Quarterlytics / Healthcare / Biotechnology / Intercept Pharmaceuticals

Intercept Pharmaceuticals

icpt · NASDAQ Healthcare
Claim this profile
Ticker icpt
Exchange NASDAQ
Sector Healthcare
Industry Biotechnology
Employees 201-500
← All annual reports
FY2019 Annual Report · Intercept Pharmaceuticals
Sign in to download
Loading PDF…
Table of Contents

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

FORM 10-K

(Mark One)

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

For the fiscal year ended December 31, 2019

OR

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

For the transition period from             to

Commission file number: 001-35668

Intercept Pharmaceuticals, Inc.
(Exact Name of Registrant as Specified in Its Charter)

Delaware
(State or Other Jurisdiction of
Incorporation or Organization)

22-3868459
(I.R.S. Employer
Identification No.)

10 Hudson Yards, 37th Floor
New York, NY 10001
(Address of Principal Executive Offices and Zip Code)
(646) 747-1000
(Registrant’s Telephone Number, Including Area Code)

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

Title of each class

Common Stock, par value $0.001 per share

Trading Symbol(s)

ICPT

Name of each exchange on which registered

Nasdaq Global Select Market

Securities registered pursuant to Section 12(g) of the 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 Section 15(d) of the 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 every Interactive Data File required to be submitted 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 such files).Yes ☒ No ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth

company. See the 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
       Non-accelerated filer

☒
☐

Accelerated filer
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 Act).Yes ☐ No ☒

The  aggregate  market  value  of  the  registrant’s  common  stock  held  by  non-affiliates  as  of  June  28,  2019,  the  last  business  day  of  the  registrant’s  most  recently  completed
second fiscal quarter, was $2,027.8 million (computed by reference to the closing price of $79.57 on such date as reported by the Nasdaq Global Select Market). Common stock
held by our executive officers, directors and certain stockholders as of such date has been excluded from this calculation because such persons may be deemed to be affiliates. This
determination of affiliate status is not necessarily a conclusive determination for other purposes.

The number of shares of the registrant’s common stock outstanding as of December 31, 2019 was 32,853,066.

DOCUMENTS INCORPORATED BY REFERENCE

Certain information required by Part III of this Annual Report on Form 10-K is incorporated by reference to the registrant’s definitive proxy statement related to its 2020

Annual Meeting of Stockholders, to be filed pursuant to Regulation 14A not later than 120 days after the end of the fiscal year covered by this Annual Report on Form 10-K.

    
Table of Contents

Part I.

Intercept Pharmaceuticals, Inc.
Annual Report on Form 10-K
For the Fiscal Year Ended December 31, 2019

TABLE OF CONTENTS

Business

Item 1.
Item 1A. Risk Factors
Item 1B. Unresolved Staff Comments
Item 2.
Item 3.
Item 4. Mine Safety Disclosures

Properties
Legal Proceedings

Part II.

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

Securities
Selected Financial Data

Item 6.
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Item 7A. Quantitative and Qualitative Disclosures About Market Risk
Item 8.
Item 9.
Item 9A. Controls and Procedures
Item 9B. Other Information

Financial Statements and Supplementary Data
Changes in and Disagreements With Accountants on Accounting and Financial Disclosure

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 Accounting Fees and Services

Part IV.

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

Page

1
32
81
81
81
81

82
83
85
98
99
99
99
100

100
100
100
101
101

102
107
108

Unless  the  context  otherwise  requires,  references  in  this  Annual  Report  on  Form  10-K  to  “we,”  “our,”  “us”  and  the

“Company” refer, collectively, to Intercept Pharmaceuticals, Inc., a Delaware corporation, and its consolidated subsidiaries.

i

Table of Contents

CAUTIONARY NOTE REGARDING FORWARD-LOOKING STATEMENTS

This  Annual  Report  on  Form  10-K  contains  forward-looking  statements,  including,  but  not  limited  to,  statements
regarding the progress, timing and results of our clinical trials, including our clinical trials for the treatment of nonalcoholic
steatohepatitis (“NASH”), the safety and efficacy of our approved product, Ocaliva (obeticholic acid or “OCA”) for primary
biliary  cholangitis  (“PBC”),  and  our  product  candidates,  including  OCA  for  liver  fibrosis  due  to  NASH,  the  timing  and
acceptance  of  our  regulatory  filings  and  the  potential  approval  of  OCA  for  liver  fibrosis  due  to  NASH  or  any  other
indications in addition to PBC, the timing and potential commercial success of OCA and any other product candidates we
may develop and our strategy, future operations, future financial position, future revenue, projected costs, financial guidance,
prospects, plans and objectives.

