we became party to the Exclusive License Agreement, by and between
Vixen and the Trustees of Columbia University in the City of New York, or Columbia, dated as of December 31, 2015, or the
License  Agreement.  Under  the  License  Agreement,  we  are  obligated  to  pay  Columbia  an  annual  license  fee  of  $10,000
subject to specified adjustments for patent expenses incurred by Columbia and creditable against any royalties that may be
paid under the License Agreement. We are also obligated to pay up to an aggregate of $11.6 million upon the achievement of
specified commercial milestones, including specified levels of net sales of products covered by Columbia patent rights and/or
know-how, and royalties at a sub-single-digit percentage of annual net sales of products covered by Columbia patent rights
and/or know-how, subject to specified adjustments. If we sublicense any of Columbia’s patent rights and know-how acquired
pursuant to the License Agreement, we will be obligated to pay Columbia a portion of any consideration received from such
sublicenses in specified circumstances.  The royalties, as determined on a country-by-country and product-by-product basis,
are payable until the date that all of the patent rights for that product have expired, the expiration of any market exclusivity
period  granted  by  a  regulatory  body  or,  in  specified  circumstances,  ten  years  from  the  first  commercial  sale  of  such
product.    The  License  Agreement  terminates  on  the  date  of  expiration  of  all  royalty  obligations  thereunder  unless  earlier
terminated  by  either  party  for  a  material  breach,  subject  to  a  specified  cure  period.  We  may  also  terminate  the  License
Agreement without cause at any time upon advance written notice to Columbia. 

We accounted for the transaction with Vixen as an asset acquisition as the arrangement did not meet the definition of
a business pursuant to the guidance prescribed in Accounting Standards Codification Topic 805, Business Combinations. We
concluded the transaction with Vixen did not meet the definition of a business because the transaction principally resulted in
the acquisition of the License Agreement. We did not acquire tangible assets, processes, protocols or operating systems. In
addition, at the time of the transaction, there were no activities being conducted related to the licensed patents. We expensed
the  acquired  intellectual  property  as  of  the  acquisition  date  on  the  basis  that  the  cost  of  intangible  assets  purchased  from
others for use in research and development activities, and that have no alternative future uses, are expensed at the time the
costs are incurred.  Accordingly, we recorded the $0.6 million upfront payment, the fair value of the shares of common stock
issued of $2.4 million, and the present value of the six non-contingent annual payments as research and development expense
in  the  year  ended  December  31,  2016.    Additionally,  we  will  record  as  expense  any  contingent  milestone  payments  or
royalties in the period in which such liabilities are incurred. 

72

 
 
 
 
 
 
Table of Contents

Agreement and Plan of Merger with Confluence

In August 2017, we entered into an Agreement and Plan of Merger with Confluence, Aclaris Life Sciences, Inc., our
wholly-owned subsidiary, or Merger Sub, and Fortis Advisors LLC, as representative of the holders of Confluence equity, or
the Agreement and Plan of Merger.  Pursuant to the terms of the Agreement and Plan of Merger, the Merger Sub merged with
and into Confluence, with Confluence surviving as our wholly-owned subsidiary.  Pursuant to the terms of the Agreement
and  Plan  of  Merger,  we  paid  $10.3  million  in  cash  and  issued  349,527  shares  of  our  common  stock  with  a  value  of  $9.7
million. 

We  also  agreed  to  pay  the  Confluence  equity  holders  aggregate  contingent  consideration  of  up  to  $80.0  million,
based upon the achievement of certain development, regulatory and commercial milestones set forth in the Agreement and
Plan  of  Merger.    Of  the  contingent  consideration,  $2.5  million  may  be  paid  in  shares  of  our  common  stock  upon  the
achievement  of  a  specified  development  milestone.    In  addition,  we  have  agreed  to  pay  the  Confluence  equity  holders
specified  future  royalty  payments  calculated  as  a  low  single-digit  percentage  of  annual  net  sales,  subject  to  specified
reductions,  limitations  and  other  adjustments,  until  the  date  that  all  of  the  patent  rights  for  that  product  have  expired,  as
determined  on  a  country-by-country  and  product-by-product  basis  or,  in  specified  circumstances,  ten  years  from  the  first
commercial sale of such product.  In addition, if we sell, license or transfer any of the intellectual property acquired from
Confluence pursuant to the Agreement and Plan of Merger to a third party, we will be obligated to pay the Confluence equity
holders a portion of any incremental consideration (in excess of the development and milestone payments described above)
that we receive from such sale, license or transfer in specified circumstances. 

Other Third-Party Agreements

Under  an  assignment  agreement,  pursuant  to  which  we  acquired  intellectual  property,  we  have  agreed  to  pay
royalties  on  sales  of  ESKATA,  or  other  related  products,  at  rates  ranging  in  low  single-digit  percentages  of  net  sales,  as
defined in the agreement. Under this assignment agreement, we have paid aggregate milestone payments of $0.2 million and
there are no remaining milestone payment obligations. 

In connection with the assignment agreement, we also entered into a finder’s services agreement under which we
have  paid  aggregate  milestone  payments  of  $1.5  million  upon  the  achievement  of  specified  pre-commercialization
milestones,  such  as  clinical  trials  and  regulatory  approvals,  as  described  in  the  agreement.  We  have  also  agreed  to  make
aggregate  payments  of  up  to  $4.5  million  upon  the  achievement  of  specified  commercial  milestones.  In  addition,  we  have
agreed to pay royalties on sales of ESKATA, or other related products, at a low single-digit percentage of net sales, as defined
in the agreement. 

Components of Our Results of Operations

Revenue

We  earn  revenue  from  the  provision  of  laboratory  services  to  clients  through  Confluence,  our  wholly-owned
subsidiary.  Laboratory service revenue is generally evidenced by contracts with clients which are on an agreed upon fixed-
price, fee-for-service basis and are generally billed on a monthly basis in arrears for services rendered.  Revenue related to
these  contracts  is  generally  recognized  as  the  laboratory  services  are  performed,  based  upon  the  rates  specified  in  the
contracts. 

We  also  receive  revenue  from  grants  under  the  Small  Business  Innovation  Research  program  of  the  National
Institutes of Health, or NIH.  Through our Confluence subsidiary, we currently have two active grants from NIH which are
related to early-stage research.  We recognize revenue related to these grants as amounts become reimbursable under each
grant, which is generally when research is performed, and the related costs are incurred. 

Our  contract  research  segment  has  earned  all  of  our  revenue  to  date.    We  have  never  received  revenue  in  our

dermatology therapeutics segment.

73

 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Cost of Revenue

Cost  of  revenue  consists  of  costs  incurred  in  connection  with  the  provision  of  laboratory  services  to  our  clients

through Confluence.  Cost of revenue primarily includes:

·
·
·
·
·

employee-related expenses, which include salaries, benefits and stock-based compensation;
outsourced professional scientific services;
depreciation of laboratory equipment;
facility-related costs; and
laboratory materials and supplies used to support the services provided.

Research and Development Expenses

Research and development expenses consist of expenses incurred in connection with the discovery and development

of our drug candidates. We expense research and development costs as incurred. These expenses include:

·

expenses incurred under agreements with contract research organizations, or CROs, as well as investigative
sites and consultants that conduct our clinical trials and preclinical studies;

· manufacturing scale-up expenses and the cost of acquiring and manufacturing preclinical and clinical trial

materials and commercial materials, including manufacturing validation batches;
outsourced professional scientific development services;
employee-related expenses, which include salaries, benefits and stock-based compensation;
depreciation of manufacturing equipment;
payments made under agreements with third parties under which we have acquired or licensed intellectual
property;
expenses relating to regulatory activities, including filing fees paid to regulatory agencies; and
laboratory materials and supplies used to support our research activities.

·
·
·
·

·
·

We expense research and development costs as incurred.  Our direct research and development expenses primarily
consist of external costs including fees paid to CROs, consultants, investigator sites, regulatory agencies and third parties that
manufacture our preclinical and clinical trial materials, and are tracked on a program-by-program basis. We do not allocate
personnel  costs,  facilities  or  other  indirect  expenses,  which  are  included  within  “Personnel  and  other  costs”  in  the  table
below, to specific research and development programs. 

The following table summarizes our research and development expenses for the periods presented:

ESKATA and A-101 45% Topical Solution
JAK inhibitors
Vixen acquisition
Rigel up-front payment
Other research expenses
Total project-related expenses
Personnel and other costs
Stock-based compensation

Total research and development expenses

Year Ended
December 31, 
2016

2017

    $

10,712     $
11,789  
 —  
 —  
1,253  
23,754  
  10,565  
  5,471  

15,357    $
7,314  
3,435  
 —  
190  
26,296  
4,889  
  2,291  

  $

39,790   $

33,476   $

2015

4,578
29
 —
8,253
201
13,061
2,021
257
15,339

Research and development activities are central to our business model.  Drug candidates in later stages of clinical
development generally have higher development costs than those in earlier stages of clinical development, primarily due to
the  increased  size  and  duration  of  later-stage  clinical  trials.  We  expect  our  research  and  development  expenses  to  increase
significantly  over  the  next  several  years  as  we  increase  personnel  costs,  including  stock-based  compensation,  continue  to
conduct clinical trials of A-101 45% Topical Solution for the treatment of common warts, and conduct preclinical and clinical
development activities and prepare regulatory filings for our other drug candidates.

74

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

The successful development of our drug candidates is highly uncertain. At this time, we cannot reasonably estimate
or know the nature, timing and costs of the efforts that will be necessary to complete the remainder of the development of, or
when,  if  ever,  material  net  cash  inflows  may  commence  from  any  of  our  drug  candidates.  This  uncertainty  is  due  to  the
numerous risks and uncertainties associated with the duration and cost of clinical trials, which vary significantly over the life
of a project as a result of many factors, including:

·
·
·
·
·
·

the number of clinical sites included in the trials;
the length of time required to enroll suitable patients;
the number of patients that ultimately participate in the trials;
the number of doses patients receive;
the duration of patient follow-up; and
the results of our clinical trials.

Our expenditures are subject to additional uncertainties, including the terms and timing of marketing approvals, and
the expense of filing, prosecuting, defending and enforcing any patent claims or other intellectual property rights. We may
never succeed in achieving marketing approval for any of our drug candidates. We may obtain unexpected results from our
clinical  trials.  We  may  elect  to  discontinue,  delay  or  modify  clinical  trials  of  some  drug  candidates  or  focus  on  others.  A
change in the outcome of any of these variables with respect to the development of a drug candidate could mean a significant
change  in  the  costs  and  timing  associated  with  the  development  of  that  drug  candidate.  For  example,  if  the  FDA  or  other
regulatory  authorities  were  to  require  us  to  conduct  clinical  trials  beyond  those  that  we  currently  anticipate,  or  if  we
experience significant delays in enrollment in any of our clinical trials, we could be required to expend significant additional
financial resources and time on the completion of clinical development. Drug commercialization will take several years and
millions of dollars in development costs.

General and Administrative Expenses

General  and  administrative  expenses  consist  principally  of  salaries  and  related  costs  for  personnel  in  executive,
administrative,  finance  and  legal  functions,  including  stock-based  compensation,  travel  expenses  and  recruiting  expenses.
Other general and administrative expenses include facility-related costs, patent filing and prosecution costs, professional fees
for marketing, legal, auditing and tax services, insurance costs, as well as payments made under our related party services
agreement and milestone payments under our finder’s services agreement. 

We  anticipate  that  our  general  and  administrative  expenses  will  increase  as  a  result  of  increased  personnel  costs,
including stock-based compensation, expanded infrastructure and higher consulting, legal and tax-related services associated
with maintaining compliance with Nasdaq and SEC requirements, accounting and investor relations costs, and director and
officer  insurance  premiums  associated  with  being  a  public  company.  Additionally,  we  anticipate  a  significant  increase  in
payroll, marketing, sales and other expenses as a result of our preparation for commercial operations related to the launch of
ESKATA. 

Interest Income

Interest income consists of interest earned on our cash, cash equivalents and marketable securities.

75

 
 
 
 
 
 
 
 
 
Table of Contents

Critical Accounting Policies and Significant Judgments and Estimates

Our consolidated financial statements are prepared in accordance with generally accepted accounting principles in
the  United  States.  The  preparation  of  our  consolidated  financial  statements  and  related  disclosures  requires  us  to  make
estimates  and  judgments  that  affect  the  reported  amounts  of  assets  and  liabilities,  disclosure  of  contingent  assets  and
liabilities at the date of the financial statements, and the reported amounts of expenses during the reported period. We base
our estimates on historical experience, known trends and events and various other factors that we believe to be reasonable
under the circumstances, the results of which form the basis for making judgments about the carrying values of assets and
liabilities that are not readily apparent from other sources. We evaluate our estimates and assumptions on an ongoing basis.
Our actual results may differ from these estimates under different assumptions and conditions.

While  our  significant  accounting  policies  are  described  in  more  detail  in  the  notes  to  our  consolidated  financial
statements appearing elsewhere in this Annual Report on Form 10-K, we believe that the following accounting policies are
those most critical to the judgments and estimates used in the preparation of our consolidated financial statements.

Revenue Recognition

We recognize revenue when the earnings process is complete, which under SEC Staff Accounting Bulletin No. 104,
Topic No. 13, “Revenue Recognition,” is when revenue is realized or realizable and earned, there is persuasive evidence a
revenue  arrangement  exists,  delivery  of  goods  or  services  has  occurred,  the  sales  price  is  fixed  or  determinable,  and
collectability is reasonably assured. 

We  earn  revenue  from  the  provision  of  laboratory  services  to  clients  through  Confluence,  our  wholly-owned
subsidiary.  Laboratory service revenue is generally evidenced by contracts with clients which are on an agreed upon fixed-
price, fee-for-service basis and are generally billed on a monthly basis in arrears for services rendered.  Revenue related to
these  contracts  is  generally  recognized  as  the  laboratory  services  are  performed,  based  upon  the  rates  specified  in  the
contracts. 

We also receive revenue from grants under the Small Business Innovation Research program of the NIH.  Through
our  Confluence  subsidiary,  we  currently  have  two  active  grants  from  NIH  which  are  related  to  early-stage  research.    We
recognize  revenue  related  to  these  grants  as  amounts  become  reimbursable  under  each  grant,  which  is  generally  when
research is performed, and the related costs are incurred. 

Research and Development Expenses

As part of the process of preparing our consolidated financial statements, we are required to estimate our research
and  development  expenses.  This  process  involves  reviewing  open  contracts  and  purchase  orders,  communicating  with  our
applicable  personnel  to  identify  services  that  have  been  performed  on  our  behalf  and  estimating  the  level  of  service
performed and the associated cost incurred for the service when we have not yet been invoiced or otherwise notified of actual
costs. The majority of our preclinical development activities and clinical trials are performed pursuant to quotes and contracts
with  multiple  vendors,  including  research  institutions  and  CROs,  that  conduct  and  manage  such  activities  on  our
behalf.    Many  of  the  contracts  with  our  vendors  require  advance  payments;  while  others  invoice  us  in  arrears  for  services
performed, or on a pre-determined schedule, or upon the successful enrollment of patients, or when contractual milestones
are met. We record expenses for preclinical development activities and clinical trials based upon estimates of the total cost of
the services to be provided by the vendor and the time period over which the vendor is to perform those services.  Estimates
of research and development expenses included in our consolidated financial statements are based on facts and circumstances
known to us at that time. The financial terms of our agreements are subject to negotiation, vary from contract to contract, and
may  result  in  uneven  payment  flows.  There  may  be  times  when  payments  made  to  a  vendor  exceed  the  level  of  services
provided,  resulting  in  a  prepayment  for  work  to  be  performed.    We  may  confirm  the  accuracy  of  our  estimates  with  the
service  providers,  or  make  adjustments  to  our  estimates  based  upon  new  or  updated  facts  and  circumstances,  as
necessary.    For  example,  if  the  timing  and/or  cost  of  services  to  be  performed  is  materially  different  from  our  previous
estimates, we would make a prospective adjustment for the change in our estimates in the period in which we become aware
of  the  new  cost  and/or  timing.  Although  we  do  not  expect  our  estimates  to  be  materially  different  from  actual  amounts
incurred, our understanding of the status and timing of services performed relative to the actual status and timing of services
performed may vary and may result in reporting amounts that are too high or too low in any

76

 
 
 
 
 
 
 
 
 
Table of Contents

particular  period.    To  date,  we  have  not  made  any  material  adjustments  to  our  estimates  of  research  and  development
expenses.

Stock-Based Compensation

We measure the compensation expense of stock-based awards granted to employees and directors using the grant
date  fair  value  of  the  award.    We  have  issued  stock  options  and  restricted  stock  unit,  or  RSU,  awards  with  service-based
vesting conditions, as well as with performance-based vesting conditions.  We have not issued awards that include market-
based conditions.  For service-based awards we recognize stock-based compensation expense on a straight-line basis over the
requisite service period.  For performance-based awards we recognize stock-based compensation expense on a straight-line
basis  over  the  requisite  service  period  beginning  in  the  period  that  it  becomes  probable  the  performance  conditions  will
occur.  At each balance sheet date, we evaluate whether any performance conditions related to a performance-based award
have changed.  The effect of any change in performance conditions would be recognized as a cumulative catch-up adjustment
in the period such change occurs, and any remaining unrecognized compensation expense would be recognized on a straight-
line basis over the remaining requisite service period.  The impact of forfeitures is recognized in the period in which they
occur. 

We initially measure the compensation expense of stock-based awards granted to consultants using the grant date
fair  value  of  the  award.    We  recognize  compensation  expense  over  the  period  during  which  services  are  rendered  by  the
consultant.  At the end of each financial reporting period prior to the completion of services being rendered, we re-measure
the compensation expense related to these awards using the then current fair value of our common stock for RSUs, or based
upon updated assumptions in the Black-Scholes option-pricing model for stock option awards. 

We estimate the fair value of each stock option grant using the Black-Scholes option-pricing model.  We estimate
expected  volatility  based  on  historical  volatility  of  a  set  of  peer  companies,  which  are  publicly  traded,  and  we  expect  to
continue to do so until we have adequate historical data regarding the volatility of our own publicly-traded stock price.  The
expected  term  of  our  stock  options  has  been  determined  using  the  “simplified”  method  for  awards  that  qualify  as  “plain
vanilla”  options.  The  expected  term  of  stock  options  we  granted  to  non-employees  is  equal  to  the  contractual  term  of  the
option award.  The risk-free interest rate is determined by reference to the U.S. Treasury yield curve in effect at the time of
grant of the award for time periods approximately equal to the expected term of the award.  We use an expected dividend
yield  of  zero  because  we  have  not  paid  cash  dividends  to  date,  and  have  no  intention  of  paying  cash  dividends  in  the
future.  Prior to our IPO, we valued our common stock using a hybrid method which used market approaches to estimate our
enterprise value.  The hybrid method used was a probability-weighted expected return method which was a scenario-based
methodology  that  estimated  the  fair  value  of  our  common  stock  based  upon  an  analysis  of  future  values  for  the  company
assuming various outcomes.  The hybrid method used calculated equity values using an option pricing model in one or more
of scenarios, and also considered the rights of each class of stock.

The fair value of each restricted RSU is measured using the closing price of our common stock on the date of grant.

Income Taxes

Since our inception in 2012, we have not recorded U.S. federal or state income tax benefits for the net operating
losses  we  have  incurred  in  each  year  or  for  our  earned  research  and  development  tax  credits,  due  to  our  uncertainty  of
realizing a benefit from those items. As of December 31, 2017, we had federal and state net operating loss carryforwards of
$77.2 million and $119.3 million, respectively, which begin to expire in 2032.  As of December 31, 2017, we also had federal
research  and  development  tax  credit  carryforwards  of  $2.2  million  which  begin  to  expire  in  2032,  and  state  research  and
development tax credit carryforwards of $0.1 million which begin to expire in 2022. 

77

 
 
 
 
 
 
 
 
Table of Contents

Intangible Assets

Our  intangible  assets  include  both  finite-lived  and  indefinite-lived  assets.    Finite-lived  intangible  assets  are
amortized over their estimated useful life based on the pattern over which the intangible assets are consumed or otherwise
used  up.  If  that  pattern  cannot  be  reliably  determined,  the  straight-line  method  of  amortization  is  used.    Our  finite-lived
intangible assets consist of a research technology platform acquired through the acquisition of Confluence.  Indefinite-lived
intangible  assets  consist  of  an  in-process  research  and  development,  or  IPR&D,  drug  candidate  acquired  through  the
acquisition  of  Confluence.    IPR&D  assets  are  considered  indefinite-lived  until  the  completion  or  abandonment  of  the
associated research and development efforts.  The cost of IPR&D assets is either amortized over their estimated useful life
beginning  when  the  underlying  drug  candidate  is  approved  and  launched  commercially,  or  expensed  immediately  if
development of the drug candidate is abandoned. 

Finite-lived intangible assets are tested for impairment when events or changes in circumstances indicate that the
carrying  value  of  the  asset  may  not  be  recoverable.    Indefinite-lived  intangible  assets  are  tested  for  impairment  at  least
annually,  which  we  perform  during  the  fourth  quarter,  or  when  indicators  of  an  impairment  are  present.   We  recognize  an
impairment  loss  when  and  to  the  extent  that  the  estimated  fair  value  of  an  indefinite-lived  intangible  asset  is  less  than  its
carrying value. 

Goodwill

Goodwill is not amortized, but rather, is subject to testing for impairment at least annually, which we perform during
the  fourth  quarter,  or  when  indicators  of  an  impairment  are  present.    We  consider  each  of  our  operating  segments,
dermatology  therapeutics  and  contract  research,  to  be  a  reporting  unit  since  this  is  the  lowest  level  for  which  discrete
financial information is available.  We have attributed the full amount of the goodwill in connection with the acquisition of
Confluence, or $18.5 million, to our dermatology therapeutics segment.  We perform an impairment test annually which is a
qualitative  assessment  based  upon  current  facts  and  circumstances  related  to  operations  of  the  dermatology  therapeutics
segment.  If our qualitative assessment indicates an impairment may be present, we would perform the required quantitative
analysis and an impairment charge would be recognized to the extent that the estimated fair value of the reporting unit is less
than  its  carrying  amount.    However,  any  loss  recognized  would  not  exceed  the  total  amount  of  goodwill  allocated  to  that
reporting unit. 

Contingent Consideration

We initially recorded the contingent consideration related to future potential payments based upon the achievement
of certain development, regulatory and commercial milestones, resulting from the acquisition of Confluence, at its estimated
fair value on the date of acquisition.  Changes in fair value reflect new information about the likelihood of the payment of the
contingent  consideration  and  the  passage  of  time.    For  example,  if  the  timing  of  the  development  of  an  acquired  drug
candidate, or the size of potential commercial opportunities related to an acquired drug, differ from our assumptions, then the
fair  value  of  contingent  consideration  would  be  adjusted  accordingly.    Future  changes  in  the  fair  value  of  the  contingent
consideration, if any, will be recorded as income or expense in our consolidated statement of operations. 