These  statements  constitute  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. The words “anticipate,” “believe,”
“estimate,” “expect,” “intend,” “may,” “plan,” “predict,” “project,” “target,” “potential,” “will,” “would,” “could,” “should,”
“possible,” “continue” and similar expressions are intended to identify forward-looking statements, although not all forward-
looking  statements  contain  these  identifying  words.  Readers  are  cautioned  not  to  place  undue  reliance  on  these  forward-
looking  statements,  which  speak  only  as  of  their  dates,  and  we  undertake  no  obligation  to  update  any  forward-looking
statement  except  as  required  by  law.  These  forward-looking  statements  are  based  on  estimates  and  assumptions  by  our
management that, although believed to be reasonable, are inherently uncertain and subject to a number of risks.

The following represent some, but not necessarily all, of the factors that could cause actual results to differ materially

from historical results or those anticipated or predicted by our forward-looking statements:

● our ability to successfully commercialize Ocaliva for PBC;

● our ability to maintain our regulatory approval of Ocaliva for PBC in the United States, Europe, Canada, Israel,

Australia and other jurisdictions in which we have or may receive marketing authorization;

● the initiation, timing, cost, conduct, progress and results of our research and development activities, preclinical
studies  and  clinical  trials,  including  any  issues,  delays  or  failures  in  identifying  patients,  enrolling  patients,
treating patients, retaining patients, meeting specific endpoints in the jurisdictions in which we intend to seek
approval or completing and timely reporting the results of our NASH or PBC clinical trials;

the 

regulatory  approval  of  our  New  Drug  Application 

● our  ability  to  timely  and  cost-effectively  file  for  and  obtain  regulatory  approval  of  our  product  candidates,
including 
for  NASH;  any  advisory
committee recommendation that our product candidates, including OCA for liver fibrosis due to NASH, should
not  be  approved  or  approved  only  under  certain  conditions;  or  any  determination  that  the  regulatory
applications  and  subsequent  information  we  submit  for  our  product  candidates,  including  OCA  for  liver
fibrosis due to NASH, do not contain adequate clinical or other data or meet applicable regulatory requirements
for approval;

● conditions  that  may  be  imposed  by  regulatory  authorities  on  our  marketing  approvals  for  our  products  and
product candidates, such as the need for clinical outcomes data (and not just results based on achievement of a
surrogate endpoint), and any related restrictions, limitations and/or warnings contained in the label of any of
our products or product candidates;

● any potential side effects associated with Ocaliva for PBC, OCA for liver fibrosis due to NASH or our other
product  candidates  that  could  delay  or  prevent  approval,  require  that  an  approved  product  be  taken  off  the
market, require the inclusion of safety warnings or precautions or otherwise limit the sale of such product or
product candidate;

ii

Table of Contents

● our  ability  to  establish  and  maintain  relationships  with,  and  the  performance  of,  third-party  manufacturers,
contract research organizations and other vendors upon whom we are substantially dependent for, among other
things, the manufacture and supply of our products, including Ocaliva for PBC and, if approved, OCA for liver
fibrosis due to NASH, and our clinical trial activities;

● our ability to identify, develop and successfully commercialize our products and product candidates, including

our ability to timely and successfully launch OCA for liver fibrosis due to NASH, if approved;

● our  ability  to  obtain  and  maintain  intellectual  property  protection  for  our  products  and  product  candidates,
including  our  ability  to  cost-effectively  file,  prosecute,  defend  and  enforce  any  patent  claims  or  other
intellectual property rights;

● the  size  and  growth  of  the  markets  for  our  products  and  product  candidates  and  our  ability  to  serve  those

markets;

● the degree of market acceptance of Ocaliva for PBC and, if approved, OCA for liver fibrosis due to NASH or

our other product candidates among physicians, patients and healthcare payors;

● the availability of adequate coverage and reimbursement from governmental and private healthcare payors for
our products, including Ocaliva for PBC and, if approved, OCA for liver fibrosis due to NASH, and our ability
to obtain adequate pricing for such products;

● our ability to establish and maintain effective sales, marketing and distribution capabilities, either directly or

through collaborations with third parties;

● competition from existing drugs or new drugs that become available;

● our ability to prevent system failures, data breaches or violations of data protection laws;

● costs  and  outcomes  relating  to  any  disputes,  governmental  inquiries  or  investigations,  legal  proceedings  or
litigation, including any securities, intellectual property, employment, product liability or other litigation;

● our collaborators’ election to pursue research, development and commercialization activities;

● our  ability  to  establish  and  maintain  relationships  with  collaborators  with  development,  regulatory  and

commercialization expertise;

● our need for and ability to generate or obtain additional financing;

● our estimates regarding future expenses, revenues and capital requirements and the accuracy thereof;

● our use of cash and short-term investments;

● our ability to acquire, license and invest in businesses, technologies, product candidates and products;

● our ability to attract and retain key personnel to manage our business effectively;

● our ability to manage the growth of our operations, infrastructure, personnel, systems and controls;

● our ability to obtain and maintain adequate insurance coverage;

iii

Table of Contents

● the impact of general U.S. and foreign economic, industry, market, regulatory or political conditions, including

the potential impact of Brexit; and

● the other risks and uncertainties identified under the captions “Risk Factors,” “Business” and “Management’s
Discussion  and  Analysis  of  Financial  Condition  and  Results  of  Operations”  and  elsewhere  in  this  Annual
Report  on  Form  10-K  and  in  our  other  periodic  filings  filed  with  the  U.S.  Securities  and  Exchange
Commission.

NOTE REGARDING TRADEMARKS

The Intercept Pharmaceuticals® name and logo and the Ocaliva® name and logo are either registered or unregistered
trademarks or trade names of the Company in the United States and/or other countries. All other trademarks, trade names and
service  marks  appearing  in  this  Annual  Report  on  Form  10-K  are  the  property  of  their  respective  owners.  Solely  for
convenience, trademarks and trade names referred to in this Annual Report on Form 10-K may appear without the ® and ™
symbols,  but  those  references  are  not  intended  to  indicate,  in  any  way,  that  we  will  not  assert,  to  the  fullest  extent  under
applicable law, our rights or that the applicable owner will not assert its rights to these trademarks and trade names.

iv

Table of Contents

Item 1.   Business

Overview

PART I

We are a biopharmaceutical company focused on the development and commercialization of novel therapeutics to treat
progressive non-viral liver diseases with a high unmet medical need utilizing our proprietary bile acid chemistry. Our first
marketed product, Ocaliva® (obeticholic acid or “OCA”), is a farnesoid X receptor (“FXR”) agonist approved in the United
States,  the  European  Union  and  several  other  jurisdictions  for  the  treatment  of  primary  biliary  cholangitis  (“PBC”)  in
combination  with  ursodeoxycholic  acid  (“UDCA”)  in  adults  with  an  inadequate  response  to  UDCA  or  as  monotherapy  in
adults  unable  to  tolerate  UDCA.  In  addition  to  commercializing  OCA  for  PBC  under  the  Ocaliva  brand  name,  we  are
currently  developing  OCA  for  additional  indications,  including  nonalcoholic  steatohepatitis  (“NASH”).  We  are  also
developing several other product candidates in various stages of clinical and preclinical development. We believe that OCA
and our other product candidates have the potential to treat orphan and other more prevalent liver diseases such as NASH for
which there are currently limited therapeutic options.