78

 
 
 
 
 
 
 
 
Table of Contents

Results of Operations

Comparison of Years Ended December 31, 2017 and 2016

Revenue
Cost of revenue
Gross profit
Operating expenses:

Research and development
General and administrative
Total operating expenses

Loss from operations
Other income, net
Loss before income taxes
Provision for income taxes
Net loss

Revenue

Year Ended December 31, 

2017

2016
(In thousands)

Change

  $

  $

1,683   $
1,207  
476  

39,790  
33,109  
72,899  
(72,423) 
2,070  
(70,353) 
(1,830) 
(68,523)  $

 —   $
 —  
 —  

1,683  
1,207  
476  

33,476  
15,091  
48,567  
(48,567) 
488  
(48,079) 
 —  
(48,079)  $

6,314  
18,018  
24,332  
(23,856) 
1,582  
(22,274) 
(1,830) 
(20,444) 

Revenue was $1.7 million for the year ended December 31, 2017, and was comprised primarily of fees earned from
the provision of laboratory services to clients through Confluence, which we acquired in August 2017.  We did not generate
any revenue in the year ended December 31, 2016. 

Cost of Revenue

Cost  of  revenue  was  $1.2  million  for  the  year  ended  December  31,  2017,  and  was  comprised  entirely  of  costs
incurred to provide laboratory services to our clients through Confluence, which we acquired in August 2017.  We did not
incur any cost of revenue in the year ended December 31, 2016. 

Research and Development Expenses

Research and development expenses were $39.8 million for the year ended December 31, 2017, compared to $33.5
million  for  the  year  ended  December  31,  2016.  The  increase  of  $6.3  million  was  primarily  driven  by  an  increase  of  $3.4
million  of  expenses  related  to  our  Phase  2  clinical  trials  of  A-101  45%  Topical  Solution,  an  increase  of  $4.5  million  in
preclinical  and  clinical  trial  development  expenses  related  to  our  JAK  inhibitor  technology,  an  increase  of  $2.4  million  in
payroll-related expenses due to higher headcount, an increase of $3.2 million in stock-based compensation expense, and a
$2.9 million increase in expenses related to medical affairs activities.  We also incurred $0.7 million of expenses related to
drug discovery research performed by Confluence in the year ended December 31, 2017.  The increases noted above were
partially offset by a $7.7 million decrease in costs associated with the development of ESKATA as a result of the completion
of our Phase 3 clinical trials in November 2016, and $3.4 million in expenses associated with the acquisition of Vixen in the
year ended December 31, 2016, for which there was no similar transaction in 2017. 

79

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

General and Administrative Expenses

General and administrative expenses were $33.1 million for the year ended December 31, 2017, compared to $15.1
million for the year ended December 31, 2016. The increase of $18.0 million was primarily attributable to increases of $5.2
million  in  market  research  expenses  and  $0.9  million  in  sales  operations  expenses,  both  related  to  pre-commercial  launch
activities for ESKATA, an increase of $3.0 million in payroll-related expenses due to increased headcount, $6.3 million in
higher stock-based compensation expense, and $1.3 million in higher facilities-related costs including a one-time charge to
rent  expense  of  $0.5  million  in  connection  with  the  early  termination  of  our  sublease  with  NST  Consulting,  LLC.    In
addition,  milestone  payments  pursuant  to  the  finder’s  services  agreement  related  to  ESKATA  increased  by  $0.7  million  in
2017  compared  to  2016.    We  also  incurred  $0.6  million  of  professional  fees  in  conjunction  with  our  acquisition  of
Confluence, for which there were no similar amounts in 2016. 

Other Income, net

The  $1.6  million  increase  in  other  income,  net  was  primarily  due  to  higher  invested  balances  of  marketable

securities as a result of funds received from our financing transactions in 2016 and 2017. 

Provision for Income Taxes

Provision  for  income  taxes  was  a  net  benefit  of  $1.8  million  for  the  year  ended  December  31,  2017  and  was
comprised primarily of the revaluation of our deferred tax assets, net resulting from the Tax Cuts and Jobs Act which was
enacted on December 22, 2017. 

Comparison of Years Ended December 31, 2016 and 2015

Revenue
Cost of revenue
Gross profit
Operating expenses:

Research and development
General and administrative
Total operating expenses

Loss from operations
Other income, net
Net loss

  $

Year Ended December 31, 

2016

2015
(In thousands)

Change

 —   $
 —  
 —  

 —   $
 —  
 —  

 —  
 —  
 —  

33,476  
15,091  
48,567  
(48,567) 
488  
(48,079)  $

15,339  
5,328  
20,667  
(20,667) 
104  
(20,563)  $

18,137  
9,763  
27,900  
(27,900) 
384  
(27,516) 

  $

Research and Development Expenses

Research and development expenses were $33.5 million for the year ended December 31, 2016, compared to $15.3
million for the year ended December 31, 2015. The increase of $18.1 million was primarily attributable to a $10.2 million
increase in costs associated with the development of ESKATA for the treatment of raised SKs, an increase of $7.3 million in
preclinical  development  expenses  related  to  our  JAK  inhibitor  technology,  a  $0.5  million  increase  in  costs  related  to  the
development  of  A-101  45%  Topical  Solution  for  the  treatment  of  common  warts,  an  increase  of  $2.2  million  in  payroll-
related  expenses  due  to  increased  headcount,  and  an  increase  of  $2.0  million  in  stock-based  compensation  expense.    The
increases noted above were partially offset by a decrease of $4.6 million in licensing expenses as we incurred $3.4 million of
expenses associated with the Vixen acquisition in the year ended December 31, 2016, compared to $8.0 million of expense
resulting  from  the  upfront  payment  made  to  Rigel  for  the  ATI-501  and  ATI-502  JAK  inhibitor  drug  candidates  during  the
year ended December 31, 2015. 

80

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

General and Administrative Expenses

General and administrative expenses were $15.1 million for the year ended December 31, 2016, compared to $5.3
million for the year ended December 31, 2015. The increase of $9.8 million was primarily attributable to increases of $2.2
million  in  payroll-related  expenses  due  to  increased  headcount,  $3.2  million  in  stock-based  compensation  expense,  $0.4
million in legal and patent expenses related to the Vixen acquisition, $1.5 million in professional fees associated with being a
public company, and $1.5 million in market research expenses related to pre-commercial activities for ESKATA, as well as a
$0.3 million one-time milestone payment made during the year ended December 31, 2016 pursuant to the finder’s services
agreement related to A-101. 

Other Income, net

The increase in other income, net was primarily due to interest income received from higher invested balances of
marketable securities as a result of funds received from our IPO in October 2015, our private placement in June 2016 and our
follow-on public offering in November 2016. 

Liquidity and Capital Resources

Since  our  inception,  we  have  incurred  net  losses  and  negative  cash  flows  from  our  operations.    Prior  to  our
acquisition  of  Confluence  in  August  2017,  we  did  not  generate  any  revenue.    We  have  financed  our  operations  since
inception through sales of our convertible preferred stock, as well as net proceeds from our IPO in October 2015, our private
placement in June 2016, our public offerings in November 2016 and August 2017 and an at-the-market facility with Cowen. 

As  of  December  31,  2017,  we  had  cash,  cash  equivalents  and  marketable  securities  of  $208.9  million.  Cash  in
excess  of  immediate  requirements  is  invested  in  accordance  with  our  investment  policy,  primarily  with  a  view  towards
liquidity and capital preservation. 

We  currently  have  no  ongoing  material  financing  commitments,  such  as  lines  of  credit  or  guarantees  that  are
expected  to  affect  our  liquidity  over  the  next  five  years,  other  than  our  lease  and  sublease  obligations  and  contingent
obligations  under  intellectual  property  licensing  arrangements,  as  described  below  under  “Contractual  Obligations  and
Commitments.”

Initial Public Offering

In October 2015, we closed our IPO in which we sold 5,750,000 shares of common stock at a price to the public of
$11.00 per share, for aggregate gross proceeds of $63.3 million. We paid underwriting discounts and commissions of $4.4
million, and we also incurred expenses of $2.3 million in connection with the IPO. As a result, the net offering proceeds to
us, after deducting underwriting discounts and commissions and offering expenses, were $56.6 million. 

Private Placement

In June 2016, we closed a private placement in which we sold an aggregate of 1,081,082 shares of common stock at
a  price  of  $18.50  per  share,  for  gross  proceeds  of  $20.0  million.    We  incurred  placement  agent  fees  of  $1.3  million,  and
expenses of $0.2 million in connection with the private placement.  As a result, the net offering proceeds received by us, after
deducting placement agent fees and transaction expenses, were $18.5 million. 

November 2016 Public Offering

In November 2016, we closed our follow-on public offering in which we sold 4,600,000 shares of common stock at
a price to the public of $22.75 per share, for aggregate gross proceeds of $104.7 million. We paid underwriting discounts and
commissions of $6.3 million, and we also incurred expenses of $0.2 million in connection with the offering.  As a result, the
net offering proceeds received by us, after deducting underwriting discounts, commissions and offering expenses, were $98.2
million. 

81

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

At-The-Market Facility

In April 2017, we sold 635,000 shares of our common stock at a weighted average price per share of $31.50, for
aggregate gross proceeds of approximately $20.0 million.  We paid underwriting discounts and commissions of $0.6 million,
and we also incurred expenses of $0.1 million in connection with this sale.  The shares were sold through Cowen pursuant to
a sales agreement with them dated November 2, 2016.  As of the date of this report, we may offer and sell additional shares
of  our  common  stock  having  an  aggregate  offering  price  of  up  to  approximately  $55.0  million  from  time  to  time  through
Cowen pursuant to the sales agreement.

August 2017 Public Offering

In August 2017, we closed our follow-on public offering in which we sold 3,747,602 shares of common stock at a
price to the public of $23.02 per share, for aggregate gross proceeds of $86.3 million. We paid underwriting discounts and
commissions of $5.2 million, and we also incurred expenses of $0.2 million in connection with the offering.  As a result, the
net offering proceeds received by us, after deducting underwriting discounts, commissions and offering expenses, were $80.9
million. 

Cash Flows

The following table summarizes our cash flows for each of the periods presented:

Net cash used in operating activities
Net cash used in by investing activities
Net cash provided by financing activities
Net (decrease) increase in cash and cash equivalents

Operating Activities

2017

Year Ended December 31, 
2016
(In thousands)

2015

  $

(54,663)  $
(55,692) 
100,386  

  $

(9,969)  $

(34,603)  $
(61,903) 
116,826  
20,320   $

(20,369)
(76,951)
96,414
(906)

During the year ended December 31, 2017, operating activities used $54.7 million of cash, primarily resulting from
our net loss of $68.5 million partially offset by changes in our operating assets and liabilities of $0.9 million and non-cash
adjustments  of  $13.0  million.    Net  cash  used  by  changes  in  our  operating  assets  and  liabilities  during  the  year  ended
December 31, 2017 consisted of a $4.3 million increase in prepaid expenses and other current assets offset by a $5.2 million
increase in accounts payable and accrued expenses.  The increase in prepaid expenses and other current assets was primarily
due to a $2.0 million PDUFA fee paid to the FDA in conjunction with the filing of the NDA for ESKATA, as well as deposits
made for clinical supplies and development activities that are expected to be incurred during the first quarter of 2018.  The
increase  in  accounts  payable  and  accrued  expenses  was  primarily  due  to  an  increase  of  $1.2  million  in  accrued  bonuses
payable due to increased headcount, $0.6 million payable to NST Consulting LLC in connection with the early termination of
our sublease with them, as well as expenses incurred, but not yet paid, in connection with our Phase 2 clinical trials for A-101
45%  Topical  Solution,  ATI-501  and  ATI-502.    Non-cash  expenses  of  $13.0  million  included  stock-based  compensation
expense of $14.4 million, and $0.4 million of depreciation and amortization, partially offset by an adjustment to our deferred
tax liability, net of $1.8 million which was the result of the Tax Cuts and Jobs Act enacted on December 22, 2017. 

82

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

During the year ended December 31, 2016, our operating activities used $34.6 million of cash, primarily resulting
from our net loss of $48.1 million partially offset by cash provided by changes in our operating assets and liabilities of $4.5
million and by non-cash expenses of $9.0 million. Net cash provided by changes in our operating assets and liabilities during
the year ended December 31, 2016 consisted primarily of a $4.3 million increase in accounts payable and accrued expenses.
The  increase  in  accounts  payable  and  accrued  expenses  was  primarily  due  to  expenses  incurred,  but  not  yet  paid,  in
connection  with  preclinical  development  expenses  related  to  our  JAK  inhibitor  technology  and  the  timing  of  vendor
invoicing and payments.  In addition, we had $1.7 million of employee-related accruals as of December 31, 2016, compared
to $0 as of December 31, 2015.  The increase in employee-related accruals resulted from bonuses earned in 2016 which were
paid after December 31, 2016, while all bonuses earned in 2015 were paid before December 31, 2015.  Non-cash expenses of
$9.0 million primarily included $6.1 million related to share-based compensation expense, and $2.8 million resulting from
the Vixen acquisition. 

During the year ended December 31, 2015, our operating activities used $20.4 million of cash, primarily resulting
from our net loss of $20.6 million and net cash used in our operating assets and liabilities of $1.1 million, partially offset by
non-cash increases of $0.9 million in stock-based compensation expense and a $0.3 million write-down of equipment held for
sale to net realizable value.  Net cash used in changes in our operating assets and liabilities during the year ended December
31,  2015  consisted  primarily  of  a  $1.3  million  increase  in  prepaid  expenses  and  other  current  assets  and  a  $0.4  million
decrease  in  accounts  payable,  partially  offset  by  a  $0.6  million  increase  in  accrued  expenses.  The  increase  in  accrued
expenses  was  primarily  due  to  the  timing  of  invoices  for  licensing  fees  and  legal  expenses  relating  to  our  wholly-owned
subsidiary.  The increase in prepaid expenses and other current assets was primarily due to prepayments for clinical trials and
prepayments of insurance policies.

Investing Activities

During  the  year  ended  December  31,  2017,  we  used  cash  of  $55.7  million  in  investing  activities,  consisting  of
purchases  of  marketable  securities  of  $197.3  million,  $9.6  million  for  the  acquisition  of  Confluence  and  purchases  of
property  and  equipment  of  $1.2  million,  partially  offset  by  proceeds  from  sales  and  maturities  of  marketable  securities  of
$152.5 million.

During  the  year  ended  December  31,  2016,  we  used  cash  of  $61.9  million  in  investing  activities,  consisting  of
purchases of marketable securities of $148.8 million and purchases of equipment of $0.2 million, partially offset by proceeds
from sales and maturities of marketable securities of $87.1 million.

During  the  year  ended  December  31,  2015,  we  used  cash  of  $77.0  million  in  investing  activities,  consisting  of
purchases of marketable securities of $82.5 million and purchases of equipment of $0.5 million, partially offset by proceeds
from sales and maturities of marketable securities of $6.1 million.

Financing Activities

During the year ended December 31, 2017, net cash provided by financing activities was $100.4 million consisting
primarily of $19.3 million of net proceeds received from the sale of common stock under our sales agreement with Cowen in
April  2017,  $80.9  million  of  net  proceeds  received  from  our  public  offering  of  common  stock  in  August  2017,  and  $0.2
million  of  cash  received  from  the  exercise  of  employee  stock  options,  partially  offset  by  $0.1  million  of  capital  lease
payments for laboratory equipment. 

During the year ended December 31, 2016, net cash provided by financing activities was $116.8 million, consisting
primarily  of  $18.5  million  of  net  proceeds  received  from  the  private  placement  of  our  common  stock  in  June  2016,  net
proceeds of $98.2 million received from our follow-on public offering of common stock in November 2016, as well as $0.1
million of cash received from the exercise of employee stock options.    

During the year ended December 31, 2015, net cash provided by financing activities was $96.4 million, consisting
of $39.8 million of net proceeds received from our issuance of convertible preferred stock in August 2015 and net proceeds
of $56.6 million received from our IPO in October 2015. 

83

 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Funding Requirements

We  plan  to  focus  in  the  near  term  on  the  commercialization  of  ESKATA  for  the  treatment  of  raised  SKs  and  the
clinical  development  of  our  drug  candidates.    We  anticipate  we  will  incur  net  losses  for  the  next  several  years  as  we
commercialize  ESKATA,  continue  the  clinical  development  of  A-101  45%  Topical  Solution  for  the  treatment  of  common
warts  and  continue  research  and  development  of  ATI-501  and  ATI-502  for  the  treatment  of  AA,  and  potentially  for  other
dermatological conditions, as well as the identification, research and development of other compounds. We plan to continue
to invest in discovery efforts to explore additional drug candidates, build commercial capabilities and expand our corporate
infrastructure. We may not be able to complete the development and initiate commercialization of these programs if, among
other things, our clinical trials are not successful or if the FDA does not approve or our  drug candidates currently in clinical
trials when we expect, or at all. 

Our  primary  uses  of  capital  are,  and  we  expect  will  continue  to  be,  compensation  and  related  expenses,  clinical
costs, external research and development services, laboratory and related supplies, sales, marketing and direct-to-consumer
advertising  costs,  legal  and  other  regulatory  expenses,  and  administrative  and  overhead  costs.  Our  future  funding
requirements will be heavily determined by the resources needed to support development of our drug candidates. 

As a publicly traded company, we have incurred and will continue to incur significant legal, accounting and other
expenses that we were not required to incur as a private company. In addition, the Sarbanes-Oxley Act of 2002, as well as
rules  adopted  by  the  SEC  and  the  Nasdaq  Stock  Market,  requires  public  companies  to  implement  specified  corporate
governance  practices  that  were  not  applicable  to  us  prior  to  our  IPO.  We  expect  ongoing  compliance  with  these  rules  and
regulations will increase our legal and financial compliance costs and will make some activities more time-consuming and
costly. 

We  believe  our  existing  cash,  cash  equivalents  and  marketable  securities  are  sufficient  to  fund  our  operating  and
capital expenditure requirements for a period greater than 12 months from the date of issuance of our consolidated financial
statements  based  on  our  current  operating  assumptions  including  the  commercialization  of  ESKATA,  completion  of  our
Phase 2 clinical trials and initiation of Phase 3 clinical trials for A-101 45% Topical Solution for the treatment of common
warts and the continued development of ATI-501 and ATI-502 as potential treatments for AA. These assumptions may prove
to  be  wrong,  and  we  could  utilize  our  available  capital  resources  sooner  than  we  expect.  We  expect  that  we  will  require
additional capital to complete the clinical development and, if approved, commercialize A-101 45% Topical Solution for the
treatment  of  common  warts,  and  to  pursue  in-licenses  or  acquisitions  of  other  drug  candidates.    We  also  expect  to  incur
significant expenses related to the commercialization of ESKATA including product manufacturing, sales, marketing, direct-
to-consumer advertising and distribution costs.  Additional funds may not be available on a timely basis, on commercially
acceptable terms, or at all, and such funds, if raised, may not be sufficient to enable us to continue to implement our long-
term business strategy. If we are unable to raise sufficient additional capital, we may need to substantially curtail our planned
operations and the pursuit of our growth strategy. 

We  may  raise  additional  capital  through  the  sale  of  equity  or  convertible  debt  securities.  In  such  an  event,  your
ownership will be diluted, and the terms of these securities may include liquidation or other preferences that adversely affect
the rights of a holder of our common stock.    

Because  of  the  numerous  risks  and  uncertainties  associated  with  research,  development  and  commercialization  of
pharmaceutical drugs, we are unable to estimate the exact amount of our working capital requirements. Our future funding
requirements will depend on many factors, including:

·
·

·
·

·

·

the number and characteristics of the drug candidates we pursue;
the scope, progress, results and costs of researching and developing our drug candidates, and conducting
preclinical studies and clinical trials;
the timing of, and the costs involved in, obtaining marketing approvals for our drug candidates;
the cost of manufacturing commercial quantities of ESKATA and any drug candidates we successfully
commercialize;
our ability to establish and maintain strategic collaborations, licensing or other arrangements and the financial
terms of such agreements;
the costs involved in preparing, filing, prosecuting, maintaining, defending and enforcing patent claims,
including litigation costs and the outcome of such litigation; and

84

 
 
 
 
 
 
 
 
Table of Contents

·

the timing, receipt and amount of sales of, or milestone payments related to or royalties on, our current or future
drug candidates, if any.

See “Risk Factors” for additional risks associated with our substantial capital requirements.

Contractual Obligations and Commitments

The following table summarizes our contractual obligations at December 31, 2017 and the effect such obligations

are expected to have on our liquidity and cash flows in future periods:

Total

  Less Than  
1 Year

Payments Due by Period
1 ‑ 3
Years
(in thousands)

4 ‑ 5
Years

  More than  
5 Years

Operating lease commitments
Capital lease commitments
Vixen annual commitment
Total

  $ 3,639   $ 664   $ 1,821   $ 1,154   $

403  
500  

142  
100  

261  
300  

 —  
100  

  $ 4,542   $ 906   $ 2,382   $ 1,254   $

 —  
 —  
 —  
 —  

We  occupy  space  for  our  headquarters  in  Wayne,  Pennsylvania  under  a  sublease  agreement  which  has  a  term
through October 2023.  We lease office space in Malvern, Pennsylvania under an operating lease agreement which has a term
through November 2019.  We occupy office and laboratory space in St. Louis, Missouri under an operating lease agreement
which has a term through December 2018. 

We lease laboratory equipment used in our laboratory space in St. Louis, Missouri under two capital lease financing

arrangements which have terms through October 2020 and December 2020. 

Under various agreements, we will be required to make milestone payments and pay royalties and other amounts to
third parties. We have not included any contingent payment obligations, such as milestones or royalties, in the table above as
the amount, timing and likelihood of such payments are not known. 

Under  the  assignment  agreement  pursuant  to  which  we  acquired  intellectual  property,  we  have  agreed  to  pay
royalties on sales of ESKATA or other related products at rates ranging in low single-digit percentages of net sales, as defined
in the agreement.  Under the related finder’s services agreement, we have also agreed to make aggregate payments of up to
$4.5 million upon the achievement of specified commercial milestones. In addition, we have agreed to pay royalties on sales
of ESKATA or other related products at a low single-digit percentage of net sales, as defined in the agreement. 

Under  a  commercial  supply  agreement  with  a  third  party,  we  have  agreed  to  pay  a  termination  fee  of  up  to  $0.4

million in the event we terminate the agreement without cause or the third party terminates the agreement for cause. 