Ocaliva was approved for PBC by the U.S. Food and Drug Administration (“FDA”) in May 2016 under the accelerated
approval pathway. We commenced sales and marketing of Ocaliva in the United States shortly after receiving approval, and
Ocaliva is now available to U.S. patients primarily through a network of specialty pharmacy distributors. Ocaliva received
conditional  approval  for  PBC  from  the  European  Commission  in  December  2016  and  we  commenced  our  European
commercial  launch  in  January  2017.  We  have  submitted  dossiers  and  obtained,  or  are  otherwise  pursuing,  reimbursement
from  a  number  of  national  authorities  in  Europe.  Since  January  2017,  Ocaliva  has  also  received  regulatory  approval  in
several  of  our  target  markets  outside  the  United  States  and  Europe,  including  Canada,  Israel  and  Australia,  and  we  are
pursuing  marketing  approval  of  Ocaliva  for  PBC  in  our  other  international  target  markets.  Ocaliva  received  orphan  drug
designation in both the United States and the European Union for the treatment of PBC.

Our lead product candidate is OCA for the potential treatment of NASH. In February 2019, we announced topline results
from the planned 18-month interim analysis of our pivotal Phase 3 clinical trial of OCA in patients with liver fibrosis due to
NASH,  known  as  the  REGENERATE  trial.  In  the  primary  efficacy  analysis,  once-daily  OCA  25  mg  met  the  primary
endpoint agreed with the FDA of fibrosis improvement by at least one stage with no worsening of NASH at the planned 18-
month interim analysis. Adverse events were generally mild to moderate in severity and the most common were consistent
with the known profile of OCA. The interim analysis results were based on surrogate endpoints and the impact on clinical
outcomes  has  not  been  confirmed.  The  REGENERATE  trial  is  ongoing  and  will  continue  through  clinical  outcomes  for
verification and description of clinical benefit. OCA also achieved the primary endpoint in a Phase 2b clinical trial for the
treatment  of  NASH  completed  in  late  July  2014,  known  as  the  FLINT  trial,  which  was  sponsored  by  the  U.S.  National
Institute  of  Diabetes  and  Digestive  and  Kidney  Diseases,  a  part  of  the  National  Institutes  of  Health.  OCA  has  received
breakthrough therapy designation from the FDA for the treatment of NASH patients with liver fibrosis. In September 2019,
we submitted a New Drug Application (“NDA”) to the FDA seeking accelerated approval of OCA for liver fibrosis due to
NASH.  In  November  2019,  the  FDA  accepted  our  NDA  for  filing  and  granted  a  priority  review  designation  for  OCA  for
liver fibrosis due to NASH. Under the Prescription Drug User Fee Act (“PDUFA”), the FDA has set a target action date of
June 26, 2020 for the completion of its review of our NDA, after giving effect to a 90-day extension of its initial target action
date. The FDA has also notified us that it has tentatively scheduled an advisory committee meeting relating to our NDA for
April  22,  2020.  In  December  2019,  we  submitted  a  Marketing  Authorization  Application  (“MAA”)  to  the  European
Medicines  Agency  (“EMA”)  seeking  conditional  approval  of  OCA  for  liver  fibrosis  due  to  NASH.  In  January  2020,  the
EMA  validated  our  MAA  and  thereby  confirmed  that  our  MAA  was  sufficiently  complete  to  begin  the  formal  review
process.  In  addition,  we  are  conducting  a  number  of  other  trials  and  studies  in  connection  with  our  NASH  development
program, including our ongoing Phase 3 trial in NASH patients with compensated cirrhosis, known as the REVERSE trial. In
January 2020, we announced that we completed enrollment of the REVERSE trial with over 900 patients randomized.

As part of our product development activities, we expect to continue to invest in evaluating the potential of OCA and our

other product candidates in progressive non-viral liver diseases such as PBC and NASH. For example, we are studying

1

Table of Contents

OCA in combination with bezafibrate, a pan-peroxisome proliferator-activated receptor (“PPAR”) agonist, in patients with
PBC and potentially may study such combination in other liver diseases.

Liver Function, Bile Acids and Progressive Non-Viral Liver Diseases

The liver performs many functions that are vital for maintaining health, including the regulation of bile acid metabolism.
Bile acids are natural detergent-like emulsifying agents that are released from the gallbladder into the intestine when food is
ingested,  and  are  essential  for  the  absorption  of  dietary  cholesterol  and  other  nutrients.  Cholesterol  bound  by  bile  acids  is
taken  up  by  the  liver,  where  the  cholesterol  is  then  converted  into  one  of  two  primary  bile  acids.  The  bile  acids  are  then
actively  secreted  into  bile  ducts,  which  eventually  empty  into  the  gallbladder.  This  digestive  cycle  of  bile  flow  from
gallbladder to intestine to liver and back is called the enterohepatic recirculation of bile.