Under  a  license  agreement  with  Rigel  that  we  entered  into  in  August  2015,  we  have  agreed  to  make  aggregate
payments of up to $80.0 million upon the achievement of specified pre-commercialization milestones, such as clinical trials
and regulatory approvals. Further, we have agreed to pay up to an additional $10.0 million to Rigel upon the achievement of
a second set of development milestones. With respect to any products we commercialize under the agreement, we will pay
Rigel quarterly tiered royalties on our annual net sales of each product developed using the licensed JAK inhibitors at a high
single digit percentage of annual net sales, subject to specified reductions. 

Under  a  stock  purchase  agreement  with  the  selling  stockholders  of  Vixen,  we  are  obligated  to  make  aggregate
payments  of  up  to  $18.0  million  upon  the  achievement  of  specified  pre-commercialization  milestones  for  three  products
covered  by  the  Vixen  patent  rights  in  the  United  States,  the  European  Union  and  Japan,  and  aggregate  payments  of  up  to
$22.5 million upon the achievement of specified commercial milestones for products covered by the Vixen patent rights.  We
are also obligated to make a payment of $0.1 million on March 24th of each year, through March 24, 2022, which amounts
are creditable against any specified future payments that may be paid under the stock purchase agreement.  With respect to
any products we commercialize under the stock purchase agreement, we are obligated to pay low single-digit percentage of
annual net sales, subject to specified reductions, limitations and other adjustments, until the date that all of the patent rights
for  that  product  have  expired,  as  determined  on  a  country-by-country  and  product-by-product  basis  or,  in  specified
circumstances, ten years from the first commercial sale of such product.  If we sublicense any of the patent rights

85

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

and know-how acquired pursuant to the stock purchase agreement, we will be obligated to pay a portion of any consideration
we receive from such sublicenses in specified circumstances. 

Under  a  license  agreement  with  Columbia,  we  are  obligated  to  pay  an  annual  license  fee  of  $10,000,  subject  to
specified adjustments for patent expenses incurred by Columbia and creditable against any royalties that may be paid under
the license agreement.  We are also obligated to pay up to an aggregate of $11.6 million upon the achievement of specified
commercial milestones, including specified levels of net sales of products covered by Columbia patent rights and/or know-
how, and royalties at a sub-single-digit percentage of annual net sales of products covered by Columbia patent rights and/or
know-how,  subject  to  specified  adjustments.    If  we  sublicense  any  of  Columbia’s  patent  rights  and  know-how  acquired
pursuant to the license agreement, we will be obligated to pay Columbia a portion of any consideration Vixen receives from
such sublicenses in specified circumstances. 

Under a merger agreement with Confluence  we are obligated to make aggregate payments of up to $80.0 million
upon the achievement of specified development, regulatory and commercialization milestones.  With respect to any covered
products we commercialize, we are obligated to pay a low single-digit percentage of annual net sales, subject to specified
reductions,  limitations  and  other  adjustments,  until  the  date  that  all  of  the  patent  rights  for  that  product  have  expired,  as
determined  on  a  country-by-country  and  product-by-product  basis  or,  in  specified  circumstances,  ten  years  from  the  first
commercial sale of such product.  If we sublicense any of the patent rights and know-how acquired pursuant to the merger
agreement,  we  will  be  obligated  to  pay  a  portion  of  any  consideration  we  receive  from  such  sublicenses  in  specified
circumstances. 

We enter into contracts in the normal course of business with CROs for clinical trials, preclinical research studies
and  testing,  manufacturing  and  other  services  and  products  for  operating  purposes.  These  contracts  generally  provide  for
termination  upon  notice,  and  therefore  we  believe  that  our  non-cancelable  obligations  under  these  agreements  are  not
material. 

Off-Balance Sheet Arrangements

We did not have during the periods presented, and we do not currently have, any off-balance sheet arrangements, as

defined in the rules and regulations of the SEC. 

Recently Issued and Adopted Accounting Pronouncements

In  January  2017,  the  Financial  Accounting  Standards  Board,  or  FASB,  issued  Accounting  Standards  Update,  or
ASU, 2017-01, Business Combinations-Clarifying the Definition of a Business (Topic 805).  The amendments in this ASU
provide a screen to determine when a set of acquired assets and/or activities is not a business.  The screen requires that when
substantially all of the fair value of the gross assets acquired, or disposed of, is concentrated in a single identifiable asset or a
group  of  similar  identifiable  assets,  the  set  is  not  a  business.    The  amendments  in  this  ASU  will  reduce  the  number  of
transactions  that  meet  the  definition  of  a  business.   ASU  2017-01  is  effective  for  annual  reporting  periods  beginning  after
December  15,  2017,  including  interim  periods  within  those  years,  and  early  adoption  was  permitted.    We  are  currently
evaluating the potential impact of the adoption of this standard. 

In January 2017, the FASB issued ASU 2017-04, Intangibles-Goodwill and Other-Simplifying the Test for Goodwill
Impairment  (Topic  350).    Under  the  amendments  in  this  ASU,  an  entity  should  perform  its  annual,  or  interim,  goodwill
impairment  test  by  comparing  the  fair  value  of  a  reporting  unit  with  its  carrying  amount.   An  entity  should  recognize  an
impairment charge for the amount by which the carrying amount exceeds the reporting unit’s fair value; however, the loss
recognized should not exceed the total amount of goodwill allocated to that reporting unit.  The amendments in this ASU
eliminate Step 2 from the goodwill impairment test.  ASU 2017-04 is effective for fiscal years beginning after December 15,
2019,  and  early  adoption  is  permitted.    We  adopted  the  provisions  of  this  standard  early,  the  impact  of  which  on  our
consolidated financial statements was not significant. 

In  June  2016,  the  FASB  issued  ASU  2016-13,  Financial  Instruments-Credit  Losses  (Topic  326).    This  ASU
introduces  a  new  model  for  recognizing  credit  losses  on  financial  instruments  based  upon  estimated  expected  credit
losses.  ASU 2016-13 will apply to loans, accounts receivable, financial assets measured at amortized cost and at fair value
through other comprehensive income, loan commitments and certain off-balance sheet credit exposures.   ASU 2016-13 is
effective for annual reporting periods beginning after December 15, 2019, including interim periods within those years, and
early adoption is permitted.  We are assessing the potential impact of ASU 2016-13 on our consolidated financial statements.

86

 
 
 
 
 
 
 
 
 
 
 
Table of Contents

In March 2016, the FASB issued ASU 2016-09, Improvements to Employee Share-Based Payment Accounting.  This
ASU requires all tax effects of share-based payment settlements to be recorded through the income statement.  Currently, tax
benefits  in  excess  of  compensation  cost,  or  “windfalls”,  are  recorded  in  equity,  and  tax  deficiencies,  or  “shortfalls”,  are
recorded to equity to the extent of previous windfalls, and then to the income statement.  In addition, under the new guidance,
companies will be permitted to make a policy election to recognize the impact of forfeitures either when they occur, or on an
estimated basis.  Finally, this update simplifies withholding requirements to allow companies to withhold up to an employee’s
maximum tax rate without resulting in liability classification for the award.  ASU 2016-09 is effective for annual reporting
periods beginning after December 15, 2016.  We adopted the provisions of this standard early, the impact of which on our
consolidated financial statements was not significant.

In February 2016, the FASB issued ASU 2016-02, Leases (Topic 842).  The new standard establishes a right-of-use,
or ROU, model that requires a lessee to record a ROU asset and a lease liability on the balance sheet for all leases with terms
longer than 12 months.  Leases will be classified as either finance or operating, with classification affecting the pattern of
expense recognition in the income statement.  The new standard is effective for annual periods beginning after December 15,
2018,  including  interim  periods  within  those  annual  periods,  with  early  adoption  permitted.    A  modified  retrospective
transition approach is required for lessees for capital and operating leases existing at, or entered into after, the beginning of
the  earliest  comparative  period  presented  in  the  financial  statements,  with  certain  practical  expedients  available.    We  are
currently evaluating the potential impact of the adoption of this standard. 

In January 2016, the FASB issued ASU 2016-01, Recognition and Measurement of Financial Assets and Financial
Liabilities.    The  amendments  in  this  update  revise  the  accounting  related  to  the  classification  and  measurement  of
investments  in  equity  securities  and  the  presentation  of  certain  fair  value  changes  for  financial  liabilities  measured  at  fair
value.    The  amendments  are  effective  for  annual  reporting  periods  beginning  after  December  15,  2017,  including  interim
periods  within  those  fiscal  years.    Early  adoption  was  permitted.    We  are  currently  evaluating  the  potential  impact  of  the
adoption of this standard.  

In  November  2015,  the  FASB,  issued  ASU  2015-  17,  Balance  Sheet  Classification  of  Deferred  Taxes.    The
amendments in this update simplify the presentation of deferred income taxes to require that deferred tax liabilities and assets
are classified as noncurrent in a statement of financial position.  The amendments are effective for annual reporting periods
beginning after December 15, 2016 and interim reporting periods within those annual periods.  Early application is permitted.
We  adopted  the  provisions  of  ASU  2015-17  early,  the  impact  of  which  on  our  consolidated  financial  statements  was  not
significant. 

In  May  2014,  the  FASB  issued  ASU  2014-09,  Revenue  from  Contracts  with  Customers (Topic  606).    Under  this
ASU, entities should recognize revenue in an amount that reflects the consideration to which they expect to be entitled to in
exchange for goods and services provided.  ASU 2014-09 is effective for annual reporting periods beginning after December
15, 2017.  We adopted this standard as of January 1, 2018 and are assessing the impact of ASU 2014-09 on our consolidated
financial statements. 

Emerging Growth Company Status

The Jumpstart Our Business Startups Act of 2012, or the JOBS Act, permits an “emerging growth company” such as
us to take advantage of an extended transition period to comply with new or revised accounting standards applicable to public
companies until those standards would otherwise apply to private companies. We have irrevocably elected to “opt out” of this
provision and, as a result, we will comply with new or revised accounting standards when they are required to be adopted by
public companies that are not emerging growth companies. 

87

 
 
 
 
 
 
 
 
 
Table of Contents

Item 7A. Quantitative and Qualitative Disclosures about Market Risk

We are exposed to market risk related to changes in interest rates.  Our cash equivalents and marketable securities
consist of money market funds, asset-backed securities, commercial paper, corporate debt securities and government agency
debt. Our primary exposure to market risk is interest rate sensitivity, which is affected by changes in the general level of U.S.
interest rates.  Our marketable securities are subject to interest rate risk and will fall in value if market interest rates increase.
However, due to the short-term nature and low-risk profile of our investment portfolio, we do not expect that an immediate
10% change in market interest rates would have a material effect on the fair market value of our investment portfolio.  We
have the ability to hold our marketable securities until maturity, and therefore we would not expect our operating results or
cash flows to be affected to any significant degree by the effect of a change in market interest rates on our investments. 

88

 
 
 
Table of Contents

Item 8. Financial Statements and Supplementary Data

INDEX TO CONSOLIDATED FINANCIAL STATEMENTS

Report of Independent Registered Public Accounting Firm 

Consolidated Balance Sheets as of December 31, 2017 and 2016 

Consolidated Statements of Operations and Comprehensive Loss for the years ended December 31, 2017, 2016 and

2015 

Consolidated Statements of Convertible Preferred Stock and Stockholders’ Equity for the years ended December 31,

2017, 2016 and 2015 

Consolidated Statements of Cash Flows for the years ended December 31, 2017, 2016 and 2015 

Notes to Consolidated Financial Statements 

90

91

92

93

94

95

89

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Directors and Stockholders of
Aclaris Therapeutics, Inc.

Opinion on the Financial Statements

We have audited the accompanying consolidated balance sheets of Aclaris Therapeutics, Inc. and its subsidiaries as
of December 31st, 2017 and 2016, and the related consolidated statements of operations and comprehensive loss, statements
of convertible preferred stock and stockholders’ equity, and statements of cash flows for each of the three years in the period
ended  December  31st,  2017  including  the  related  notes  (collectively  referred  to  as  the  “consolidated  financial
statements”).    In  our  opinion,  the  consolidated  financial  statements  present  fairly,  in  all  material  respects,  the  financial
position of the Company as of December 31st, 2017 and 2016, and the results of their operations and their cash flows for
each of the three years in the period ended December 31st, 2017 in conformity with accounting principles generally accepted
in the United States of America. 

Basis for Opinion

These consolidated financial statements are the responsibility of the Company’s management.  Our responsibility is
to express an opinion on the Company’s consolidated financial statements based on our audits.  We are a public accounting
firm  registered  with  the  Public  Company  Accounting  Oversight  Board  (United  States)  (“PCAOB”)  and  are  required  to  be
independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and
regulations of the Securities and Exchange Commission and the PCAOB.

We  conducted  our  audits  of  these  consolidated  financial  statements  in  accordance  with  the  standards  of  the
PCAOB.    Those  standards  require  that  we  plan  and  perform  the  audit  to  obtain  reasonable  assurance  about  whether  the
consolidated  financial  statements  are  free  of  material  misstatement,  whether  due  to  error  or  fraud.    The  Company  is  not
required  to  have,  nor  were  we  engaged  to  perform,  an  audit  of  its  internal  control  over  financial  reporting.  As  part  of  our
audits  we  are  required  to  obtain  an  understanding  of  internal  control  over  financial  reporting  but  not  for  the  purpose  of
expressing  an  opinion  on  the  effectiveness  of  the  Company's  internal  control  over  financial  reporting.    Accordingly,  we
express no such opinion.

Our audits included performing procedures to assess the risks of material misstatement of the consolidated financial
statements, whether due to error or fraud, and performing procedures that respond to those risks.  Such procedures included
examining,  on  a  test  basis,  evidence  regarding  the  amounts  and  disclosures  in  the  consolidated  financial  statements.    Our
audits  also  included  evaluating  the  accounting  principles  used  and  significant  estimates  made  by  management,  as  well  as
evaluating the overall presentation of the consolidated financial statements.  We believe that our audits provide a reasonable
basis for our opinion.

/s/ PricewaterhouseCoopers LLP
Philadelphia, Pennsylvania
March 12, 2018

We have served as the Company’s auditor since 2015.

90

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

ACLARIS THERAPEUTICS, INC.
CONSOLIDATED BALANCE SHEETS

(In thousands, except share and per share data)

December 31, 

2017

2016

Assets
Current assets:

Cash and cash equivalents
Marketable securities
Accounts receivable, net
Prepaid expenses and other current assets

Total current assets

Marketable securities
Property and equipment, net
Intangible assets
Goodwill
Other assets

Total assets

Liabilities and Stockholders’ Equity
Current liabilities:

Accounts payable
Accrued expenses

Total current liabilities

Contingent consideration
Other liabilities
Deferred tax liability

Total liabilities
Stockholders’ Equity:

  $

20,202   $

30,171  
107,051  
 —  
1,334  
138,556  
36,912  
481  
 —  
 —  
136  
  $ 243,509   $ 176,085  

173,655  
481  
5,883  
200,221  
14,997  
2,159  
7,349  
18,504  
279  

  $

7,822   $
4,940  
12,762  
4,378  
558  
549  
18,247  

2,845  
3,378  
6,223  
 —  
372  
 —  
6,595  

Preferred stock, $0.00001 par value; 10,000,000 shares authorized and no shares issued or

outstanding at December 31, 2017 and December 31, 2016

 —  

 —  

Common stock, $0.00001 par value; 100,000,000 shares authorized at December 31, 2017
and December 31, 2016; 30,856,505 and 26,059,181 shares issued and outstanding at
December 31, 2017 and December 31, 2016, respectively

Additional paid‑in capital
Accumulated other comprehensive loss
Accumulated deficit

Total stockholders’ equity
Total liabilities and stockholders’ equity

 —  
384,943  
(246) 
(159,435) 
225,262  

 —  
260,671  
(269) 
(90,912) 
169,490  
  $ 243,509   $ 176,085  

The accompanying notes are an integral part of these consolidated financial statements.

91

 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
 
 
 
 
 
 
 
 
 
   
 
   
 
 
   
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
 
 
   
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

ACLARIS THERAPEUTICS, INC.
CONSOLIDATED STATEMENTS OF OPERATIONS AND COMPREHENSIVE LOSS

(In thousands, except share and per share data)

Year Ended
December 31, 
2016

2017

2015

Revenue
Cost of revenue
Gross profit
Operating expenses:

Research and development
General and administrative
Total operating expenses

Loss from operations
Other income, net
Loss before income taxes
Provision for (benefit from) income taxes
Net loss
Accretion of convertible preferred stock
Net loss attributable to common stockholders
Net loss per share attributable to common stockholders, basic and diluted
Weighted average common shares outstanding, basic and diluted
Other comprehensive loss:

Unrealized (loss) gain on marketable securities, net of tax of $0
Foreign currency translation adjustments

Total other comprehensive income (loss)

Comprehensive loss

    $

  $
  $

1,683     $
1,207  
476  

39,790  
33,109  
72,899  
(72,423) 
2,070  
(70,353) 
(1,830) 
(68,523) 
 —  
(68,523)  $
(2.44)  $

 —   $
 —  
 —  

 —  
 —  
 —  

33,476  
15,091  
48,567  
(48,567) 
488  
(48,079) 
 —  
(48,079) 
 —  
(48,079)  $
(2.25)  $

15,339  
5,328  
20,667  
(20,667) 
104  
(20,563) 
 —  
(20,563) 
(2,566) 
(23,129) 
(3.79) 
  6,107,042  

  28,102,386  

  21,415,733  

  $

  $

(121)  $
144  
23  
(68,500)  $

105  
(225) 
(120) 
(48,199)  $

(148) 
 5  
(143) 
(20,706) 

The accompanying notes are an integral part of these consolidated financial statements.

92

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
   
 
   
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

ACLARIS THERAPEUTICS, INC.
CONSOLIDATED STATEMENTS OF CONVERTIBLE PREFERRED STOCK
AND STOCKHOLDERS’ EQUITY

(In thousands, except share data)

Balance at December 31, 2014

Issuance of Series C convertible

preferred stock, net of issuance costs
of $136

Issuance of common stock in

connection with IPO, net of offering
costs of $2,272

Issuance of common stock upon

conversion of convertible preferred
stock

Unrealized loss on marketable securities  
Foreign currency translation adjustment  
Stock-based compensation expense
Accretion of redeemable convertible

preferred stock to redemption value

Net loss

Balance at December 31, 2015
Issuance of common stock in

connection with Vixen acquisition

Issuance of common stock in

connection with private placement,
net of offering costs of $1,453

Issuance of common stock in

connection with follow-on public
offering, net of offering costs of
$6,492

Exercise of stock options and vesting of

RSUs

Unrealized gain on marketable

securities

Foreign currency translation adjustment  
Stock-based compensation expense
Net loss 

Balance at December 31, 2016

Issuance of common stock under the at-
the-market sales agreement, net of
offering costs of $691

Issuance of common stock in

connection with public offering, net
of offering costs of $5,352
Issuance of common stock in

connection with the acquisition of
Confluence

Exercise of stock options and vesting of

RSUs

Unrealized loss on marketable securities  
Foreign currency translation adjustment  
Stock-based compensation expense
Net loss 

Balance at December 31, 2017

Series A, B and C
Convertible
Preferred Stock

Shares

   Amount      
27,341,057   $ 36,677    

    Common Stock   Additional 

  Accumulated    
Other

Total

  Shares 

  Par   Paid‑in   Comprehensive   Accumulated  Stockholders’  
   Value   Capital

Equity

Deficit

Loss

2,730,427   $  —   $

 —   $

(6)  $

(20,749)  $

(20,755) 

12,944,984     39,864    

 —  

 —  

 —  

 —    

 —    

5,750,000  

 —  

56,550  

(40,286,041)    (78,305)    
 —    
 —    
 —    

 —    
 —    
 —    

11,677,076  
 —  
 —  
 —  

 —  
 —  
 —  
 —  

78,305  
 —  
 —  
891  

 —    
 —    
 —    

1,764    
 —    
 —    

 —  
 —  

20,157,503    

 —  
 —  
 —    

(243) 
 —  

135,503    

 —    

 —    

159,420    

 —    

2,355    

 —  

 —  

 —  
(148) 
 5  
 —  

 —  
 —  
(149)   

 —    

 —  

 —  

 —  

56,550  

 —  
 —  
 —  
 —  

(1,521) 
(20,563) 
(42,833)   

78,305  
(148) 
 5  
891  

(1,764) 
(20,563) 
92,521  

 —    

2,355  

 —    

 —    

1,081,082    

 —    

18,547    

 —    

 —    

18,547  

 —    

 —    

4,600,000    

 —    

98,158    

 —    

 —    

61,176    

 —    

 4    

 —    
 —    
 —    
 —    
 —    

 —    
 —    
 —    
 —    
 —    26,059,181    

 —    
 —    
 —    
 —  

 —    
 —    
 —    
 —  
 —     260,671    

 —    
 —    
6,104    
 —  

 —    

 —    

105    
(225)   
 —    
 —  
(269)   

 —    

 —    

 —    
 —    
 —    

(48,079) 
(90,912)   

98,158  

 4  

105  
(225) 
6,104  
(48,079) 
169,490  

 —    

 —   

635,000    

 —    

19,311    

 —    

 —    

19,311  

 —    

 —   

3,747,602    

 —    

80,918    

 —    

 —    

80,918  

349,527    

9,675    

 —    

 —    
 —    
 —    
 —    
 —    
 —   $

 —   
 —   
 —   
 —   
 —   
 —    30,856,505   $  —   $ 384,943   $

65,195    
 —    
 —    
 —    
 —  

(62)   
 —    
 —    
14,430    
 —  

 —    
 —    
 —    
 —    
 —  

 —    
(121)   
144    
 —    
 —  
(246)  $

 —    

 —    
 —    
 —    
 —    

(68,523) 
(159,435)  $

9,675  

(62) 
(121) 
144  
14,430  
(68,523) 
225,262  

The accompanying notes are an integral part of these consolidated financial statements.

93

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
 
   
 
 
   
 
 
 
 
 
 
 
 
 
 
   
 
 
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

ACLARIS THERAPEUTICS, INC.
CONSOLIDATED STATEMENTS OF CASH FLOWS

(In thousands)

Cash flows from operating activities:

Net loss
Adjustments to reconcile net loss to net cash used in operating activities:

Depreciation and amortization
Stock-based compensation expense
Deferred taxes
Write-down of property and equipment held for sale
Non-cash charges related to Vixen acquisition
Changes in operating assets and liabilities:

Prepaid expenses and other assets
Accounts payable
Accrued expenses

Net cash used in operating activities
Cash flows from investing activities:
Purchases of property and equipment
Acquisition of Confluence, net of cash acquired
Purchases of marketable securities
Proceeds from sales and maturities of marketable securities

Net cash used in investing activities
Cash flows from financing activities:

Year Ended
December 31, 
2016

2017

2015

  $ (68,523)  $ (48,079)  $ (20,563) 

402  
14,430  
(1,837) 
 —  
 —  

(4,306) 
4,564  
607  
(54,663) 

120   
6,104   
 —   
216   
2,784   

90  
891  
 —  
289  
 —  

(8)   
1,810   
2,450   
(34,603)   

(1,269) 
(359) 
552  
(20,369) 

(1,235) 
(9,647) 
  (197,337) 
152,527  
(55,692) 

(232)   
 —   
  (148,764)   
87,093   
(61,903)   

(507) 
 —  
(82,513) 
6,069  
(76,951) 

Proceeds from issuance of common stock under the at-the-market sales

agreement, net of issuance costs

Proceeds from issuance of common stock in connection with public offering, net

of issuance costs

Proceeds from issuance of common stock in connection with private placement,

net of issuance costs

Proceeds from initial public offering, net of issuance costs
Proceeds from issuance of redeemable convertible preferred stock, net of

issuance costs

Capital lease payments
Proceeds from the exercise of employee stock options

Net cash provided by financing activities

Net (decrease) increase in cash and cash equivalents
Cash and cash equivalents at beginning of period
Cash and cash equivalents at end of period
Supplemental disclosure of non-cash investing and financing activities:

Additions to property and equipment included in accounts payable
Fair value of stock issued in connection with Confluence acquisition
Fair value of stock issued in connection with Vixen acquisition
Offering costs included in accounts payable
Accretion of convertible preferred stock to redemption value

  $

  $
  $
  $
  $
  $

19,311  

 —   

80,918  

98,158   

 —  

 —  

 —  
 —  

18,547   
 —   

 —  
56,550  

 —  
(78) 
235  
100,386  
(9,969) 
30,171  
20,202   $

 —   
 —   
121   
116,826   
20,320   
9,851   
30,171  $

39,864  
 —  
 —  
96,414  
(906) 
10,757  
9,851  

274   $
9,675   $
 —   $
20   $
 —   $

11  $
 —   
2,355  $
250  $
 —  $

 2  
 —  
 —  
 —  
1,764  

The accompanying notes are an integral part of these consolidated financial statements.

94

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
 
 
          
          
     
 
 
   
 
   
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
     
 
 
 
 
Table of Contents

ACLARIS THERAPEUTICS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

(Amounts in thousands, except share and per share data)

1. Organization and Nature of Business

Overview

Aclaris Therapeutics, Inc. was incorporated under the laws of the State of Delaware in 2012.  In July 2015, Aclaris
Therapeutics  International  Limited  (“ATIL”)  was  established  under  the  laws  of  the  United  Kingdom  as  a  wholly-owned
subsidiary  of  Aclaris  Therapeutics,  Inc.    In  March  2016,  Vixen  Pharmaceuticals,  Inc.  (“Vixen”)  became  a  wholly-owned
subsidiary of Aclaris Therapeutics, Inc. (see Note 12).  In August 2017, Confluence Life Sciences Inc. (“Confluence”) was
acquired by Aclaris Therapeutics, Inc. and became a wholly-owned subsidiary thereof (see Note 3).  Aclaris Therapeutics,
Inc.,  ATIL,  Vixen  and  Confluence  are  referred  to  collectively  as  the  “Company”.    The  Company  is  a  dermatologist-led
biopharmaceutical company focused on identifying, developing and commercializing innovative and differentiated therapies
to  address  significant  unmet  needs  in  medical  and  aesthetic  dermatology.  The  Company’s  lead  drug,  ESKATA  (Hydrogen
Peroxide) Topical Solution, 40% (w/w) (“ESKATA”), is a proprietary high‑concentration formulation of hydrogen peroxide
that  the  Company  is  commercializing  as  a  prescription  treatment  for  raised  seborrheic  keratosis  (“SK”),  a  common
non‑malignant skin tumor. In February 2017, the Company submitted a New Drug Application (“NDA”) for ESKATA to the
U.S. Food and Drug Administration (“FDA”).  The NDA was approved by the FDA in December 2017. 

Liquidity

The  Company’s  consolidated  financial  statements  have  been  prepared  on  the  basis  of  continuity  of  operations,
realization of assets and the satisfaction of liabilities in the ordinary course of business. At December 31, 2017, the Company
had cash, cash equivalents and marketable securities of $208,854 and an accumulated deficit of $159,435.  Since inception,
the Company has incurred net losses and negative cash flows from its operations.  Prior to the acquisition of Confluence in
August 2017, the Company had never generated any revenue. There is no assurance that profitable operations will ever be
achieved,  and,  if  achieved,  will  be  sustained  on  a  continuing  basis.    In  addition,  development  activities,  clinical  and  pre-
clinical testing, and commercialization of the Company’s drug candidates will require significant additional financing.  The
Company expects that its cash, cash equivalents and marketable securities as of December 31, 2017 will be sufficient to fund
its operations for a period greater than 12 months from the date of issuance of these consolidated financial statements based
on its current operating assumptions. The future viability of the Company is dependent on its ability to generate cash from
operating activities or to raise additional capital to finance its operations. The Company’s failure to raise capital as and when
needed could have a negative impact on its financial condition and ability to pursue its business strategies. 

2. Summary of Significant Accounting Policies

Basis of Presentation

The accompanying consolidated financial statements have been prepared in conformity with accounting principles
generally accepted in the United States of America (“GAAP”).  The financial statements include the consolidated accounts of
the  Company  and  its  wholly-owned  subsidiaries,  Confluence,  ATIL  and  Vixen.   All  significant  intercompany  transactions
have been eliminated. 

Use of Estimates

The  preparation  of  financial  statements  in  conformity  with  GAAP  requires  management  to  make  estimates  and
assumptions that affect the reported amounts of assets and liabilities, the disclosure of contingent assets and liabilities at the
date of the financial statements and the reported amounts of expenses during the reporting periods. Significant estimates and
assumptions  reflected  in  these  financial  statements  include,  but  are  not  limited  to,  research  and  development  expenses,
contingent consideration and the valuation of stock-based awards. 

95

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Estimates are periodically reviewed in light of changes in circumstances, facts and experience. Actual results could

differ from the Company’s estimates.

Revenue Recognition

The Company recognizes revenue when the earnings process is complete, which under SEC Staff Accounting
Bulletin  No.  104,  Topic  No.  13,  “Revenue  Recognition,”  is  when  revenue  is  realized  or  realizable  and  earned,  there  is
persuasive  evidence  a  revenue  arrangement  exists,  delivery  of  goods  or  services  has  occurred,  the  sales  price  is  fixed  or
determinable, and collectability is reasonably assured. 

The  Company  earns  revenue  from  the  provision  of  laboratory  services  to  clients  through  Confluence,  its  wholly-
owned subsidiary.  Laboratory service revenue is generally evidenced by contracts with clients which are on an agreed upon
fixed-price, fee-for-service basis and are generally billed on a monthly basis in arrears for services rendered.  Revenue related
to  these  contracts  is  generally  recognized  as  the  laboratory  services  are  performed,  based  upon  the  rates  specified  in  the
contracts. 

The  Company  also  receives  revenue  from  grants  under  the  Small  Business  Innovation  Research  program  of  the
National Institutes of Health (“NIH”).  The Company, through its Confluence subsidiary, currently has two active grants from
NIH which are related to early-stage research.  The Company recognizes revenue related to these grants as amounts become
reimbursable under each grant, which is generally when research is performed and the related costs are incurred. 

Research and Development Costs

Research  and  development  costs  are  expensed  as  incurred.  Research  and  development  expenses  include  salaries,
stock-based  compensation  and  benefits  of  employees,  fees  paid  under  licensing  agreements,  fees  paid  under  a  third  party
assignment agreement and other operational costs related to the Company’s research and development activities, including
depreciation expenses and the cost of research and development contracts which the Company has entered into with outside
vendors to conduct both preclinical studies and clinical trials.  Significant judgment and estimates are made in determining
the amount of research and development costs recognized in each reporting period.  The Company analyzes the progress of
its  preclinical  studies  and  clinical  trials,  completion  of  milestone  events,  invoices  received  and  contracted  costs  when
estimating  research  and  development  costs.  Actual  results  could  differ  from  the  Company’s  estimates.  The  Company’s
historical estimates for research and development costs have not been materially different from the actual costs.

Foreign Currency Translation

The reporting currency of the Company is the U.S. Dollar. The functional currency of ATIL, the Company’s wholly-
owned  subsidiary,  is  the  British  Pound.    Assets  and  liabilities  of  ATIL  are  translated  into  U.S.  Dollars  based  on  exchange
rates at the end of each reporting period. Revenues and expenses are translated at average exchange rates during the reporting
period.  Gains  and  losses  arising  from  the  translation  of  assets  and  liabilities  are  included  as  a  component  of  accumulated
other comprehensive loss within the Company’s consolidated balance sheet. Gains and losses resulting from foreign currency
transactions are reflected within the Company’s consolidated statements of operations. The Company has not utilized foreign
currency hedging strategies to mitigate the effect of its foreign currency exposure.

Stock-Based Compensation

The Company measures the compensation expense of stock-based awards granted to employees and directors using
the grant date fair value of the award.  The Company has issued stock options and restricted stock unit (“RSU”) awards with
service-based vesting conditions, as well as with performance-based vesting conditions.  The Company has not issued awards
that include market-based conditions.  For service-based awards the Company recognizes stock-based compensation expense
on a straight-line basis over the requisite service period.  For performance-based awards the Company recognizes stock-based
compensation  expense  on  a  straight-line  basis  over  the  requisite  service  period  beginning  in  the  period  that  it  becomes
probable  the  performance  conditions  will  occur.    At  each  balance  sheet  date,  the  Company  evaluates  whether  any
performance  conditions  related  to  a  performance-based  award  have  changed.    The  effect  of  any  change  in  performance
conditions would be recognized as a cumulative catch-up adjustment in the period such change occurs, and any remaining
unrecognized  compensation  expense  would  be  recognized  on  a  straight-line  basis  over  the  remaining  requisite  service
period.  The impact of forfeitures is recognized in the period in which they occur. 

96

 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

The Company initially measures the compensation expense of stock-based awards granted to consultants using the
grant date fair value of the award. Compensation expense is recognized over the period during which services are rendered
by  such  consultants.  At  the  end  of  each  financial  reporting  period  prior  to  completion  of  services  being  rendered,  the
compensation  expense  related  to  these  awards  is  remeasured  using  the  then  current  fair  value  of  the  Company’s  common
stock for RSUs, or based upon updated assumptions in the Black-Scholes option pricing model for stock option awards. 

The Company classifies stock-based compensation expense in its statement of operations and comprehensive loss in
the  same  manner  in  which  the  award  recipient’s  payroll  costs  are  classified  or  in  which  the  award  recipients’  service
payments are classified. 

The fair value of each stock option grant is estimated on the date of grant using the Black-Scholes option-pricing
model.  The  Company  estimates  its  expected  stock  volatility  based  on  the  historical  volatility  of  a  set  of  peer  companies,
which are publicly traded, and expects to continue to do so until it has adequate historical data regarding the volatility of its
own  publicly-traded  stock  price.  The  expected  term  of  the  Company’s  stock  options  has  been  determined  using  the
“simplified” method for awards that qualify as “plain vanilla” options. The expected term of stock options granted to non-
employees is equal to the contractual term of the option award. The risk-free interest rate is determined by reference to the
U.S. Treasury yield curve in effect at the time of grant of the award for time periods approximately equal to the expected
term of the award. The Company uses an expected dividend yield of zero based on the fact that the Company has never paid
cash dividends and does not expect to pay cash dividends in the future.  Prior to the IPO, the Company valued its common
stock using a hybrid method to estimate its enterprise value.  The hybrid method used was a probability-weighted expected
return method which was a scenario-based methodology that estimated the fair value of the Company’s common stock based
upon an analysis of future values for the Company assuming various outcomes.  The hybrid method used calculated equity
values using an option pricing model in one or more of scenarios, and also considered the rights of each class of stock. 

The  fair  value  of  each  RSU  is  measured  using  the  closing  price  of  the  Company’s  common  stock  on  the  date  of

grant.

Patent Costs

All  patent  related  costs  incurred  in  connection  with  filing  and  prosecuting  patent  applications  are  expensed  as
incurred  due  to  the  uncertainty  about  the  recovery  of  the  expenditure.    Amounts  incurred  are  classified  as  general  and
administrative expenses.

Income Taxes

The  Company  accounts  for  income  taxes  using  the  asset  and  liability  method,  which  requires  the  recognition  of
deferred  tax  assets  and  liabilities  for  the  expected  future  tax  consequences  of  events  that  have  been  recognized  in  the
financial  statements  or  in  the  Company’s  tax  returns.  Deferred  taxes  are  determined  based  on  the  difference  between  the
financial statement and tax basis of assets and liabilities using enacted tax rates in effect in the years in which the differences
are  expected  to  reverse.  Changes  in  deferred  tax  assets  and  liabilities  are  recorded  in  the  provision  for  income  taxes.  The
Company assesses the likelihood that its deferred tax assets will be recovered from future taxable income and, to the extent it
believes, based upon the weight of available evidence, that it is more likely than not that all or a portion of the deferred tax
assets  will  not  be  realized,  a  valuation  allowance  is  established  through  a  charge  to  income  tax  expense.  Potential  for
recovery  of  deferred  tax  assets  is  evaluated  by  estimating  the  future  taxable  profits  expected  and  considering  prudent  and
feasible tax planning strategies.

The  Company  accounts  for  uncertainty  in  income  taxes  recognized  in  the  consolidated  financial  statements  by
applying a two-step process to determine the amount of tax benefit to be recognized. First, the tax position must be evaluated
to determine the likelihood that it will be sustained upon external examination by the taxing authorities. If the tax position is
deemed more likely than not to be sustained, the tax position is then assessed to determine the amount of benefit to recognize
in the consolidated financial statements. The amount of the benefit that may be recognized is the largest amount that has a
greater than 50% likelihood of being realized upon ultimate settlement. The provision for income taxes includes the effects of
any resulting tax reserves, or unrecognized tax benefits, that are considered appropriate as well as the related net interest and
penalties.

97

 
 
 
 
 
 
 
 
 
 
Table of Contents

Reverse Stock Split

In  September  2015,  the  Company  effected  a  1‑for‑3.45  reverse  stock  split  of  its  issued  and  outstanding  shares  of
common  stock  and  a  proportional  adjustment  to  the  existing  conversion  ratios  for  each  series  of  the  Company’s  then-
outstanding  convertible  preferred  stock.  Accordingly,  all  share  and  per  share  amounts  for  all  periods  presented  in  these
consolidated financial statements and notes thereto have been adjusted retroactively, where applicable, to reflect this reverse
stock split and adjustment of the preferred stock conversion ratios. 

Accretion of Convertible Preferred Stock

Accretion of convertible preferred stock included the accretion of accruing dividends on and issuance costs of the
Company’s  Series  A,  B  and  C  convertible  preferred  stock.  The  carrying  values  of  the  Series  A  and  Series  B  convertible
preferred  stock  were  accreted  to  their  respective  redemption  values,  using  the  effective  interest  method,  from  the  date  of
issuance through August 28, 2015.  In connection with the closing of the Company’s Series C convertible preferred stock
financing  on  August  28,  2015,  the  redemption  rights  of  the  Series  A  and  B  convertible  preferred  stock  were
removed.    Subsequent  to  August  28,  2015,  the  Company  was  no  longer  required  to  record  the  accumulated  undeclared
dividends on its balance sheet, but was thereafter required to deduct accumulated undeclared dividends as part of its earnings
per share calculation.  In October 2015, in connection with the Company’s IPO, all of the Company’s convertible preferred
stock was converted to common stock. 

Comprehensive Loss

Comprehensive  loss  includes  net  loss  as  well  as  other  changes  in  stockholders’  equity  (deficit)  that  result  from
transactions and economic events other than those with stockholders. Comprehensive loss is comprised of net loss, foreign
currency translation adjustments and unrealized gains (losses) on marketable securities.

Net Loss per Share

Basic net loss per share is computed using the weighted average number of common shares outstanding during the
period.  Diluted net loss per share is computed using the sum of the weighted average number of common shares outstanding
during the period, plus the weighted average number of potential shares of common stock from the assumed exercise of stock
options, and the assumed vesting of RSUs and restricted stock granted by the Company upon its formation, if dilutive.  Prior
to the IPO, the Company applied the two-class method of calculating its basic and diluted net loss per share attributable to
common stockholders since its convertible preferred stock and common stock were participating securities.  The Company’s
convertible preferred stock contractually entitled the holders of such shares to participate in dividends, but not in losses, of
the Company. Since the Company was in a net loss position, and preferred stockholders did not participate in losses, basic
and diluted net loss per share was the same for each of the periods presented. 

Cash Equivalents

The  Company  considers  all  short  term,  highly  liquid  investments  with  original  maturities  of  90  days  or  less  at
acquisition date to be cash equivalents. Cash equivalents, which have consisted of money market accounts, commercial paper
and corporate debt securities with original maturities of less than three months, are stated at fair value. 

Marketable Securities

Marketable securities with original maturities of greater than three months and remaining maturities of less than one
year from the balance sheet date are classified as short term. Marketable securities with remaining maturities of greater than
one year from the balance sheet date are classified as long term. 

98

 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

The Company classifies all of its marketable securities as available-for-sale securities. The Company’s marketable
securities are measured and reported at fair value using quoted prices in markets that are not active for identical or similar
securities. Unrealized gains and losses are reported as a separate component of stockholders’ equity. The cost of securities
sold is determined on a specific identification basis, and realized gains and losses, if any, are included in other income, net
within the consolidated statement of operations and comprehensive loss. If any adjustment to fair value reflects a decline in
the value of the investment, the Company considers available evidence to evaluate the extent to which the decline is “other
than temporary” and reduces the investment to fair value through a charge to the statement of operations and comprehensive
loss. 

Assets Held for Sale

In order for an asset to be classified as held for sale, several criteria must be achieved.  These criteria include, among
others, an active program to market an asset and locate a buyer, as well as the probable disposition of the asset within one
year.    Upon  being  classified  as  held  for  sale,  the  recoverability  of  the  carrying  value  of  an  asset  must  be  assessed  and
evaluated.  After the valuation process is completed, the held for sale asset is reported at the lower of its carrying value or fair
value less cost to sell, and no additional depreciation expense is recognized related to the asset.  Once an asset is classified as
held  for  sale,  all  of  its  historical  balance  sheet  information  is  included  in  prepaid  expenses  and  other  current  assets  in  the
accompanying consolidated balance sheets. During the year ended December 31, 2015, the Company determined that several
pieces  of  machinery  used  in  the  Company’s  scale-up  operations  would  no  longer  be  part  of  the  Company’s  future
operations.  The Company engaged a third-party to market the assets and locate a buyer in the fourth quarter of 2015. During
the year ended December 31, 2016, the Company was unable to locate a buyer for the machinery and, therefore, wrote the
remaining value of the machinery down to zero.  The Company recorded impairment charges of $216 and $289 in the years
ended  December  31,  2016  and  2015,  respectively.    The  impairment  charges  are  included  in  research  and  development
expense  on  the  Company’s  consolidated  statement  of  operations  and  comprehensive  loss.    The  Company  had  no  assets
classified as held for sale as of December 31, 2017 and 2016. 

Other Assets

In  February  2017,  the  Company  paid  a  $2.0  million  PDUFA  fee  to  the  FDA  in  conjunction  with  the  filing  of  its
NDA for ESKATA.  The Company requested a waiver and refund of this PDUFA fee, which was approved by the FDA in
December 2017.  The amount paid by the Company has been recorded in prepaid expenses and other current assets on the
Company’s consolidated balance sheet since the refund was not received until after December 31, 2017. 

Fair Value Measurements

Certain assets and liabilities are carried at fair value under GAAP. Fair value is defined as the exchange price that
would be received for an asset or paid to transfer a liability (an exit price) in the principal or most advantageous market for
the  asset  or  liability  in  an  orderly  transaction  between  market  participants  on  the  measurement  date.  Valuation  techniques
used  to  measure  fair  value  must  maximize  the  use  of  observable  inputs  and  minimize  the  use  of  unobservable  inputs.
Financial assets and liabilities carried at fair value are to be classified and disclosed in one of the following three levels of the
fair value hierarchy, of which the first two are considered observable and the last is considered unobservable:

·

·

·

Level 1 — Quoted prices in active markets for identical assets or liabilities.

Level 2 — Observable inputs (other than Level 1 quoted prices), such as quoted prices in active markets for
similar assets or liabilities, quoted prices in markets that are not active for identical or similar assets or
liabilities, or other inputs that are observable or can be corroborated by observable market data.

Level 3 — Unobservable inputs that are supported by little or no market activity and that are significant to
determining the fair value of the assets or liabilities, including pricing models, discounted cash flow
methodologies and similar techniques.

The  Company’s  cash  equivalents,  marketable  securities  and  contingent  consideration  are  carried  at  fair  value,
determined according to the fair value hierarchy described above.  The carrying value of the Company’s accounts payable
and accrued expenses approximate fair value due to the short-term nature of these liabilities. 

99

 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Concentration of Credit Risk and of Significant Customers and Suppliers

Financial instruments that potentially expose the Company to concentrations of credit risk consist primarily of cash,
cash equivalents and marketable securities. The Company holds all cash, cash equivalents and marketable securities balances
at one accredited financial institution, in amounts that exceed federally insured limits. The Company does not believe that it
is subject to unusual credit risk beyond the normal credit risk associated with commercial banking relationships. 

The  Company’s  top  five  customers  represented  70%  of  total  laboratory  service  revenues  earned  from  August  3,

2017, the date of acquisition of Confluence, through December 31, 2017. 

The Company is dependent on third party manufacturers to supply products for research and development activities
of  its  programs,  including  preclinical  and  clinical  testing.  These  programs  could  be  adversely  affected  by  a  significant
interruption in the supply of active pharmaceutical ingredients and other components. 

Deferred Offering Costs

The  Company  recorded  legal,  accounting  and  other  third-party  fees  associated  directly  with  the  filing  of  its
registration  statement  on  Form  S-3  in  November  2016,  in  other  assets  on  its  consolidated  balance  sheet.    These  deferred
offering  costs  are  recorded  in  stockholders’  equity  as  a  reduction  of  the  proceeds  generated  from  offerings  consummated
under the Form S-3 on a pro rata basis.  The Company may also record legal, accounting and other third-party fees directly
associated  with  in-process  equity  financings  as  deferred  offering  costs  (non-current)  until  such  financings  are
completed.  The deferred costs related to an in-process equity financing are recorded in stockholders’ equity as a reduction of
the  proceeds  generated  from  the  related  offering  when  it  is  completed.    Deferred  offering  costs  were  $62  and  $116  as  of
December 31, 2017 and 2016, respectively. 