In  addition  to  facilitating  nutrient  absorption,  bile  acids  act  as  important  signals  that  help  regulate  multiple  other
biological functions. They are also complex signaling molecules that integrate metabolic and immune pathways involved in
the healthy functioning of various tissues and organs. For example, the actions of bile acids in the liver, intestine and kidney
regulate repair mechanisms that modulate inflammation and fibrosis (scarring), which can lead to progressive organ damage.

The biological effects of bile acids are mediated through dedicated receptors. The best understood receptor is FXR, a
nuclear receptor that regulates bile acid synthesis and clearance from the liver, thereby preventing excessive bile acid build-
up in the liver, which may be toxic. As such, FXR is a target for the treatment of several liver diseases such as PBC that
involve impaired bile flow, a condition called cholestasis. In cholestasis, the liver is typically exposed to higher than normal
levels  of  bile  acids,  which  can  cause  significant  damage  over  time.  In  addition,  bile  acid  activation  of  FXR  is  believed  to
induce anti-fibrotic, anti-inflammatory, anti-steatotic and other mechanisms that are necessary for the normal regeneration of
the  liver.  As  a  result,  FXR  is  also  a  target  for  the  treatment  of  more  common  liver  diseases  such  as  NASH  and  alcoholic
hepatitis. Further, based on the discovery of similar FXR-mediated protective mechanisms in other organs exposed to bile
acids,  we  believe  that  FXR  may  also  be  a  potential  target  for  the  treatment  of  a  number  of  intestinal,  kidney  and  other
diseases.

OCA is a bile acid analog, a chemical substance that has a structure based on a naturally occurring human bile acid, that
selectively  binds  to  and  activates  FXR.  We  believe  that  OCA  has  broad  liver-protective  properties  and  may  effectively
counter  a  variety  of  chronic  insults  to  the  liver  that  cause  fibrosis  (scarring),  which  can  eventually  lead  to  cirrhosis,  liver
transplant and death. Due to OCA’s bile acid-like properties, it circulates enterohepatically and engages FXR in both the liver
and intestine. FXR engagement in the liver is believed to be critical to successfully treat pathologic injury due to progressive
underlying disease.

By virtue of our patent portfolio and the proprietary know-how of our employees and collaboration partners, we believe
that we hold a leading position in the fields of bile acid chemistry and therapeutics. Our research and development efforts
have resulted in a pipeline of bile acid analogs in addition to OCA and through our on-going work with our collaboration
partners such as Professor Roberto Pellicciari, Ph.D., one of our co-founders, and TES Pharma S.r.l., we are continuing our
research to rationally design compounds that bind selectively and potently to FXR and other bile acid receptors.

Our Strategy

Our  objective  is  to  develop  and  commercialize  novel  therapeutics  for  the  treatment  of  progressive  non-viral  liver

diseases with high unmet medical need. The key elements of our strategy are to:

● Advance our leading NASH program. We have filed for approval of OCA for liver fibrosis due to NASH in the
United  States  and  Europe  and  will  continue  to  prepare  for  the  potential  commercialization  of  OCA  for  liver
fibrosis due to NASH, if approved. We also expect to continue REGENERATE through clinical outcomes and
to  progress  our  Phase  3  REVERSE  trial  for  NASH  patients  with  compensated  cirrhosis.  We  also  intend  to
conduct studies to explore the potential of OCA in combination therapy.

2

Table of Contents

● Expand  our  global  PBC  business.  We  intend  to  expand  access  to  Ocaliva  to  eligible  patients  by  increasing
Ocaliva’s  penetration  in  the  markets  where  Ocaliva  has  been  approved,  pursuing  regulatory  approval  for
Ocaliva in our target markets where Ocaliva has not yet been approved and developing additional innovative
product candidates, such as OCA in combination with bezafibrate, for PBC.

● Develop and expand our pipeline.  We  intend  to  continue  to  develop  OCA  and  our  other  product  candidates,
alone or in combination, for non-viral liver diseases. In addition, we intend to expand our portfolio of clinical
and preclinical product candidates by leveraging our and our collaborators’ expertise in bile acid chemistry and
opportunistically pursuing business development transactions.

● Expand and protect our intellectual property. We intend to expand and aggressively prosecute our intellectual
property in the area of bile acid chemistry and therapeutics with the objective of maintaining a defensible and
valuable intellectual property portfolio.

History and Development of the Company

In September 2002, we were incorporated in Delaware and shortly thereafter began operations in New York. In October
2012,  following  several  rounds  of  private  funding,  we  completed  our  initial  public  offering  (the  “IPO”)  and  received  net
proceeds  of  approximately  $78.7  million  therefrom.  We  used  the  proceeds  from  our  IPO  to  fund,  among  other  things,
preclinical  and  clinical  development  activities,  including  our  Phase  3  POISE  trial  studying  OCA  for  PBC  and  work
performed in anticipation of our submission of regulatory filings for the approval of OCA for PBC. In addition, between June
2013  and  April  2015,  we  completed  four  registered  public  offerings  of  our  common  stock  and  received  aggregate  net
proceeds of approximately $803.4 million therefrom.

In March 2014, we announced the results of our Phase 3 POISE trial of OCA for PBC. In November 2014, results from
the FLINT Phase 2b clinical trial of OCA for liver fibrosis due to NASH were published in The Lancet. Both of these trials
met their primary endpoints.

In June 2015, we submitted a NDA to the FDA seeking accelerated approval of OCA for PBC and a MAA to the EMA
seeking  conditional  approval  of  OCA  for  PBC.  In  September  2015,  we  announced  the  initiation  of  our  Phase  3
REGENERATE trial of OCA in patients with liver fibrosis due to NASH.

In May 2016, Ocaliva was approved for PBC by the FDA. We commenced sales and marketing of Ocaliva in the United
States shortly after receiving approval. In July 2016, we issued and sold $460.0 million aggregate principal amount of 3.25%
Convertible Senior Notes due 2023 (the “2023 Convertible Notes”) in a registered public offering and received net proceeds
of  approximately  $447.6  million  therefrom.  In  December  2016,  Ocaliva  received  conditional  approval  for  PBC  from  the
European Commission.

In  January  2017,  we  commenced  our  European  launch  of  Ocaliva  for  PBC.  Since  January  2017,  Ocaliva  has  also
received regulatory approval in several of our target markets outside the United States and Europe, including Canada, Israel
and Australia, and we are pursuing marketing approval of Ocaliva for PBC in our other international target markets. In July
2017,  we  announced  positive  results  from  our  Phase  2  CONTROL  trial,  the  goal  of  which  was  to  characterize  the  lipid
metabolic effects of OCA and cholesterol management effects of concomitant statin administration in NASH patients, as well
as positive top-line results from our Phase 2 AESOP trial of OCA for primary sclerosing cholangitis (“PSC”).

In  February  2018,  we  announced  our  Phase  3  REVERSE  trial  of  OCA  for  liver  fibrosis  due  to  NASH  patients  with
compensated cirrhosis. In April 2018, we issued and sold an aggregate of approximately 4.3 million shares of common stock
in  a  registered  public  offering  and  a  concurrent  private  placement  (the  “Concurrent  Private  Placement”)  exempt  from  the
registration  requirements  of  the  Securities  Act  of  1933,  as  amended,  and  received  net  proceeds  of  approximately  $261.4
million therefrom. In December 2018, we entered into an agreement (the “Aralez Agreement”) with Aralez Pharmaceuticals
Canada Inc. (“Aralez”), pursuant to which we acquired (i) Aralez’s license to develop and commercialize bezafibrate in the
United  States,  (ii)  Aralez’s  investigational  new  drug  application  (“IND”)  on  file  with  the  FDA  and  other  associated
regulatory documentation and (iii) a non-exclusive license to certain of Aralez’s intellectual property. We are evaluating the
efficacy, safety and tolerability of bezafibrate in combination with OCA in patients with PBC in a Phase 2

3

Table of Contents

study, with the longer-term goal of developing and seeking regulatory approval for a fixed dose combination regimen in this
indication and potentially other liver diseases.