Property and Equipment

Property and equipment are stated at cost less accumulated depreciation. Depreciation expense is recognized using
the straight-line method over the useful life of the asset. Computer equipment is depreciated over three years. Manufacturing
and laboratory equipment is depreciated over five years. Furniture and fixtures are depreciated over five years.  Leasehold
improvements are depreciated over the shorter of the lease term or their useful life.  Expenditures for repairs and maintenance
of assets are charged to expense as incurred. Upon retirement or sale, the cost and related accumulated depreciation of assets
disposed of are removed from the accounts and any resulting gain or loss is included in loss from operations. 

Impairment of Long Lived Assets

Long-lived  assets  consist  of  property  and  equipment.  Long-lived  assets  to  be  held  and  used  are  tested  for
recoverability whenever events or changes in business circumstances indicate that the carrying amount of the assets may not
be  fully  recoverable.  Factors  that  the  Company  considers  in  deciding  when  to  perform  an  impairment  review  include
significant underperformance of the business in relation to expectations, significant negative industry or economic trends and
significant changes or planned changes in the use of the assets. If an impairment review is performed to evaluate a long lived
asset  for  recoverability,  the  Company  compares  forecasts  of  undiscounted  cash  flows  expected  to  result  from  the  use  and
eventual disposition of the long lived asset to its carrying value. An impairment loss would be recognized when estimated
undiscounted future cash flows expected to result from the use of an asset are less than its carrying amount. The impairment
loss  would  be  based  on  the  excess  of  the  carrying  value  of  the  impaired  asset  over  its  fair  value,  determined  based  on
discounted cash flows. 

100

 
 
 
 
 
 
 
 
 
 
Table of Contents

Intangible Assets

Intangible  assets  include  both  finite-lived  and  indefinite-lived  assets.    Finite-lived  intangible  assets  are  amortized
over their estimated useful life based on the pattern over which the intangible assets are consumed or otherwise used up. If
that  pattern  cannot  be  reliably  determined,  the  straight-line  method  of  amortization  is  used.    Finite-lived  intangible  assets
consist  of  a  research  technology  platform  the  Company  acquired  through  the  acquisition  of  Confluence.    Indefinite-lived
intangible  assets  consist  of  an  in-process  research  and  development  (“IPR&D”)  drug  candidate  acquired  through  the
acquisition  of  Confluence.    IPR&D  assets  are  considered  indefinite-lived  until  the  completion  or  abandonment  of  the
associated research and development efforts.  The cost of IPR&D assets is either amortized over their estimated useful life
beginning  when  the  underlying  drug  candidate  is  approved  and  launched  commercially,  or  expensed  immediately  if
development of the drug candidate is abandoned. 

Finite-lived intangible assets are tested for impairment when events or changes in circumstances indicate that the
carrying  value  of  the  asset  may  not  be  recoverable.    Indefinite-lived  intangible  assets  are  tested  for  impairment  at  least
annually,  which  the  Company  performs  during  the  fourth  quarter,  or  when  indicators  of  an  impairment  are  present.    The
Company recognizes impairment losses when and to the extent that the estimated fair value of an indefinite-lived intangible
asset is less than its carrying value. 

Goodwill

Goodwill  is  not  amortized,  but  rather  is  subject  to  testing  for  impairment  at  least  annually,  which  the  Company
performs  during  the  fourth  quarter,  or  when  indicators  of  an  impairment  are  present.   The  Company  considers  each  of  its
operating segments, dermatology therapeutics and contract research, to be a reporting unit since this is the lowest level for
which discrete financial information is available.  The Company has attributed the full amount of the goodwill acquired with
Confluence, or $18,504, to the dermatology therapeutics segment.  The annual impairment test performed by the Company is
a  qualitative  assessment  based  upon  current  facts  and  circumstances  related  to  operations  of  the  dermatology  therapeutics
segment.  If the qualitative assessment indicates an impairment may be present, the Company would perform the required
quantitative  analysis  and  an  impairment  charge  would  be  recognized  to  the  extent  that  the  estimated  fair  value  of  the
reporting unit is less than its carrying amount.  However, any loss recognized would not exceed the total amount of goodwill
allocated to that reporting unit. 

Contingent Consideration

The  Company  initially  recorded  the  contingent  consideration  related  to  future  potential  payments  based  upon  the
achievement of certain development, regulatory and commercial milestones, resulting from the acquisition of Confluence, at
its estimated fair value on the date of acquisition.  Changes in fair value reflect new information about the likelihood of the
payment  of  the  contingent  consideration  and  the  passage  of  time.    Future  changes  in  the  fair  value  of  the  contingent
consideration, if any, will be recorded as income or expense in the Company’s consolidated statement of operations. 

Segment Data

The  Company  operates  in  two  segments,  dermatology  therapeutics  and  contract  research,  for  the  purposes  of
assessing  performance  and  making  operating  decisions.  The  Company’s  dermatology  therapeutics  segment,  which  has  not
generated  any  revenue  to  date,  is  focused  on  identifying,  developing  and  commercializing  innovative  and  differentiated
therapies  to  address  significant  unmet  needs  in  medical  and  aesthetic  dermatology  and  immunology.    The  Company’s
contract  research  segment  is  focused  on  providing  laboratory  services  under  contract  research  arrangements  to
pharmaceutical and biotech companies looking to supplement their research and development efforts with difficult-to-execute
specialty skills and programs. 

101

 
 
 
 
 
 
 
 
 
 
Table of Contents

Recently Issued and Adopted Accounting Pronouncements

In  January  2017,  the  Financial  Accounting  Standards  Board  (“FASB”)  issued  Accounting  Standards  Update
(“ASU”) 2017-01, Business Combinations-Clarifying the Definition of a Business (Topic 805).  The amendments in this ASU
provide a screen to determine when a set of acquired assets and/or activities is not a business.  The screen requires that when
substantially all of the fair value of the gross assets acquired, or disposed of, is concentrated in a single identifiable asset or a
group  of  similar  identifiable  assets,  the  set  is  not  a  business.    The  amendments  in  this  ASU  will  reduce  the  number  of
transactions  that  meet  the  definition  of  a  business.   ASU  2017-01  is  effective  for  annual  reporting  periods  beginning  after
December 15, 2017, including interim periods within those years, and early adoption is permitted.  The Company is assessing
the potential impact of ASU 2017-01 on its consolidated financial statements. 

In January 2017, the FASB issued ASU 2017-04, Intangibles-Goodwill and Other-Simplifying the Test for Goodwill
Impairment  (Topic  350).    Under  the  amendments  in  this  ASU,  an  entity  should  perform  its  annual,  or  interim,  goodwill
impairment  test  by  comparing  the  fair  value  of  a  reporting  unit  with  its  carrying  amount.   An  entity  should  recognize  an
impairment charge for the amount by which the carrying amount exceeds the reporting unit’s fair value; however, the loss
recognized should not exceed the total amount of goodwill allocated to that reporting unit.  The amendments in this ASU
eliminate Step 2 from the goodwill impairment test.  ASU 2017-04 is effective for fiscal years beginning after December 15,
2019, and early adoption is permitted.  The Company adopted the provisions of this standard early, the impact of which on its
consolidated financial statements was not significant. 

In  June  2016,  the  FASB  issued  ASU  2016-13,  Financial  Instruments-Credit  Losses  (Topic  326).    This  ASU
introduces  a  new  model  for  recognizing  credit  losses  on  financial  instruments  based  upon  estimated  expected  credit
losses.  ASU 2016-13 will apply to loans, accounts receivable, financial assets measured at amortized cost and at fair value
through  other  comprehensive  income,  loan  commitments  and  certain  off-balance  sheet  credit  exposures.   ASU  2016-13  is
effective for annual reporting periods beginning after December 15, 2019, including interim periods within those years, and
early adoption is permitted.  The Company is assessing the potential impact of ASU 2016-13 on its consolidated financial
statements. 

In  May  2014,  the  FASB  issued  ASU  2014-09,  Revenue  from  Contracts  with  Customers (Topic  606).    Under  this
ASU, entities should recognize revenue in an amount that reflects the consideration to which they expect to be entitled to in
exchange for goods and services provided.  ASU 2014-09 is effective for annual reporting periods beginning after December
15, 2017.  The Company is assessing the potential impact of ASU 2014-09 on its consolidated financial statements. 

In March 2016, the FASB issued ASU 2016-09, Improvements to Employee Share-Based Payment Accounting.  This
ASU requires all tax effects of share-based payment settlements to be recorded through the income statement.  Currently, tax
benefits  in  excess  of  compensation  cost,  or  “windfalls”,  are  recorded  in  equity,  and  tax  deficiencies,  or  “shortfalls”,  are
recorded to equity to the extent of previous windfalls, and then to the income statement.  In addition, under the new guidance,
companies will be permitted to make a policy election to recognize the impact of forfeitures either when they occur, or on an
estimated basis.  Finally, this update simplifies withholding requirements to allow companies to withhold up to an employee’s
maximum tax rate without resulting in liability classification for the award.  ASU 2016-09 was effective for annual reporting
periods beginning after December 15, 2016.  The Company adopted the provisions of this standard early, the impact of which
on its consolidated financial statements was not significant. 

In February 2016, the FASB issued ASU 2016-02, Leases (Topic 842).  The new standard establishes a right-of-use
(“ROU”) model that requires a lessee to record a ROU asset and a lease liability on the balance sheet for all leases with terms
longer than 12 months.  Leases will be classified as either finance or operating, with classification affecting the pattern of
expense  recognition  in  the  income  statement.   ASU  2016-02  is  effective  for  annual  periods  beginning  after  December  15,
2018,  including  interim  periods  within  those  annual  periods,  with  early  adoption  permitted.    A  modified  retrospective
transition approach is required for lessees for capital and operating leases existing at, or entered into after, the beginning of
the  earliest  comparative  period  presented  in  the  financial  statements,  with  certain  practical  expedients  available.    The
Company is currently evaluating the potential impact of the adoption of this standard.

102

 
 
 
 
 
 
 
 
Table of Contents

In January 2016, the FASB issued ASU 2016-01, Recognition and Measurement of Financial Assets and Financial
Liabilities.    The  amendments  in  this  update  revise  the  accounting  related  to  the  classification  and  measurement  of
investments  in  equity  securities  and  the  presentation  of  certain  fair  value  changes  for  financial  liabilities  measured  at  fair
value.    The  amendments  are  effective  for  annual  reporting  periods  beginning  after  December  15,  2017,  including  interim
periods within those fiscal years.  Early adoption is permitted.  The Company is currently evaluating the potential impact of
the adoption of this standard. 

In  November  2015,  the  FASB  issued  ASU  2015-  17,  Balance  Sheet  Classification  of  Deferred  Taxes.    The
amendments in this update simplify the presentation of deferred income taxes to require that deferred tax liabilities and assets
are classified as noncurrent in a statement of financial position.  The amendments are effective for annual reporting periods
beginning  after  December  15,  2016  and  interim  reporting  periods  within  those  annual  periods.    Early  application  is
permitted.  The  Company  adopted  the  provisions  of  this  standard  early,  the  impact  of  which  on  its  consolidated  financial
statements was not significant. 

3. Confluence Acquisition

In  August  2017,  the  Company  entered  into  an  Agreement  and  Plan  of  Merger  with  Confluence,  Aclaris  Life
Sciences,  Inc.,  a  Delaware  corporation  and  wholly-owned  subsidiary  of  the  Company  (the  “Merger  Sub”),  and  Fortis
Advisors LLC, as representative of the holders of Confluence equity (the “Agreement and Plan of Merger”).  Pursuant to the
terms of the Agreement and Plan of Merger, the Merger Sub merged with and into Confluence, with Confluence surviving as
a  wholly-owned  subsidiary  of  the  Company,  resulting  in  the  Company’s  acquisition  of  100%  of  the  outstanding  shares  of
Confluence.  Pursuant to the terms of the Agreement and Plan of Merger, the Company gave aggregate consideration with a
fair value of $24,322 to the equity holders of Confluence, subject to a post-closing working capital adjustment. Confluence
was  a  privately  held  biotechnology  company  focused  on  the  discovery  and  development  of  kinase  inhibitors  to  treat
inflammatory and immunological disorders and cancer.  Confluence also provided laboratory services under contract research
arrangements to pharmaceutical and biotechnology companies looking to supplement their research and development efforts
with  difficult-to-execute  specialty  skills  and  programs.    The  acquisition  of  Confluence  has  added  small  molecule  drug
discovery  and  preclinical  development  capabilities,  which  has  allowed  the  Company  to  bring  early-stage  research  and
development activities in-house that were previously outsourced to third parties. 

The Company also agreed to pay the Confluence equity holders contingent consideration of up to $80,000, based
upon the achievement of certain development, regulatory and commercial milestones set forth in the Agreement and Plan of
Merger.    Of  the  contingent  consideration,  $2,500  may  be  paid  in  shares  of  the  Company’s  common  stock  upon  the
achievement  of  a  specified  development  milestone.    In  addition,  the  Company  has  agreed  to  pay  the  Confluence  equity
holders specified future royalty payments calculated as a low single-digit percentage of annual net sales, subject to specified
reductions,  limitations  and  other  adjustments,  until  the  date  that  all  of  the  patent  rights  for  that  product  have  expired,  as
determined  on  a  country-by-country  and  product-by-product  basis  or,  in  specified  circumstances,  ten  years  from  the  first
commercial  sale  of  such  product.    In  addition,  if  the  Company  sells,  licenses  or  transfers  any  of  the  intellectual  property
acquired from Confluence pursuant to the Agreement and Plan of Merger to a third party, the Company will be obligated to
pay the Confluence equity holders a portion of any incremental consideration (in excess of the development and milestone
payments described above) that the Company receives from such sales, licenses or transfers in specified circumstances. 

The following table summarizes the fair value of total consideration given to the Confluence equity holders pursuant

to the Agreement and Plan of Merger: 

Cash consideration paid
Aclaris common stock issued
Contingent consideration

Total fair value of consideration to Confluence equity holders

The Company funded the acquisition and transaction expenses with cash on hand. 

$

$

10,269
9,675
4,378
24,322

103

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

The  Company  accounted  for  this  transaction  as  a  business  combination  using  the  acquisition  method  of
accounting.  Under the acquisition method of accounting, the assets acquired and liabilities assumed in this transaction were
recorded at their respective fair values on the date of acquisition using assumptions that are subject to change. The Company
expects to finalize its allocation of the purchase price upon the finalization of valuations for the identified intangible assets,
final resolution of the post-closing working capital adjustment and certain tax accounts that are based on the best estimates of
management. The completion and filing of federal and state tax returns for the acquired entity may result in adjustments to
the carrying value of assets and liabilities. 

The  following  table  summarizes  the  preliminary  fair  value  of  assets  acquired  and  liabilities  assumed  in  the

acquisition of Confluence as of the acquisition date: 

Cash and cash equivalents
Accounts receivable, net
Other current assets
Property and equipment
Other intangible assets
IPR&D
Goodwill

Total assets acquired

Accounts payable and accrued expenses
Deferred tax liability
Other liabilities

Total liabilities assumed

Total net assets acquired

$

622
574
89
268
751
6,629
18,504
27,437

656
2,386
73
3,115

$

24,322

The  estimated  fair  value  of  the  IPR&D,  and  other  identified  intangibles,  acquired  was  determined  using  a
replacement cost method, which estimates the cost that would be required to rebuild the intangible assets identified in the
acquisition of Confluence.  The acquisition of Confluence resulted in the recognition of goodwill in the amount of $18,504
which  represents  the  value  of  new  products  and  technologies  to  be  developed  in  the  future  as  well  as  the  value  of  the
employee workforce acquired. 

The  following  supplemental  unaudited  pro  forma  information  presents  the  Company’s  financial  results,  for  the
periods  presented,  as  if  the  acquisition  of  Confluence  had  occurred  on  January  1,  2015.   This  supplemental  unaudited  pro
forma financial information has been prepared for comparative purposes only, and is not necessarily indicative of what actual
results would have been had the acquisition of Confluence occurred on January 1, 2015, nor is this information indicative of
future results. 

Revenue
Gross profit
Total operating expenses
Net loss

Year Ended
December 31, 
2016

2017

2015

    $

4,365     $
1,347  
73,810  
(70,391) 

3,693     $
1,652  
51,277  
(49,148) 

2,630  
1,302  
  24,151  
  (22,803) 

The  supplemental  unaudited  pro  forma  financial  results  for  the  year  ended  December  31,  2017  includes  an
adjustment to exclude $1,351 of acquisition-related expenses, as well as $888 to exclude revenue billed to the Company by
Confluence.  The supplemental unaudited pro forma financial results for the year ended December 31, 2017 also includes an
adjustment for amortization expense related to the other intangible assets acquired. 

104

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

There were no acquisition-related expenses incurred, or revenue billed to the Company by Confluence, for the years
ended December 31, 2016 and 2015, and accordingly, no adjustments are necessary for these items in the supplemental pro
forma financial results for those years.  The supplemental unaudited pro forma financial results for the years ended December
31, 2016 and 2015 includes an adjustment for amortization expense related to the other intangible assets acquired. 

4. Fair Value of Financial Assets and Liabilities

The following tables present information about the fair value measurements of the Company’s financial assets and
liabilities which are measured at fair value on a recurring basis, and indicate the level of the fair value hierarchy utilized to
determine such fair values:

Assets:

Cash equivalents
Marketable securities

Total Assets

Liabilities:

     Level 1     

Level 2

     Level 3     

Total

December 31, 2017

  $ 19,339   $

 —   $

 —  

  188,652  

  $ 19,339   $ 188,652   $

 —   $ 19,339  
 —  
  188,652  
 —   $ 207,991  

Acquisition-related contingent consideration

Total liabilities

$
  $

 — $
 —   $

 — $ 4,378
$
 —   $ 4,378   $

4,378
4,378  

Assets:

Cash equivalents
Marketable securities

Total

     Level 1     

Level 2

     Level 3     

Total

December 31, 2016

  $ 11,522   $ 12,691   $

 —  

  143,963  

  $ 11,522   $ 156,654   $

 —   $ 24,213  
 —  
  143,963  
 —   $ 168,176  

As  of  December  31,  2017  and  2016,  the  Company’s  cash  equivalents  consisted  of  investments  with  maturities  of
less  than  three  months  and  included  a  money  market  fund  which  was  valued  based  upon  Level  1  inputs,  and  commercial
paper and corporate debt securities which were valued based upon Level 2 inputs.  In determining the fair value of its Level 2
investments the Company relied on quoted prices for identical securities in markets that are not active. These quoted prices
were  obtained  by  the  Company  with  the  assistance  of  a  third‑party  pricing  service  based  on  available  trade,  bid  and  other
observable  market  data  for  identical  securities.  Quarterly,  the  Company  compares  the  quoted  prices  obtained  from  the
third‑party  pricing  service  to  other  available  independent  pricing  information  to  validate  the  reasonableness  of  the  quoted
prices  provided.  The  Company  evaluates  whether  adjustments  to  third-party  pricing  is  necessary  and,  historically,  the
Company has not made adjustments to quoted prices obtained from the third-party pricing service.  During the years ended
December 31, 2017 and 2016, there were no transfers between Level 1, Level 2 and Level 3. 

As of December 31, 2017 and 2016, the fair value of the Company’s available-for-sale marketable securities by type

of security was as follows:

December 31, 2017
Gross
Gross
  Amortized   Unrealized   Unrealized  
Gain

Loss

Cost

Fair
Value

Marketable securities:

Corporate debt securities
Commercial paper
Asset-backed securities
U.S. government agency debt securities

Total marketable securities

  $ 37,401   $

85,202  
16,708  
  49,511  
  $ 188,822   $

 —   $
 —  
 —  
 —  
 —   $

(68)  $ 37,333  
85,202  
 —  
16,695  
(13) 
(89) 
  49,422  
(170)  $ 188,652  

105

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
          
          
          
          
 
 
 
 
 
 
 
  
 
  
 
  
 
  
 
 
 
  
 
  
 
  
 
  
 
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
          
          
          
          
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
           
          
          
          
 
 
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

December 31, 2016
Gross
Gross
  Amortized   Unrealized   Unrealized  
Gain

Loss

Cost

Fair
Value

Marketable securities:

Corporate debt securities
Commercial paper
Asset-backed securities
U.S. government agency debt securities

Total marketable securities

5. Property and Equipment, Net

Property and equipment, net consisted of the following:

  $ 51,352   $

20,463  
28,692  
43,505  

  $ 144,012   $

 —   $
 —  
 6  
 8  
14   $

(59)  $ 51,293  
20,463  
 —  
28,697  
(1) 
43,510  
(3) 
(63)  $ 143,963  

Computer equipment
Manufacturing equipment
Lab equipment
Furniture and fixtures
Leasehold improvements
Property and equipment, gross
Accumulated depreciation
Property and equipment, net

December 31, 

2017

2016

    $

650     $
511  
721  
327  
430  
2,639  
(480) 

  $ 2,159   $

310  
149  
 —  
115  
33  
607  
(126) 
481  

Depreciation  expense  was  $370,  $120  and  $90  for  the  years  ended  December  31,  2017,  2016  and  2015,

respectively. 

6. Accrued Expenses

Accrued expenses consisted of the following:

Employee compensation expenses
Research and development expenses
Payable to NST
Vixen contract payable
Capital leases, current portion
Other

Total accrued expenses

December 31, 

2017

2016

  $ 3,010   $ 1,732  
1,166  
 —  
100  
 —  
380  
  $ 4,940   $ 3,378  

627  
590  
100  
142  
471  

106

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
           
          
          
          
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

7. Stockholders’ Equity

Preferred Stock

As of December 31, 2017 and 2016, the Company’s amended and restated certificate of incorporation authorized the
Company to issue 10,000,000 shares of undesignated preferred stock.  There were no shares of preferred stock outstanding as
of December 31, 2017 and 2016.

The  Company  previously  issued  Series  A,  Series  B  and  Series  C  convertible  preferred  stock  (collectively,  the
“Preferred Stock”).  Through August 28, 2015, the Company had issued an aggregate of 11,677,076 shares of Preferred Stock
in the Series A, Series B and Series C offerings.  Upon the closing of the Company’s IPO in October 2015, all of the then
outstanding Preferred Stock was converted into an aggregate total of 11,677,076 shares of common stock.  Also in connection
with  the  IPO,  the  Company  amended  and  restated  its  certificate  of  incorporation  and  authorized  10,000,000  shares  of
undesignated preferred stock.

Common Stock

As of December 31, 2017 and 2016, the Company’s certificate of incorporation, as amended and restated, authorized

the Company to issue 100,000,000 shares of $0.00001 par value common stock.

Each  share  of  common  stock  entitles  the  holder  to  one  vote  on  all  matters  submitted  to  a  vote  of  the  Company’s
stockholders. Common stockholders are entitled to receive dividends, as may be declared by the board of directors, if any,
subject to any preferential dividend rights of any series of preferred stock that may be outstanding.  No dividends have been
declared through December 31, 2017.