In  February  2019,  we  announced  topline  results  from  our  pivotal  Phase  3  REGENERATE  trial  in  patients  with  liver
fibrosis due to NASH. In the primary efficacy analysis, once-daily OCA 25 mg met the primary endpoint agreed with the
FDA of fibrosis improvement by at least one stage with no worsening of NASH at the planned 18-month analysis. Adverse
events were generally mild to moderate in severity and the most common were consistent with the known profile of OCA.

In  May  2019,  we  issued  and  sold  $230.0  million  aggregate  principal  amount  of  2.00%  Convertible  Senior  Notes  due
2026 (the “2026 Convertible Notes” and together with the 2023 Convertible Notes, the “Convertible Notes”) in a registered
public  offering  and  received  net  proceeds  of  approximately  $223.4  million  therefrom.  In  May  2019,  we  issued  and  sold
2,760,000  shares  of  common  stock  in  a  registered  public  offering  (“the  2019  Public  Offering”)  and  119,760  shares  of
common stock in a concurrent private placement of common stock (the “2019 Concurrent Private Placement”) and received
net proceeds of approximately $227.3 million.

In  September  2019,  we  submitted  a  NDA  to  the  FDA  seeking  accelerated  approval  of  OCA  for  liver  fibrosis  due  to
NASH.  In  November  2019,  the  FDA  accepted  our  NDA  for  filing  and  granted  a  priority  review  designation  for  OCA  for
liver fibrosis due to NASH. Under PDUFA, the FDA has set a target action date of June 26, 2020 for the completion of its
review of our NDA, after giving effect to a 90-day extension of its initial target action date. The FDA has also notified us that
it has tentatively scheduled an advisory committee meeting relating to our NDA for April 22, 2020.

In  December  2019,  we  submitted  a  MAA  to  the  EMA  seeking  conditional  approval  of  OCA  for  liver  fibrosis  due  to
NASH. In January 2020, the EMA validated our MAA and thereby confirmed that our MAA was sufficiently complete to
begin the formal review process.

For  information  regarding  our  financial  condition  and  results  of  operations,  including  our  revenues,  net  loss  and  total
assets,  see  our  audited  consolidated  financial  statements  and  accompanying  notes  and  “Management’s  Discussion  and
Analysis of Financial Condition and Results of Operations” included elsewhere in this Annual Report on Form 10-K.

Our First Approved Product  

Ocaliva

Ocaliva was approved for PBC by the FDA in May 2016 under the accelerated approval pathway. We commenced sales
and marketing of Ocaliva in the United States shortly after receiving approval, and Ocaliva is now available to U.S. patients
primarily  through  a  network  of  specialty  pharmacy  distributors.  Ocaliva  received  conditional  approval  for  PBC  from  the
European Commission in December 2016 and we commenced our European commercial launch in January 2017. We have
submitted dossiers and obtained, or are otherwise pursuing, reimbursement from a number of national authorities in Europe.
Since January 2017, Ocaliva has also received regulatory approval in several of our target markets outside the United States
and Europe, including Canada, Israel and Australia, and we are pursuing marketing approval of Ocaliva for PBC in our other
international target markets. Ocaliva received orphan drug designation in both the United States and the European Union for
the treatment of PBC.

Overview of PBC

PBC is a rare liver disease that primarily results from autoimmune destruction of the bile ducts that transport bile acids
out of the liver, resulting in cholestasis. The build-up of bile acids in the liver damages liver cells. These damaged liver cells,
in  turn,  release  abnormal  amounts  of  serum  alkaline  phosphatase  (“ALP”),  a  liver  enzyme  that  is  a  key  biomarker  of  the
disease  pathology.  As  shown  in  numerous  clinical  trials  of  treatment  with  UDCA  (available  generically  as  ursodiol),  a
positive  therapeutic  response  is  primarily  determined  by  sustained  reduction  of  ALP  levels,  along  with  maintenance  of
normal bilirubin levels, indicating adequately compensated liver function. This biochemical improvement has been shown to
correlate  well  with  improved  clinical  outcomes  such  as  transplant-free  survival.  As  the  disease  progresses,  it  causes
progressive  liver  damage  marked  by  chronic  inflammation  and  fibrosis.  Despite  its  rarity,  PBC  is  the  most  common
cholestatic liver disease and is among the leading indications for liver transplant among women in the United States.