Restricted Common Stock

In  July  2012,  the  Company  issued  2,730,427  shares  of  restricted  common  stock  with  time-based  vesting  to  its
founders in connection with the formation of the Company.  Unvested shares of restricted common stock could not be sold or
transferred  by  the  holders  of  those  shares.    Of  the  shares  issued  in  July  2012,  1,918,834  shares  were  subject  to  vesting
pursuant  to  restricted  stock  agreements  with  25%  vesting  in  July  2013  and  the  remaining  75%  vesting  in  equal  monthly
installments over a three-year period thereafter.  Upon the Company’s IPO in October 2015, all remaining unvested shares of
restricted common stock vested immediately.  The estimated grant‑date fair value of the restricted common stock issued was
$0.00001 per share, equal to the par value of each share issued.  The aggregate fair value of restricted common stock that
vested during the years ended December 31, 2017, 2016 and 2015 was $0, $0 and $6,423, respectively.  As of December 31,
2017 and 2016, no shares were subject to repurchase. 

Initial Public Offering

In  October  2015,  the  Company’s  registration  statement  on  Form  S-1  relating  to  its  initial  public  offering  of  its
common stock (the “IPO”) was declared effective by the Securities and Exchange Commission (“SEC”).  The Company’s
common stock began trading on the Nasdaq Global Select Market on October 7, 2015.  The IPO closed on October 13, 2015,
and 5,000,000 shares of common stock were sold at a price to the public of $11.00 per share, for aggregate gross proceeds of
$55,000.    In  addition,  upon  the  closing  of  the  IPO,  all  of  the  Company’s  outstanding  convertible  preferred  stock  was
converted into an aggregate total of 11,677,076 shares of common stock.  The conversion of the convertible preferred stock
was a non-cash transaction which has been excluded from the Consolidated Statements of Cash Flows. 

On October 12, 2015, the underwriters of the IPO exercised in full their option to purchase additional shares, and on
October 13, 2015, the Company sold 750,000 additional shares of common stock at a price to the public of $11.00 per share,
for aggregate gross proceeds of $8,250.

The Company paid underwriting discounts and commissions of $4,428 to the underwriters in connection with the
IPO, including the underwriters’ exercise of their option to purchase additional shares.  In addition, the Company incurred
expenses  of  $2,272  in  connection  with  the  IPO.    The  net  offering  proceeds  received  by  the  Company,  after  deducting
underwriting discounts, commissions and offering expenses, were $56,550.

107

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Private Placement

In June 2016, pursuant to a securities purchase agreement with certain accredited investors dated May 27, 2016, the
Company closed a private placement in which it sold an aggregate of 1,081,082 shares of common stock at a price of $18.50
per share, for gross proceeds of $20,000.  The Company incurred placement agent fees of $1,300 and expenses of $153 in
connection with the private placement.  The net offering proceeds received by the Company, after deducting placement agent
fees and transaction expenses, were $18,547.

November 2016 Public Offering

In  November  2016,  the  Company’s  registration  statement  on  Form  S-3  was  declared  effective  by  the  SEC.    On
November 23, 2016, the Company closed a follow-on public offering in which 4,000,000 shares of common stock were sold
to  the  public  at  a  price  of  $22.75  per  share,  for  gross  proceeds  of  $91,000.    On  November  17,  2016,  the  underwriters
exercised in full their option to purchase 600,000 additional shares of common stock at a price to the public of $22.75 per
share, for gross proceeds of $13,650. 

The Company paid underwriting discounts and commissions of $6,279 to the underwriters in connection with the
offering,  including  the  underwriters’  exercise  of  their  option  to  purchase  additional  shares.    In  addition,  the  Company
incurred  expenses  of  $188  in  connection  with  the  offering.    The  net  offering  proceeds  received  by  the  Company,  after
deducting underwriting discounts, commissions and offering expenses, were $98,158.

At-The-Market Equity Offering 

In November 2016, the Company entered into an at-the-market sales agreement with Cowen and Company, LLC to
sell the Company’s securities under the Company’s registration statement on Form S-3.  During the year ended December 31,
2017, the Company issued 635,000 shares of common stock under the at-the-market sales agreement.  As of December 31,
2017,  the  Company  had  issued  and  sold  an  aggregate  of  635,000  shares  of  common  stock  under  the  at-the-market  sales
agreement at a weighted average price per share of $31.50, for aggregate gross proceeds of $20,003.  The Company incurred
expenses of $691 in connection with the shares issued under the at-the-market sales agreement.    

August 2017 Public Offering

In August 2017, the Company entered into an underwriting agreement pursuant to which the Company issued and
sold 3,747,602 shares of common stock under the Company’s registration statement on Form S-3, including the underwriters’
partial exercise of their option to purchase additional shares.  The shares of common stock were sold to the public at a price
of $23.02 per share, for gross proceeds of $86,270. 

The Company paid underwriting discounts and commissions of $5,176 to the underwriters in connection with the
offering.  In addition, the Company incurred expenses of $176 in connection with the offering.  The net offering proceeds
received by the Company, after deducting underwriting discounts and commissions and offering expenses, were $80,918. 

8. Stock‑Based Awards

2017 Inducement Plan

In  July  2017,  the  Company’s  board  of  directors  adopted  the  2017  Inducement  Plan  (the  “2017  Inducement
Plan”).  The 2017 Inducement Plan is a non-shareholder approved stock plan adopted pursuant to the “inducement exception”
provided under Nasdaq listing rules.  The only employees eligible to receive grants of awards under the 2017 Inducement
Plan are individuals who satisfy the standards for inducement grants under Nasdaq rules, generally including individuals who
were not previously an employee or director of the Company. Under the terms of the 2017 Inducement Plan the Company
may  grant  up  to  1,000,000  shares  of  common  stock  pursuant  to  nonqualified  stock  options,  stock  appreciation  rights,
restricted stock awards, RSUs, and other stock awards.  The shares of common stock underlying any awards that expire, or
are otherwise terminated, settled in cash or repurchased by the Company under the 2017 Inducement Plan will be added back
to the shares of common stock available for issuance under the 2017 Inducement Plan.  As of December 31, 2017, 489,884
shares of common stock were available for grant under the 2017 Inducement Plan. 

108

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

2015 Equity Incentive Plan

In September 2015, the Company’s board of directors adopted the 2015 Equity Incentive Plan (the “2015 Plan”),
and the Company’s stockholders approved the 2015 Plan.  The 2015 Plan became effective in connection with the Company’s
IPO.    Beginning  at  the  time  the  2015  Plan  became  effective,  no  further  grants  may  be  made  under  the  Company’s  2012
Equity Compensation Plan, as amended and restated (the “2012 Plan”).  The 2015 Plan provides for the grant of incentive
stock options, nonqualified stock options, stock appreciation rights, restricted stock awards, RSU awards, performance stock
awards, cash-based awards and other stock-based awards. The number of shares initially reserved for issuance under the 2015
Plan was 1,643,872 shares of common stock. The number of shares of common stock that may be issued under the 2015 Plan
will automatically increase on January 1 of each year, beginning on January 1, 2016 and ending on January 1, 2025, in an
amount  equal  to  the  lesser  of  (i)  4.0%  of  the  shares  of  the  Company’s  common  stock  outstanding  on  December  31  of  the
preceding  calendar  year  or  (ii)  an  amount  determined  by  the  Company’s  board  of  directors.  The  shares  of  common  stock
underlying any awards that expire, are otherwise terminated, settled in cash or repurchased by the Company under the 2015
Plan and the 2012 Plan will be added back to the shares of common stock available for issuance under the 2015 Plan.  As of
December 31, 2017, 1,404,498 shares remained available for grant under the 2015 Plan.  As of January 1, 2018, the number
of shares of common stock that may be issued under the 2015 Plan was automatically increased by 1,234,260 shares.

2012 Equity Compensation Plan

Upon the 2015 Plan becoming effective, no further grants can be made under the 2012 Plan.  The Company granted
a total of 1,140,524 stock options under the 2012 Plan, of which 984,720 and 1,049,667 were outstanding as of December 31,
2017, and 2016, respectively.  Stock options granted under the 2012 Plan vest over four years and expire after ten years.  As
required, the exercise price for the stock options granted under the 2012 Plan was not less than the fair value of common
shares as determined by the Company as of the date of grant. 

Stock Option Valuation

The weighted average assumptions the Company used to estimate the fair value of stock options granted during the

years ended December 31, 2017, 2016 and 2015 were as follows:

Risk-free interest rate
Expected term (in years)
Expected volatility
Expected dividend yield

Year Ended
December 31, 
2016

2017

2015

1.93 % 
6.2  
94.19 % 
 0 % 

2.06 % 
6.5  
94.86 % 
 0 % 

1.78 % 
6.3  
93.90 % 
 0 % 

The Company recognizes compensation expense for awards over their vesting period.  Compensation expense for

awards includes the impact of forfeiture in the period when they occur. 

109

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
Table of Contents

Stock Options

The following table summarizes stock option activity for the years ended December 31, 2017, 2016 and 2015:

     Weighted       

Number
of Shares

Price

  Weighted   Average
  Average
  Exercise

  Remaining   Aggregate  
  Contractual  
Term
(in years)

Intrinsic
Value

Outstanding as of December 31, 2014

Granted
Exercised
Forfeited and canceled

Outstanding as of December 31, 2015

Granted
Exercised
Forfeited and canceled

Outstanding as of December 31, 2016

Granted
Exercised
Forfeited and cancelled

Outstanding as of December 31, 2017
Options vested and expected to vest as of December 31, 2017
Options exercisable as of December 31, 2017

500,262   $

  1,238,262  
 —  
 —  
  1,738,524  
  1,083,919  
(51,980) 
(68,113) 
2,702,350   $
790,100  
(36,738) 
(126,955) 
3,328,757   $
3,328,757   $
1,239,736
$

(1)

1.22  
18.08  
 —  
 —  
13.23  
27.12  
 —  
 —  
18.94  
26.21  
6.40  
22.05  
20.69  
20.69  
15.56  

9.77   $

305  

9.51  

  24,722  

9.05   $ 24,434  

8.28   $ 19,812  
8.28   $ 19,812  
7.43   $ 13,414  

(1) All  options  granted  under  the  2012  Plan  are  exercisable  immediately,  subject  to  a  repurchase  right  in  the  Company’s
favor  that  lapses  as  the  option  vests.  This  amount  reflects  the  number  of  shares  under  options  that  were  vested,  as
opposed to exercisable, as of December 31, 2017.

The  weighted  average  grant  date  fair  value  of  stock  options  granted  during  the  years  ended  December  31,  2017,

2016 and 2015 was $20.28, $21.16 and $13.84 per share, respectively.

The intrinsic value of a stock option is calculated as the difference between the exercise price of the stock option and

the fair value of the underlying common stock, and cannot be less than zero. 

110

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
      
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
   
 
 
  
 
   
 
 
  
 
   
 
 
  
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
 
 
 
 
   
 
 
 
 
 
   
 
 
 
 
 
   
 
 
 
 
 
 
 
 
Table of Contents

Restricted Stock Units

The following table summarizes RSU activity for the years ended December 31, 2017, 2016 and 2015. 

Outstanding as of December 31, 2014

Granted
Vested
Forfeited and cancelled

Outstanding as of December 31, 2015

Granted
Vested
Forfeited and cancelled

Outstanding as of December 31, 2016

Granted
Vested
Forfeited and cancelled

Outstanding as of December 31, 2017

Stock‑Based Compensation

Weighted

Average
Grant Date  
Fair Value

Per Share

28.68  

28.68  
27.16  
28.68  
28.68  
27.43  
26.27  
26.89  
27.53  
27.02  

Number  
of Shares  
 —  
53,800   $
 —  
 —  
53,800  
180,764  
(12,950) 
(2,000) 
219,614   $
117,883  
(40,705) 
(13,239) 
283,553   $

The following table summarizes stock-based compensation expense recorded by the Company for the years ended

December 31, 2017, 2016 and 2015:

Year Ended
December 31, 

2017

2016

2015

Cost of revenue
Research and development
General and administrative

Total stock-based compensation expense

   $

211      $

 —  $
  2,291   
  3,813   
  $ 14,430   $ 6,104  $

5,471  
8,748  

 —  
257  
634  
891  

As of December 31, 2017, the Company had unrecognized stock‑based compensation expense for stock options and
RSUs of $36,150 and $5,849, respectively, which is expected to be recognized over weighted average periods of 2.93 years
and 2.93 years, respectively. 

111

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
     
     
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
Table of Contents

9. Net Loss per Share

Basic and diluted net loss per share attributable to common stockholders was calculated as follows:

Numerator:
Net loss
Accretion of redeemable convertible preferred stock

Net loss attributable to common stockholders

Denominator:

Weighted average shares of common stock outstanding
Less: Weighted average shares of unvested restricted common stock
outstanding

Weighted average common shares outstanding used in calculating net
loss per share attributable to common stockholders, basic and diluted
Net loss per share attributable to common stockholders, basic and diluted

Year Ended
December 31, 
2016

2017

2015

 $

 $

(68,523)  $
 —  
(68,523)  $

(48,079)  $
 —  
(48,079)  $

(20,563) 
(2,566) 
(23,129) 

   28,102,386  

  21,415,733  

  6,637,678  

 —  

 —  

(530,636) 

   28,102,386  
 $

(2.44)  $

  21,415,733  

  6,107,042  
(3.79) 

(2.25)  $

To  calculate  net  loss  attributable  to  common  stockholders  the  Company  reduced  the  net  loss  for  the  accretion  of
issuance  costs  and  cumulative  dividends  accrued  but  not  paid  through  August  28,  2015,  and  the  remaining  cumulative
dividends  accrued  but  not  paid  through  October  13,  2015,  the  date  on  which  all  convertible  preferred  stock  converted  to
common stock.

The  Company’s  potential  dilutive  securities,  which  included  stock  options,  RSUs,  preferred  stock,  and  shares  of
restricted common stock that were issued but not yet vested, have been excluded from the computation of diluted net loss per
share since the effect would be to reduce the net loss per share. Therefore, the weighted average number of common shares
outstanding used to calculate both basic and diluted net loss per share attributable to common stockholders is the same. The
following table presents potential common shares excluded from the calculation of diluted net loss per share attributable to
common  stockholders  for  the  years  ended  December  31,  2017,  2016  and  2015.   All  share  amounts  presented  in  the  table
below represent the total number outstanding as of December 31.

Options to purchase common stock
Restricted stock unit awards

Total potential common shares

10. Commitments and Contingencies

Agreements for Office Space

Year Ended
December 31, 
2016

2015

2017

  3,328,757  
283,553  
  3,612,310  

2,702,350      1,738,524  
53,800  
2,921,964   1,792,324  

219,614  

In  November  2017,  the  Company  entered  into  a  sublease  agreement  with  a  third  party.    The  Company  subleases
33,019 square feet of office space under the terms of the agreement for its headquarters in Wayne, Pennsylvania.  Subject to
the  consent  of  Chesterbrook  Partners,  LP  (“Landlord”)  as  set  forth  in  the  lease  by  and  between  them  and  Auxilium
Pharmaceuticals, LLC (“Sublandlord”), the sublease has a term that runs through October 2023.  If for any reason the lease
between  the  Landlord  and  Sublandlord  is  terminated  or  expires  prior  to  October  2023,  the  Company’s  sublease  will
automatically terminate. 

In November 2016, the Company entered into a lease agreement with a third party for additional office space in the
Malvern, Pennsylvania with a term beginning in February 2017, and ending in November 2019.  The Company also occupies
office and laboratory space in St. Louis, Missouri under the terms of an agreement which it entered into in January 2018 and
which expires in December 2018. 

112

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
      
          
          
 
  
 
 
  
  
 
  
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
Table of Contents

Rent expense was $946, $254 and $119 for the years ended December 31, 2017, 2016 and 2015, respectively. The
Company recognizes rent expense on a straight-line basis over the term of the agreement and has accrued for rent expense
incurred but not yet paid. 

As of December 31, 2017, future minimum lease payments under the sublease were as follows:

Year Ending December 31, 
2018
2019
2020
2021
2022
Thereafter
Total

  $

  $

664  
627  
589  
605  
622  
532  
3,639  

Capital Leases for Laboratory Equipment

The Company leases laboratory equipment which is used in its laboratory space in St. Louis, Missouri under two
capital lease financing arrangements which the Company entered into in August 2017 and October 2017.  The capital leases
have terms which end in October 2020 and December 2020. 

Stock Purchase Agreement with Vixen Pharmaceuticals, Inc

Pursuant to the stock purchase agreement with Vixen the Company is obligated to make annual payments of $100

on March 24  of each year, through March 2022, with such amounts being creditable against specified future payments. 

th

Indemnification Agreements

In  the  ordinary  course  of  business,  the  Company  may  provide  indemnification  of  varying  scope  and  terms  to
vendors, lessors, business partners and other parties with respect to certain matters including, but not limited to, losses arising
out  of  breach  of  such  agreements  or  from  intellectual  property  infringement  claims  made  by  third  parties.  In  addition,  the
Company has entered into indemnification agreements with members of its board of directors that will require the Company,
among other things, to indemnify them against certain liabilities that may arise by reason of their status or service as directors
or  officers.  The  maximum  potential  amount  of  future  payments  the  Company  could  be  required  to  make  under  these
indemnification agreements is, in many cases, unlimited. To date, the Company has not incurred any material costs as a result
of such indemnifications. The Company does not believe that the outcome of any claims under indemnification arrangements
will have a material effect on its financial position, results of operations or cash flows, and it has not accrued any liabilities
related to such obligations in its consolidated financial statements as of December 31, 2017 or 2016. 

113

 
 
 
 
 
 
 
        
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

11. Income Taxes

The Tax Cuts and Jobs Act (the "TCJA") was enacted on December 22, 2017 and became effective January 1, 2018.
The Tax Act made significant changes to U.S. tax law, including lowering U.S. corporate income tax rates, implementing a
territorial  tax  system,  imposing  a  one-time  transition  tax  on  deemed  repatriated  earnings  of  foreign  subsidiaries  and
modifying the taxation of other income and expense items.

The TCJA reduces the U.S. corporate income tax rate from 35% to 21%, effective January 1, 2018. Deferred tax
assets and liabilities are measured using enacted tax rates expected to apply to taxable income in the years in which those
temporary differences are expected to reverse. As a result of the reduction in the U.S. corporate income tax rate from 35% to
21%  under  the  TCJA,  the  Company  revalued  its  deferred  tax  liabilities,  net  as  of  December  31,  2017.    The  impact  of
revaluation of the deferred tax liabilities, net was $18,507 of income tax expense, which was more than offset by a reduction
in the valuation allowance of $20,344 resulting in a net impact of a $1,837 tax benefit.  The net tax benefit recorded was
primarily the result of tax law changes which impacted the deferred tax liability the Company recorded for IPR&D related to
the acquisition of Confluence.  Under GAAP, IPR&D is an indefinite lived intangible that is capitalized on the balance sheet,
but which does not have a cost basis under U.S. tax law. 

The  TCJA  provided  for  a  one-time  transition  tax  on  the  deemed  repatriation  of  post-1986  undistributed  foreign
subsidiary earnings and profits. The Company did not have consolidated accumulated earnings and profits attributable to its
foreign subsidiary; accordingly, the Company did not record any income tax expense related to the transition tax.  

Due to the timing of the enactment of the TCJA and the substantial changes it brings, the Staff of the SEC issued
SAB  118  which  provides  a  measurement  period  to  report  the  impact  of  the  TCJA.    During  the  measurement  period,
provisional amounts for the effects of the law are recorded to the extent a reasonable estimate can be made.  To the extent that
all information necessary is not available, prepared or analyzed, companies may recognize provisional estimated amounts for
a period of up to one year following enactment of the TCJA. 

During the years ended December 31, 2017, 2016 and 2015, the Company did not record an income tax benefit for

net operating losses incurred in each year due to the uncertainty of realizing a benefit from those items.

Loss before income taxes is allocated as follows:

Year Ended December 31,

U.S. operations
Foreign operations
Loss before income taxes

2017

2016
  $ (63,665)  $ (40,597)  $ (11,823) 
(8,740) 
  $ (70,353)  $ (48,079)  $ (20,563) 

(6,688) 

(7,482) 

2015

A  reconciliation  of  the  U.S.  federal  statutory  income  tax  rate  to  the  Company’s  effective  income  tax  rate  is  as

follows:

Federal statutory income tax rate

State taxes, net of federal benefit
Research and development tax credits
Permanent differences
Foreign rate differential
Change in deferred tax asset valuation allowance
Impact of U.S. tax reform

Effective income tax rate

114

Year Ended December 31,
2016
(34.0)%  
(5.2) 
(2.0) 
1.8  
3.2  
36.2  
 —  
 — %  

2017
(34.0)%  
(9.7) 
(1.1) 
0.4  
1.7  
17.4  
22.7  
(2.6)%  

2015
(34.0)%
(3.8) 
(1.5) 
 —  
6.0  
33.3  
 —  
 — %

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
    
 
 
 
 
 
 
 
 
 
Table of Contents

Deferred tax liabilities, net as of December 31, 2017 and 2016 consisted of the following:

Deferred tax assets:

Net operating loss carryforwards
Capitalized start up costs
Research and development tax credit carryforwards
Capitalized research and development expenses
Intangible asset
Stock‑based compensation expenses
Property and equipment
Other

Total deferred tax assets

Deferred tax liabilities:
     Section 481(a) adjustment

Intangible asset
Other

Total deferred tax liabilities

Valuation allowance

Deferred tax liabilities, net

$

$

December 31,

2017

2016

26,566   $ 16,836  
8,840  
9,940  
1,480  
2,296  
594  
3,595  
1,403  
 —  
2,629  
6,220  
199  
86  
 2  
280  
31,983  
48,983  

(498) 
(1,843) 
(313) 
(2,654) 
  (46,878) 

(549)  $

(1,257) 
 —  
 —  
(1,257) 
  (30,726) 
 —  

As  of  December  31,  2017,  the  Company  had  federal  and  state  net  operating  loss  carryforwards  of  $76,310  and
$117,808, respectively, which begin to expire in 2032.  As of December 31, 2017, the Company also had federal research and
development tax credit carryforwards of $2,202 which begin to expire in 2032, and state research and development tax credit
carryforwards  of  $118  which  begin  to  expire  in  2022.  The  Company  also  has  $1,292  of  loss  carry  forwards  in  the  United
Kingdom  which  can  be  carried  forward  indefinitely.  Utilization  of  the  net  operating  loss  carryforwards  and  research  and
development tax credit carryforwards in the United States may be subject to a substantial annual limitation under Section 382
of the Internal Revenue Code of 1986 due to ownership changes that may have occurred previously or that could occur in the
future. These ownership changes may limit the amount of carryforwards that can be utilized annually to offset future taxable
income. In general, an ownership change, as defined by Section 382, results from transactions increasing the ownership of
certain stockholders or public groups in the stock of a corporation by more than 50% over a three-year period. The Company
has completed an analysis under Section 382 for NOLs generated from July 13, 2012 through December 31, 2016. Although
the Company has experienced Section 382 ownership changes since 2012, the Company has concluded that it should have
sufficient ability to utilize NOLs accumulated during the periods tested. The Company has not yet determined if a Section
382 ownership change has occurred during the year ended December 31, 2017, or for Confluence prior to the acquisition. In
addition,  the  Company  may  experience  ownership  changes  in  the  future  as  a  result  of  subsequent  shifts  in  its  stock
ownership, some of which may be outside of the Company’s control. 

The Company has evaluated the positive and negative evidence bearing upon its ability to realize the deferred tax
assets. Management has considered the Company’s history of cumulative net losses incurred since inception and its lack of
commercialization of any products or generation of any revenue from product sales since inception and has concluded that it
is more likely than not that the Company will not realize the benefits of the deferred tax assets. Accordingly, a full valuation
allowance has been established against the deferred tax assets as of December 31, 2017 and 2016. The Company evaluates
positive and negative evidence of its’ ability to realize deferred tax assets at each reporting period. 

115

 
 
 
 
 
 
 
 
 
 
 
 
 
 
        
          
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Changes in the valuation allowance for deferred tax assets during the years ended December 31, 2017, 2016, and
2015  related  primarily  to  the  increases  in  net  operating  loss  carryforwards,  capitalized  start-up  costs,  and  research  and
development tax credit carryforwards and were as follows:

Valuation allowance at beginning of year

Decreases recorded as benefit to income tax provision
Increases resulting from the acquisition of Confluence
Increases recorded to income tax provision

Valuation allowance as of end of year

$

$

2017

Year Ended December 31,
2016

(30,726)     $ (13,286)    $

2015
(6,444) 
—  
—  
 —  
 —  
 —  
(4,176) 
(11,976) 
(6,842) 
(17,440) 
(46,878)  $ (30,726)  $ (13,286) 

During  the  year  ended  December  31,  2015,  the  Company  recorded  unrecognized  tax  benefits  in  the  amount  of
$4,400 related to start-up costs that were previously deducted beginning in the initial return filing period ended December 31,
2012.  During the year ended December 31, 2016, the Company filed a method of accounting change with the IRS related to
the  start-up  costs,  and  reversed  the  related  unrecognized  tax  position.    During  the  year  ended  December  31,  2017,  the
Company recorded uncertain tax benefits related to tax positions from the acquired Confluence business.  The following table
summarizes the changes in the Company’s unrecognized tax benefits:

Unrecognized tax benefits at beginning of year
Increases related to prior year tax provisions
Decreases related to prior year tax provisions
Increases related to current year tax provisions

Unrecognized tax benefits as of end of year

Year ended December 31,

2017

 —   $
(43)  
 —  
 —  
(43)   $

2016
(4,400)  $
 —  
4,400  
 —  
 —   $

2015

 —
(2,624)
 —
(1,776)
(4,400)

  $

  $

The total amount of unrecognized tax benefits that, if recognized, would impact the Company’s effective tax rate
were  $36  and  $0  as  of  December  31,  2017  and  2016,  respectively.  The  Company  accrues  interest  and  penalties  related  to
unrecognized tax benefits in income tax expense (benefit) in the consolidated statements of operations and comprehensive
loss.  During each of the years ended December 31, 2017, 2016 and 2015, the Company recognized expense (benefit) of $3,
$0 and $0, respectively, related to interest and penalties.

The Company files tax returns as prescribed by the tax laws of the jurisdictions in which it operates. In the normal
course  of  business,  the  Company  is  subject  to  examination  by  federal  and  state  jurisdictions,  where  applicable.  There  are
currently  no  pending  income  tax  examinations.  The  Company’s  tax  years  are  still  open  under  statute  from  2012  to  the
present. All open years may be examined to the extent that tax credit or net operating loss carryforwards are used in future
periods. The Company’s policy is to record interest and penalties related to income taxes as part of its income tax provision.

12. Related Party Transactions

In August 2013, the Company entered into a sublease agreement with NeXeption, Inc. ("NeXeption"), which was
subsequently amended and restated in March 2014 and further amended in December 2014.  In August 2015, pursuant to an
Assignment  and  Assumption  Agreement,  NeXeption,  Inc.  assigned  all  interests,  rights,  duties  and  obligations  under  the
sublease  to  NST  Consulting,  LLC,  a  wholly-owned  subsidiary  of  NST,  LLC.    Following  the  Assignment  and  Assumption
Agreement, the sublease was further amended in August 2015, February 2016, October 2016 and July 2017.  On November
30, 2017, the Company entered into an agreement with NST Consulting, LLC to terminate the sublease effective March 31,
2018.  The Company agreed to pay $590 to NST Consulting, LLC, which amount represents accelerated rent payments.  The
Company  recorded  a  one-time  charge  of  $506  in  the  year  ended  December  31,  2017  which  is  included  in  general  and
administrative  expenses  in  the  consolidated  statement  of  operations.    Total  payments  made  under  the  sublease  during  the
years ended December 31, 2017, 2016 and 2015, were $318, $253 and $127, respectively.

116

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

In February 2014, the Company entered into a services agreement with NST, LLC (the “NST Services Agreement”),
pursuant to which NST, LLC provided certain pharmaceutical development, management and other administrative services to
the  Company.    The  NST  Services  Agreement  was  amended  in  January  2015  pursuant  to  which  NST,  LLC  assigned  all
interests,  rights,  duties  and  obligations  under  the  NST  Services  Agreement  to  NST  Consulting,  LLC.    Under  the  NST
Services Agreement, as amended, the Company also provided services to another company under common control with the
Company and NST Consulting, LLC and was reimbursed by NST Consulting, LLC for those services.  The Company may
offset any payments owed by the Company to NST Consulting, LLC against payments that are owed by NST Consulting,
LLC  to  the  Company  for  the  provision  of  personnel,  including  consultants,  to  the  Company.    In  November  2017,  the
Company provided notice of termination of the NST Services Agreement to NST Consulting, LLC effective December 31,
2017. 

Mr. Stephen Tullman, the chairman of the Company’s board of directors, was an executive officer of NeXeption and
is  also  the  manager  of  NST  Consulting,  LLC  and  NST,  LLC,  and  three  of  the  Company’s  executive  officers  are  and  have
been members of entities affiliated with NST, LLC.    

During  the  years  ended  December  31,  2017,  2016  and  2015  amounts  included  in  the  consolidated  statement  of

operations for the NST Services Agreement are summarized in the following table:

Services provided by NST Consulting, LLC
Services provided to NST Consulting, LLC
General and administrative expense, net

Services provided by NST Consulting, LLC
Services provided to NST Consulting, LLC
Research and development expense, net

Services provided by NST Consulting, LLC
Services provided to NST Consulting, LLC

Total, net

Year Ended

December 31, 

2017

2016

2015

225   $
(17) 
208   $

 —   $
 —  
 —   $

323
(56)
267

246
(97)
149

225   $
(17) 
208   $

569
(153)
416

 $

 $

 $

 $

 $

 $

455  
(294) 
161  

52  
(259) 
(207) 

507  
(553) 
(46) 

  $

  $

  $

  $

  $

  $

Net payments made to (received from) NST Consulting, LLC

  $

300   $

325   $

(46) 

The  Company  had  a  net  amount  payable  of  $570  and  $91  due  to  NST  Consulting,  LLC  under  the  NST  Services

Agreement as of December 31, 2017, and December 31, 2016, respectively. 

13. Agreements Related to Intellectual Property

Assignment Agreement and Finder’s Services Agreement

In August 2012, the Company entered into an assignment agreement with the Estate of Mickey Miller (the “Miller
Estate”)  under  which  the  Company  acquired  some  of  the  intellectual  property  rights  covering  A-101.  The  assignment  of
intellectual property rights covers specified know-how, along with modifications of, improvements to and variations on A-
101 that meet defined chemical properties. Under the agreement, the Company has the sole and exclusive right, but not the
duty,  to  develop,  obtain  regulatory  approval  for  and  commercialize  A-101  in  various  countries  throughout  the  world.  The
Company is required to use commercially reasonable efforts to develop and commercialize at least one product for at least
one indication in the United States. In connection with obtaining the assignment of the intellectual property from the Miller
Estate, the Company also entered into a separate finder’s services agreement with KPT Consulting, LLC.

117

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
 
 
   
 
 
 
  
 
 
  
  
 
 
 
   
 
 
 
  
 
 
  
  
 
 
 
   
 
 
   
 
   
 
   
 
 
 
   
 
   
 
   
 
 
 
 
 
 
 
Table of Contents

Under  the  terms  of  the  assignment  agreement  and  the  finder’s  services  agreement,  the  Company  made  one-time
milestone payments of $400 in 2013 upon the dosing of the first human subject with ESKATA in the Company’s Phase 2
clinical  trial.  There  are  no  remaining  potential  milestone  payments  under  the  assignment  agreement.  Under  the  finder’s
services agreement, the Company made one-time milestone payments of $300 in the year ended December 31, 2016 upon the
dosing  of  the  first  human  subject  with  ESKATA  in  the  Company’s  Phase  3  clinical  trial  and  $1,000  in  the  year  ended
December 31, 2017 upon the achievement of specified regulatory milestones.  The Company is obligated to make additional
payments  of  up  to  $4,500  upon  the  achievement  of  specified  commercial  milestones  under  the  finder’s  services
agreement.    The  Company  recorded  both  milestone  payments  made  under  the  finder’s  services  agreement  as  general  and
administrative expense in the consolidated statement of operations.  Under each of the assignment agreement and the finder’s
services agreement, the Company is also obligated to pay royalties on sales of ESKATA or related products, at low single-
digit  percentages  of  net  sales,  subject  to  reduction  in  specified  circumstances.  The  Company  has  not  made  any  royalty
payments  to  date  under  either  agreement.  Both  agreements  will  terminate  upon  the  expiration  of  the  last  pending,  viable
patent claim of the patents acquired under the assignment agreement, but no sooner than 15 years from the effective date of
the agreements.

License Agreement with Rigel Pharmaceuticals, Inc.

In August 2015, the Company entered into an exclusive, worldwide license and collaboration agreement with Rigel
Pharmaceuticals, Inc. (“Rigel”) for the development and commercialization of products containing specified JAK inhibitors
developed  by  Rigel.    Under  this  agreement,  the  Company  intends  to  develop  these  JAK  inhibitors  for  the  treatment  of
alopecia areata and potentially for other dermatological conditions. During the year ended December 31, 2015, the Company
made  an  upfront  non-refundable  payment  of  $8,000  to  Rigel.    In  addition,  the  Company  has  agreed  to  make  aggregate
payments of up to $80,000 upon the achievement of specified pre‑commercialization milestones, such as clinical trials and
regulatory approvals. Further, the Company has agreed to pay up to an additional $10,000 to Rigel upon the achievement of a
second set of development milestones. With respect to any products the Company commercializes under the agreement, the
Company will pay Rigel quarterly tiered royalties on its annual net sales of each product at a high single‑digit percentage of
annual net sales, subject to specified reductions, until the date that all of the patent rights for that product have expired, as
determined on a country‑by‑country and product‑by‑product basis or, in specified countries under specified circumstances,
ten years from the first commercial sale of such product.

The agreement terminates on the date of expiration of all royalty obligations unless earlier terminated by either party
for a material breach. The Company may also terminate the agreement without cause at any time upon advance written notice
to Rigel. Rigel, after consultation with the Company, will be responsible for maintaining and prosecuting the patent rights,
and the Company will have final decision making authority regarding such patent rights for a product in the United States
and  the  European  Union.  To  the  extent  that  the  Company  and  Rigel  jointly  develop  intellectual  property,  the  parties  will
confer and decide which party will be responsible for filing, prosecuting and maintaining those patent rights. The agreement
also establishes a joint steering committee composed of an equal number of representatives for each party which will monitor
progress in the development of products.

The  Company  accounted  for  the  transaction  as  an  asset  acquisition  as  the  licensing  arrangement  did  not  meet  the
definition  of  a  business  pursuant  to  the  guidance  prescribed  in  ASC  Topic  805,  Business Combinations.  Accordingly,  the
Company recorded the $8,000 upfront payment as research and development expense in the year ended December 31, 2015.
The Company will record as expense any contingent milestone payments or royalties in the period in which such liabilities
are incurred. The Company concluded that licensing arrangement with Rigel did not meet the definition of a business because
the transaction principally resulted in its acquisition of intellectual property. As part of the transaction, the Company did not
acquire  any  employees  or  tangible  assets,  or  any  processes,  protocols  or  operating  systems.  In  addition,  at  the  time  of  the
acquisition, there were no activities being conducted related to the licensed patents. The Company will expense the acquired
intellectual property asset as of the acquisition date on the basis that costs of intangible assets that are purchased from others
for use in research and development activities and that have no alternative future uses are research and development costs at
the time the costs are incurred.

118

 
 
 
 
 
 
Table of Contents

Stock Purchase Agreement with Vixen Pharmaceuticals, Inc. and License Agreement with Columbia University

In March 2016, the Company entered into a stock purchase agreement (the “Vixen Agreement”) with Vixen, JAK1,
LLC,  JAK2,  LLC  and  JAK3,  LLC  (all  together  with  Vixen,  the  “Selling  Stockholders”)  and  Shareholder  Representative
Services LLC, a Colorado limited liability company, solely in its capacity as the representative of the Selling Stockholders.
Pursuant to the Vixen Agreement, the Company acquired all shares of Vixen’s capital stock from the Selling Stockholders
(the  “Vixen  Acquisition”).  Following  the  Vixen  Acquisition,  Vixen  became  a  wholly-owned  subsidiary  of  the  Company.
Pursuant  to  the  Vixen  Agreement,  the  Company  paid  $600  upfront  and  issued  an  aggregate  of  159,420  shares  of  the
Company’s  common  stock  to  the  Selling  Stockholders.  The  Company  is  obligated  to  make  annual  payments  of  $100  on
March 24  of each year, through March 2022, with such amounts being creditable against specified future payments that may
be paid under the Vixen Agreement.

th

The  Company  is  obligated  to  make  aggregate  payments  of  up  to  $18,000  to  the  Selling  Stockholders  upon  the
achievement of specified pre-commercialization milestones for three products in the United States, the European Union and
Japan, and aggregate payments of up to $22,500 upon the achievement of specified commercial milestones. With respect to
any commercialized products covered by the Vixen Agreement, the Company is obligated to pay low single-digit royalties on
net sales, subject to specified reductions, limitations and other adjustments, until the date that all of the patent rights for that
product have expired, as determined on a country-by-country and product-by-product basis or, in specified circumstances, ten
years from the first commercial sale of such product. If the Company sublicenses any of Vixen’s patent rights and know-how
acquired  pursuant  to  the  Vixen  Agreement,  the  Company  will  be  obligated  to  pay  a  portion  of  any  consideration  the
Company receives from such sublicenses in specified circumstances.

As a result of the transaction with Vixen, the Company became party to the Exclusive License Agreement, by and
between Vixen and the Trustees of Columbia University in the City of New York (“Columbia”), dated as of December 31,
2015  (the  “License  Agreement”).  Under  the  License  Agreement,  the  Company  is  obligated  to  pay  Columbia  an  annual
license  fee  of  $10,  subject  to  specified  adjustments  for  patent  expenses  incurred  by  Columbia  and  creditable  against  any
royalties that may be paid under the License Agreement. The Company is also obligated to pay up to an aggregate of $11,600
upon  the  achievement  of  specified  commercial  milestones,  including  specified  levels  of  net  sales  of  products  covered  by
Columbia  patent  rights  and/or  know-how,  and  royalties  at  a  sub-single-digit  percentage  of  annual  net  sales  of  products
covered by Columbia patent rights and/or know-how, subject to specified adjustments. If the Company sublicenses any of
Columbia’s patent rights and know-how acquired pursuant to the License Agreement, it will be obligated to pay Columbia a
portion  of  any  consideration  received  from  such  sublicenses  in  specified  circumstances.  The  royalties,  as  determined  on  a
country-by-country and product-by-product basis, are payable until the date that all of the patent rights for that product have
expired, the expiration of any market exclusivity period granted by a regulatory body or, in specified circumstances, ten years
from the first commercial sale of such product. The License Agreement terminates on the date of expiration of all royalty
obligations thereunder unless earlier terminated by either party for a material breach, subject to a specified cure period. The
Company may also terminate the License Agreement without cause at any time upon advance written notice to Columbia.

The Company accounted for the transaction with Vixen as an asset acquisition as the arrangement did not meet the
definition  of  a  business  pursuant  to  the  guidance  prescribed  in  ASC  Topic  805,  Business  Combinations.  The  Company
concluded the transaction with Vixen did not meet the definition of a business because the transaction principally resulted in
the  acquisition  of  the  License  Agreement.  The  Company  did  not  acquire  tangible  assets,  processes,  protocols  or  operating
systems. In addition, at the time of the transaction, there were no activities being conducted related to the licensed patents.
The Company expensed the acquired intellectual property as of the acquisition date on the basis that the cost of intangible
assets  purchased  from  others  for  use  in  research  and  development  activities,  and  that  have  no  alternative  future  uses,  are
expensed at the time the costs are incurred.  Accordingly, the Company recorded the $600 upfront payment, the fair value of
the shares of common stock issued of $2,355, and the present value of the six non-contingent annual payments as research
and  development  expense  in  the  year  ended  December  31,  2016.  Additionally,  the  Company  will  record  as  expense  any
contingent milestone payments or royalties in the period in which such liabilities are incurred. 

119

 
 
 
 
 
 
Table of Contents

14. 401(k) Savings Plan

The Company has a defined contribution savings plan under Section 401(k) of the Internal Revenue Code. This plan
covers  substantially  all  employees  who  meet  minimum  age  and  service  requirements  and  allows  participants  to  defer  a
portion of their annual compensation on a pre-tax basis. Company contributions to the plan may be made at the discretion of
the Company’s board of directors. The Company has elected to match 100% of employee contributions to the 401(k) Plan up
to 4% of the employee’s earnings, subject to certain limitations. Company contributions under the 401(k) Plan were $270,
$176 and $99 for the years ended December 31, 2017, 2016 and 2015, respectively.

15. Segment Information

The  Company  has  two  reportable  segments,  dermatology  therapeutics  and  contract  research.    The  dermatology
therapeutics  segment  is  focused  on  identifying,  developing  and  commercializing  innovative  and  differentiated  therapies  to
address significant unmet needs in medical and aesthetic dermatology.  The Company’s lead drug, ESKATA, is a proprietary
formulation of high-concentration hydrogen peroxide topical solution that the Company is commercializing as a prescription
treatment for raised SKs, a common non-malignant skin tumor, and which will be distributed by a wholesaler.  The contract
research  segment  earns  revenue  from  the  provision  of  laboratory  services  to  clients  through  Confluence,  the  Company’s
wholly-owned  subsidiary.    Laboratory  service  revenue  is  generally  evidenced  by  contracts  with  clients  which  are  on  an
agreed upon fixed-price, fee-for-service basis.  The Company does not report balance sheet information by segment since it is
not reviewed by the chief operating decision maker, and all of the Company’s tangible assets are held in the United States.

Year Ended December 31, 2017
Revenue
Cost of revenue
Research and development
General and administrative
Loss from operations

Year Ended December 31, 2016
Revenue
Cost of revenue
Research and development
General and administrative
Loss from operations

Year Ended December 31, 2015
Revenue
Cost of revenue
Research and development
General and administrative
Loss from operations

120

Total

  Dermatology  Contract   Corporate  
  Therapeutics  Research   and Other   Company
  $
1,683
 —   $ 3,202   $ (1,519)  $
(1,519)   
 —     2,726    
1,207
39,790
 —    
 —    
33,109
18,445    
673    
  $ (53,781)  $ (197)  $ (18,445)  $ (72,423)

39,790    
13,991    

Total

  Dermatology  Contract   Corporate  
  Therapeutics  Research   and Other   Company
  $
 —   $
 —
 —   $
 —    
 —    
 —
 —    
33,476
 —    
 —    
15,091
11,641    
 —   $ (11,641)  $ (48,567)

 —   $
 —    
33,476    
3,450    
  $ (36,926)  $

Total

  Dermatology  Contract   Corporate  
  Therapeutics  Research   and Other   Company
  $
 —   $
 —
 —   $
 —    
 —    
 —
 —    
15,339
 —    
 —    
5,328
4,133    
 —   $ (4,133)  $ (20,667)

 —   $
 —    
15,339    
1,195    
  $ (16,534)  $

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
   
 
   
    
    
    
 
 
 
 
 
 
 
 
   
 
   
 
 
   
   
   
 
 
 
 
 
 
 
   
 
   
 
 
 
 
 
 
 
 
   
 
   
 
 
   
   
   
 
 
Table of Contents

Foreign Subsidiary

The Company’s wholly-owned subsidiary, ATIL, was formed and operates in the United Kingdom.  ATIL is utilized
for  research  and  development,  regulatory  and  administrative  functions  and  had  $175  and  $4,786  of  net  assets,  composed
principally of cash, as of December 31, 2017 and 2016, respectively. 

Intersegment Revenue

Revenue  for  the  contract  research  segment  includes  $1,519  for  services  performed  on  behalf  of  the  dermatology
therapeutics  segment  for  the  period  between  August  3,  2017,  the  acquisition  date  for  Confluence,  and  December  31,
2017.  All intersegment revenue has been eliminated in the Company’s consolidated statement of operations. 

16. Quarterly Financial Information (unaudited)

The following table summarizes the unaudited consolidated financial results of operations for the quarters indicated:

2017 Quarter Ended

Revenue
Gross profit
Operating expenses
Other income, net
Net loss
Net loss per share, basic and diluted

Revenue
Gross profit
Operating expenses
Other income, net
Net loss
Net loss per share, basic and diluted

  March 31,   June 30,
  $
 —  $
 —   

 —  $
 —   
    12,930    15,295   
457   
    (12,559)   (14,838)  
  $
(0.56) $

  September 30,  December 31,
999
684   $
231    
245
25,687
18,987    
678
564    
(22,934)
(18,192)   
(0.74)
(0.63)  $

(0.48) $

371   

2016 Quarter Ended

  March 31,   June 30,
  $
 —  $
 —   

 —  $
 —   
    13,139    12,989   
118   
    (13,039)   (12,871)  
  $
(0.62) $

  September 30,  December 31,
 —
 —   $
 —    
 —
11,627
10,812    
152
118    
(11,475)
(10,694)   
(0.49)
(0.50)  $

(0.65) $

100   

Net loss per share is computed independently for each quarter and, therefore, the sum of the quarterly per share

amounts may not equal the year-to-date per share amount. 

121

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
   
 
   
 
   
 
   
 
 
 
 
   
   
 
   
 
   
 
   
 
   
 
 
 
 
 
Table of Contents

Item 9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure

None.

Item 9A. Controls and Procedures

Evaluation of Disclosure Controls and Procedures

Under the supervision of and with the participation of our management, including our chief executive officer, who is
our  principal  executive  officer,  and  our  chief  financial  officer,  who  is  our  principal  financial  officer,  we  conducted  an
evaluation  of  the  effectiveness  of  our  disclosure  controls  and  procedures  as  of  December  31,  2017,  the  end  of  the  period
covered by this Annual Report. The term “disclosure controls and procedures,” as set forth in Rules 13a-15(e) and 15d-15(e)
under  the  Securities  Exchange  Act  of  1934,  as  amended,  or  the  Exchange  Act,  means  controls  and  other  procedures  of  a
company that are designed to provide reasonable assurance that information required to be disclosed by a company in the
reports  that  it  files  or  submits  under  the  Exchange  Act  is  recorded,  processed,  summarized  and  reported,  within  the  time
periods  specified  in  the  rules  and  forms  promulgated  by  the  SEC.  Disclosure  controls  and  procedures  include,  without
limitation, controls and procedures designed to ensure that information required to be disclosed by a company in the reports
that it files or submits under the Exchange Act is accumulated and communicated to the company’s management, including
its principal executive and principal financial officers, as appropriate to allow timely decisions regarding required disclosure.
Management  recognizes  that  any  controls  and  procedures,  no  matter  how  well  designed  and  operated,  can  provide  only
reasonable assurance of achieving their objectives, and management necessarily applies its judgment in evaluating the cost-
benefit relationship of possible controls and procedures. Based on the evaluation of our disclosure controls and procedures as
of December 31, 2017, our chief executive officer and chief financial officer concluded that, as of such date, our disclosure
controls and procedures were effective at the reasonable assurance level.

Changes in Internal Control over Financial Reporting

There  was  no  change  in  our  internal  control  over  financial  reporting  identified  in  connection  with  the  evaluation
required by Rule 13a-15(d) and 15d-15(d) of the Exchange Act that occurred during the quarter ended December 31, 2017
that has materially affected, or is reasonably likely to materially affect, our internal control over financial reporting.

Management’s Report on Internal Control over Financial Reporting and Attestation Report of the Registered Public
Accounting Firm

Our  management  is  responsible  for  establishing  and  maintaining  an  adequate  system  of  internal  control  over
financial  reporting,  as  defined  in  the  Exchange  Act  Rule  13a-15(f).  Management  conducted  an  assessment  of  our  internal
control over financial reporting based on the framework established in 2013 by the Committee of Sponsoring Organizations
of  the  Treadway  Commission  in  Internal  Control—Integrated  Framework.    We  have  excluded  our  2017  acquisition  of
Confluence from the assessment of internal control over financial reporting as of December 31, 2017 because it was acquired
by  us  in  a  business  combination  in  August  2017.    The  acquisition  of  Confluence  represented  approximately  2%  of  our
consolidated total assets and all of our consolidated net revenues as of, and for the year ended, December 31, 2017.  Based on
the  assessment,  management  concluded  that,  as  of  December  31,  2017,  our  internal  control  over  financial  reporting  was
effective.

This Annual Report does not include an attestation report of our registered public accounting firm regarding internal
control over financial reporting as required by Section 404(c) of the Sarbanes-Oxley Act of 2002. Because we qualify as an
emerging  growth  company  under  the  JOBS  Act,  management's  report  was  not  subject  to  attestation  by  our  independent
registered public accounting firm. 

Item 9B. Other Information

Not applicable.

122

 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

PART III

We  will  file  a  definitive  Proxy  Statement  for  our  2018  Annual  Meeting  of  Stockholders,  or  the  2018  Proxy
Statement, with the SEC, pursuant to Regulation 14A, not later than 120 days after the end of our fiscal year. Accordingly,
certain information required by Part III has been omitted under General Instruction G(3) to Form 10-K. Only those sections
of the 2018 Proxy Statement that specifically address the items set forth herein are incorporated by reference.

Item 10. Directors, Executive Officers and Corporate Governance

The  information  required  by  Item  10  is  hereby  incorporated  by  reference  to  the  sections  of  the  2018  Proxy
Statement  under  the  captions  "Information  Regarding  the  Board  of  Directors  and  Corporate  Governance,"  "Election  of
Directors," "Executive Officers" and "Section 16(a) Beneficial Ownership Reporting Compliance."

Item 11. Executive Compensation

The information required by Item 11 is hereby incorporated by reference to the sections of the 2018 Proxy Statement

under the captions "Executive Compensation" and "Non-Employee Director Compensation."

Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

The  information  required  by  Item  12  is  hereby  incorporated  by  reference  to  the  sections  of  the  2018  Proxy
Statement  under  the  captions  "Security  Ownership  of  Certain  Beneficial  Owners  and  Management"  and  "Securities
Authorized for Issuance under Equity Compensation Plans."

Item 13. Certain Relationships and Related Transactions, and Director Independence

The  information  required  by  Item  13  is  hereby  incorporated  by  reference  to  the  sections  of  the  2018  Proxy

Statement under the captions "Transactions with Related Persons" and "Independence of the Board of Directors."

Item 14. Principal Accountant Fees and Services

The  information  required  by  Item  14  is  hereby  incorporated  by  reference  to  the  sections  of  the  2018  Proxy

Statement under the caption "Ratification of Selection of Independent Auditors."

123

 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

Item 15.  Exhibits and Financial Statement Schedules.

PART IV

(a)Exhibits

Exhibit
Number

Description of Document

2.1#  Stock Purchase Agreement, by and among the Registrant, Vixen Pharmaceuticals, Inc., JAK1, LLC, JAK2,

LLC, JAK3, LLC and Shareholder Representative Services LLC, dated as of March 24, 2016 (incorporated by
reference to Exhibit 2.1 to the Registrant’s Quarterly Report on Form 10-Q (File No. 001-37581), filed with the
SEC on May 11, 2016).

2.2#  Agreement and Plan of Merger, dated as of August 3, 2017, by and among the Registrant, Aclaris Life

Sciences, Inc., Confluence Life Sciences, Inc. and Fortis Advisors LLC (incorporated by reference to Exhibit
2.1 to the Registrant’s Quarterly Report on Form 10-Q (File No. 001-37581), filed with the SEC on November
7, 2017).

3.1  Amended and Restated Certificate of Incorporation of the Registrant (incorporated by reference to Exhibit 3.1
to the Registrant’s Current Report on Form 8-K (File No. 001-37581), filed with the SEC on October 13,
2015).

3.2  Amended and Restated Bylaws of the Registrant (incorporated by reference to Exhibit 3.2 to the Registrant’s

Current Report on Form 8-K (File No. 001-37581), filed with the SEC on October 13, 2015).

4.1  Specimen stock certificate evidencing shares of Common Stock (incorporated by reference to Exhibit 4.1 to
Amendment No. 2 to the Registrant’s Registration Statement on Form S-1 (File No. 333-206437), filed with
the SEC on September 25, 2015).

10.1#  Clinical and Commercial Supply Agreement, by and between the Registrant and PeroxyChem LLC, dated as of
August 6, 2014 (incorporated by reference to Exhibit 10.1 to the Registrant’s Registration Statement on
Form S-1 (File No. 333-206437), filed with the SEC on August 17, 2015).

10.2#  Assignment Agreement, by and between the Registrant and Mickey J. Miller, II, as personal representative of

the estate of Mickey J. Miller, dated as of August 20, 2012 (incorporated by reference to Exhibit 10.3 to
Amendment No. 2 to the Registrant’s Registration Statement on Form S-1 (File No. 333-206437), filed with
the SEC on September 25, 2015).

10.3#  Finder's Services Agreement, by and between the Registrant and KPT Consulting, LLC, dated as of August 25,

2012 (incorporated by reference to Exhibit 10.4 to the Registrant’s Registration Statement on Form S-1 (File
No. 333-206437), filed with the SEC on August 17, 2015).

10.4  Second Amended and Restated Investors' Rights Agreement, dated as of August 28, 2015, by and among the

Registrant and certain of its stockholders (incorporated by reference to Exhibit 10.5 to Amendment No. 1 to the
Registrant’s Registration Statement on Form S-1 (File No. 333-206437), filed with the SEC on September 4,
2015).

10.5+  Amended and Restated 2012 Equity Compensation Plan (incorporated by reference to Exhibit 10.7 to

Amendment No. 1 to the Registrant’s Registration Statement on Form S-1 (File No. 333-206437), filed with
the SEC on September 4, 2015).

10.6+  Form of Stock Option Grant under Amended and Restated 2012 Equity Compensation Plan (incorporated by
reference to Exhibit 10.8 to the Registrant’s Registration Statement on Form S-1 (File No. 333-206437), filed
with the SEC on August 17, 2015).
2015 Equity Incentive Plan (incorporated by reference to Exhibit 4.6 to the Registrant’s Registration Statement
on Form S-8 (File No. 333-207434), filed with the SEC on October 15, 2015).

10.7+ 

10.8+  Form of Stock Option Grant Notice and Stock Option Agreement under 2015 Equity Incentive Plan

(incorporated by reference to Exhibit 10.10 to Amendment No. 2 to the Registrant’s Registration Statement on
Form S-1 (File No. 333-206437), filed with the SEC on September 25, 2015).

10.9+  Form of Restricted Stock Unit Grant Notice and Restricted Stock Unit Award Agreement under 2015 Equity
Incentive Plan (incorporated by reference to Exhibit 10.11 to Amendment No. 2 to the Registrant’s
Registration Statement on Form S-1 (File No. 333-206437), filed with the SEC on September 25, 2015).

10.10  Form of Indemnification Agreement (incorporated by reference to Exhibit 10.12 to the Registrant’s

Registration Statement on Form S-1 (File No. 333-206437), filed with the SEC on August 17, 2015).

124

 
 
 
 
 
   
 
Table of Contents

10.11+  Non-Employee Director Compensation Policy (incorporated by reference to Exhibit 10.13 to Amendment

No. 2 to the Registrant’s Registration Statement on Form S-1 (File No. 333-206437), filed with the SEC on
September 25, 2015).

10.12#  License and Collaboration Agreement, by and between Aclaris Therapeutics International Limited and Rigel

Pharmaceuticals, Inc., dated as of August 27, 2015 (incorporated by reference to Exhibit 10.14 to Amendment
No. 3 to the Registrant’s Registration Statement on Form S-1 (File No. 333-206437), filed with the SEC on
October 1, 2015).

10.13+  Amended and Restated Employment Agreement, by and between the Registrant and Neal Walker, dated as of
October 5, 2015 (incorporated by reference to Exhibit 10.1 to the Registrant’s Quarterly Report on Form 10-Q
(File No. 001-37581), filed with the SEC on November 18, 2015).

10.14+  Employment Agreement, by and between the Registrant and Stuart Shanler, dated as of October 4, 2015

(incorporated by reference to Exhibit 10.2 to the Registrant’s Quarterly Report on Form 10-Q (File No. 001-
37581), filed with the SEC on November 18, 2015).

10.15+  Employment Agreement, by and between the Registrant and Christopher Powala, dated as of September 17,

2015 (incorporated by reference to Exhibit 10.3 to the Registrant’s Quarterly Report on Form 10-Q (File
No. 001-37581), filed with the SEC on November 18, 2015).

10.16# Exclusive License Agreement, by and between The Trustees of Columbia University in the City of New York
and Vixen Pharmaceuticals, Inc., dated as of December 31, 2015 (incorporated by reference to Exhibit 10.1 to
the Registrant’s Quarterly Report on Form 10-Q (File No. 001-37581), filed with the SEC on May 11, 2016).

10.17  Amendment to Assignment Agreement, by and between the Registrant and Mickey J. Miller, II, as personal

representative of the estate of Mickey J. Miller, dated as of June 15, 2016 (incorporated herein by reference to
Exhibit 10.25 to the Registrant’s Registration Statement on Form S-1 (File No. 333-212095), filed with the
SEC on June 2, 2016).

10.18  Common Stock Sales Agreement, dated November 2, 2016, by and between the Registrant and Cowen and
Company, LLC (incorporated by reference to Exhibit 10.1 to the Registrant’s Current Report on Form 8-K
(File No. 001-37581), filed with the SEC on November 2, 2016).

10.19  Employment Agreement with Kamil Ali-Jackson, dated as of September 17, 2015 (incorporated by reference

to Exhibit 10.1 to the Registrant’s Quarterly Report on Form 10-Q (File No. 001-37581), filed with the SEC on
May 9, 2017).

10.20  Aclaris Therapeutics, Inc. Inducement Plan (incorporated herein by reference to Exhibit 10.1 to the

Registrant’s Current Report on Form 8-K (File No. 001-37581), filed with the SEC on August 1, 2017).

10.21  Form of Stock Option Grant Notice and Stock Option Agreement used in connection with the Aclaris

Therapeutics, Inc. Inducement Plan (incorporated herein by reference to Exhibit 10.2 to the Registrant’s
Current Report on Form 8-K (File No. 001-37581), filed with the SEC on August 1, 2017).

10.22  Form of Restricted Stock Unit Grant Notice and Restricted Stock Unit Award Agreement used in connection
with the Aclaris Therapeutics, Inc. Inducement Plan (incorporated herein by reference to Exhibit 10.3 to the
Registrant’s Current Report on Form 8-K (File No. 001-37581), filed with the SEC on August 1, 2017).
10.23  Sublease, dated November 2, 2017, by and between the Company and Auxilium Pharmaceuticals, LLC

(incorporated by reference to Exhibit 10.1 to the Registrant’s Current Report on Form 8-K (File No. 001-
37581), filed with the SEC on November 2, 2017).

21.1*  Subsidiaries of the Registrant.
23.1*  Consent of PricewaterhouseCoopers LLP, independent registered public accounting firm.
24.1*  Power of Attorney (contained on signature page hereto).
31.1*  Certification of Principal Executive Officer pursuant to Rules 13a-14(a) and 15d-14(a) promulgated under the

Securities Exchange Act of 1934, as adopted pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.

31.2*  Certification of Principal Financial Officer pursuant to Rules 13a-14(a) and 15d-14(a) promulgated under the

Securities Exchange Act of 1934, as adopted pursuant to section 302 of the Sarbanes-Oxley Act of 2002.

32.1 *†  Certification of Principal Executive Officer and Principal Financial Officer pursuant to Rules 13a-14(b) and
15d-14(b) promulgated under the Securities Exchange Act of 1934 and 18 U.S.C. Section 1350, as adopted
pursuant to section 906 of The Sarbanes-Oxley Act of 2002.

101.INS*  XBRL Instance Document
101.SCH*  XBRL Taxonomy Extension Schema Document
101.CAL*  XBRL Taxonomy Extension Calculation Linkbase Document

125

 
Table of Contents

101.DEF*  XBRL Taxonomy Extension Definition Linkbase Document
101.LAB*  XBRL Taxonomy Extension Label Linkbase Document
101.PRE*  XBRL Taxonomy Extension Presentation Linkbase Document

Filed herewith.

*
† This certification is being furnished solely to accompany this Annual Report pursuant to 18 U.S.C. Section 1350, and are
not  being  filed  for  purposes  of  Section  18  of  the  Securities  Exchange  Act  of  1934,  as  amended,  and  is  not  to  be
incorporated by reference into any filing of the Registrant, whether made before or after the date hereof, regardless of
any general incorporation language in such filing.
Indicates management contract or compensatory plan.

+
# Confidential treatment has been granted with respect to portions of this exhibit (indicated by asterisks) and those portions

have been separately filed with the SEC.

Item 16.  Form 10-K Summary.

Not applicable.

126

 
 
 
 
 
 
Table of Contents

Pursuant  to  the  requirements  of  Section  13  or  15(d)  of  the  Securities  Exchange  Act  of  1934,  as  amended,  the

registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

SIGNATURES

ACLARIS THERAPEUTICS, INC.

By:

/s/ Neal Walker
Neal Walker

President and Chief Executive Officer

Date:  March 12, 2018

KNOW ALL PERSONS BY THESE PRESENTS, that each person whose signature appears below constitutes and
appoints Neal Walker, Kamil Ali-Jackson and Frank Ruffo, jointly and severally, as his true and lawful attorneys-in-fact and
agents, with full power of substitution and resubstitution, for him and in his name, place and stead, in any and all capacities,
to sign this Annual Report on Form 10-K of Aclaris Therapeutics, Inc., and any or all amendments (including post-effective
amendments) thereto, and to file the same, with all exhibits thereto, and other documents in connection therewith, with the
Securities  and  Exchange  Commission,  granting  unto  said  attorneys-in-fact  and  agents  full  power  and  authority  to  do  and
perform  each  and  every  act  and  thing  requisite  or  necessary  to  be  done  in  and  about  the  premises  hereby  ratifying  and
confirming all that said attorneys-in-fact and agents, or his or their substitute or substitutes, may lawfully do or cause to be
done by virtue hereof.

Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, this report has been signed below

by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

Signature

/s/ Neal Walker
Neal Walker

/s/ Frank Ruffo
Frank Ruffo

Title

Date

President, Chief Executive Officer and Director
(Principal Executive Officer)

  Chief Financial Officer

(Principal Financial Officer and Principal
Accounting Officer)

March 12, 2018

March 12, 2018

/s/ Stephen A. Tullman
Stephen A. Tullman

  Chairman of the Board of Directors

March 12, 2018

/s/ Christopher Molineaux
Christopher Molineaux

  Director

/s/ Anand Mehra, M.D.
Anand Mehra, M.D.

  Director

/s/ William Humphries
William Humphries

  Director

/s/ Andrew Powell
Andrew Powell

/s/ Andrew Schiff
Andrew Schiff

  Director

  Director

127

March 12, 2018

March 12, 2018

March 12, 2018

March 12, 2018

March 12, 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Subsidiaries of Aclaris Therapeutics, Inc. 

Exhibit 21.1 

Name of Subsidiary

Aclaris Therapeutics International, Ltd.
Vixen Pharmaceuticals, Inc.
Confluence Life Sciences, Inc.

Jurisdiction of Incorporation or
Organization

United Kingdom
Delaware
Delaware

   
   
 
 
 
 
 
 
 
 
CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

We hereby consent to the incorporation by reference in the Registration Statements on Form S-3 (No. 333-214384) and Form
S-8 (No. 333-207434, No. 333-210379, No. 333-216703, No. 333-220149) of our report dated March 12, 2018 relating to the
financial statements, which appears in this Form 10-K.

EXHIBIT 23.1

/s/ PricewaterhouseCoopers LLP

Philadelphia, Pennsylvania
March 12, 2018

 
 
 
 
 
 
 
Exhibit 31.1

CERTIFICATION OF PRINCIPAL EXECUTIVE OFFICER 
PURSUANT TO SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002

I, Neal Walker, certify that:

1.    I have reviewed this annual report on Form 10-K of Aclaris Therapeutics, Inc. (the “registrant”);

2.    Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary

to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the
period covered by this report;

3.    Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material

respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4.    The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as
defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and 15d-15(e)) and internal control over financial reporting (as defined in
Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have:

(a)  Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our

supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to
us by others within those entities, particularly during the period in which this report is being prepared;

(b)  Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed
under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of
financial statements for external purposes in accordance with generally accepted accounting principles;

(c)  Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about

the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such
evaluation; and

(d)  Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s
most recent fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is
reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5.    The registrant’s other certifying officer(s) and I have disclosed, based on our most recent evaluation of internal control over financial

reporting, to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the
equivalent functions):

(a)  All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which

are reasonably likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; and

(b)  Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s

internal control over financial reporting.

Date: March 12, 2018

/s/ Neal Walker
Neal Walker
President & Chief Executive Officer
(principal executive officer)

 
 
 
 
 
 
 
 
Exhibit 31.2

CERTIFICATION OF PRINCIPAL EXECUTIVE OFFICER 
PURSUANT TO SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002

I, Frank Ruffo, certify that:

1.    I have reviewed this annual report on Form 10-K of Aclaris Therapeutics, Inc. (the “registrant”);

2.    Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary

to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the
period covered by this report;

3.    Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material

respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4.    The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as
defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and 15d-15(e)) and internal control over financial reporting (as defined in
Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have:

(a)  Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our

supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to
us by others within those entities, particularly during the period in which this report is being prepared;

(b)  Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed
under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of
financial statements for external purposes in accordance with generally accepted accounting principles;

(c)  Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about

the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such
evaluation; and

(d)  Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s
most recent fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is
reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5.    The registrant’s other certifying officer(s) and I have disclosed, based on our most recent evaluation of internal control over financial

reporting, to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the
equivalent functions):

(a)  All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which

are reasonably likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; and

(b)  Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s

internal control over financial reporting.

Date: March 12, 2018

/s/ Frank Ruffo
Frank Ruffo
Chief Financial Officer
(principal financial officer and principal accounting officer)

 
 
 
 
 
 
CERTIFICATIONS OF
PRINCIPAL EXECUTIVE OFFICER AND PRINCIPAL FINANCIAL OFFICER
PURSUANT TO 18 U.S.C. SECTION 1350,
AS ADOPTED PURSUANT TO
SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002

Exhibit 32.1

Pursuant to the requirement set forth in Rule 13a-14(b) of the Securities Exchange Act of 1934, as amended (the

“Exchange Act”), and Section 1350 of Chapter 63 of Title 18 of the United States Code (18 U.S.C. §1350), Neal Walker,
President and Chief Executive Officer of Aclaris Therapeutics, Inc. (the “Company”), and Frank Ruffo, Chief Financial
Officer of the Company, each hereby certifies that, to the best of his knowledge:

1. The Company’s Annual Report on Form 10-K for the period ended December 31, 2017 (the “Annual Report”), to
which this Certification is attached as Exhibit 32.1, fully complies with the requirements of Section 13(a) or
Section 15(d) of the Exchange Act, and

2. The information contained in the Annual Report fairly presents, in all material respects, the financial condition of
the Company as of the end of the period covered by the Annual Report and results of operations of the Company
for the periods covered by the Annual Report.

In Witness Whereof, the undersigned have set their hands hereto as of the 12th day of March, 2018.

/s/ Neal Walker
Neal Walker
President & Chief Executive Officer

/s/ Frank Ruffo
Frank Ruffo
Chief Financial Officer

*  This certification accompanies the Form 10-K to which it relates, is not deemed filed with the Securities and Exchange

Commission and is not to be incorporated by reference into any filing of the Company under the Securities Act of 1933, as
amended, or the Exchange Act (whether made before or after the date of the Form 10-K), irrespective of any general
incorporation language contained in such filing.