4

Table of Contents

Disease  progression  in  PBC  varies  significantly,  with  median  survival  in  untreated  patients  estimated  to  be  7.5  years  if
symptomatic at diagnosis and up to 16 years if asymptomatic at diagnosis. PBC patients whose disease is progressing have
persistently elevated levels of ALP and other liver enzymes, with abnormal bilirubin levels heralding more advanced disease.
Data  from  published  long-term  studies  demonstrate  that  a  significant  portion  of  such  patients  with  advancing  disease
progress to liver failure, transplant or death within five to ten years.

Based on our analysis of 2016 industry data, there were approximately 290,000 people with PBC at the time of our U.S.
launch  in  the  United  States,  certain  European  countries,  Canada,  Australia  and  New  Zealand.  An  estimated  90%  of  PBC
patients are women, with approximately one in 1,000 women over the age of 40 afflicted by the disease. The mean age of
diagnosis is about 40 years old and the typical initial presentation occurs between the ages of 30 and 65 years old. A majority
of PBC patients are asymptomatic at the time of initial diagnosis, but most develop symptoms over time. Fatigue and pruritus
are the most common symptoms in PBC patients. Less common symptoms include dry eyes and mouth, as well as jaundice,
which can be seen in more advanced disease. Based on the guidelines of the American Association for the Study of Liver
Disease and the European Association for the Study of the Liver, the clinical diagnosis of PBC is established based on the
presence of (i) a positive antimitochondrial antibody (“AMA”), a marker of this autoimmune disease seen in up to 95% of
PBC patients and (ii) elevated serum levels of ALP. In the earlier stages of PBC, ALP is often the only abnormally elevated
liver enzyme, rising to between two to ten times higher than normal values. Bilirubin is a marker of liver function and is also
monitored  in  PBC  to  provide  an  indication  of  how  well  the  liver  is  functioning.  Liver  biopsy  can  be  used  to  confirm  the
diagnosis of PBC, but is not required and is becoming less-frequently performed.

A  number  of  published  clinical  studies  have  demonstrated  that  lower  levels  of  ALP,  both  independently  or  in
conjunction  with  normal  bilirubin  levels,  correlate  with  a  significant  reduction  in  adverse  clinical  outcomes  such  as  liver
transplant and/or death in PBC patients. These studies include the result of meta-analyses of PBC clinical outcomes data of
more than 6,000 PBC patients from 15 academic centers in eight countries that have been compiled by the Global PBC Study
Group, which we sponsored, as well as a dataset of over 6,000 PBC patients across the United Kingdom compiled by the UK
PBC Group.

Prior to Ocaliva, the only approved drug indicated for the treatment of PBC was UDCA, which is widely considered the
standard first-line therapy for PBC patients. In patients for whom UDCA is effective, the treatment slows the progression of
PBC, reducing the likelihood of liver failure and the need for transplant.

Phase 3 POISE Trial

Ocaliva’s accelerated approval in the United States and conditional approval in the European Union was supported by
the  results  of  our  Phase  3  POISE  trial,  which  was  completed  in  March  2014.  The  data  from  the  POISE  trial  showed  that
Ocaliva, at both a once-daily 10 mg dose and a once-daily 5 mg dose titrated to 10 mg, met the trial’s primary endpoint of
achieving a reduction in ALP to below a threshold of 1.67 times the upper limit of normal (“ULN”), with a minimum of a
15%  reduction  in  ALP  level  from  baseline,  and  a  normal  bilirubin  level  after  12  months  of  therapy.  The  percentage  of
patients meeting the POISE trial’s primary endpoint was 10% in the placebo group, 47% in the 10 mg Ocaliva group and
46% in the Ocaliva titration group (both dose groups p < 0.0001 as compared to placebo) in an intent-to-treat analysis. The
placebo group experienced a mean decrease in ALP from baseline of 5%, compared to a mean decrease of 39% in the 10 mg
Ocaliva dose group and 33% in the Ocaliva titration group (both dose groups p < 0.0001 as compared to placebo). Pruritus,
generally  mild  to  moderate,  was  the  most  frequently  reported  adverse  event  associated  with  Ocaliva  treatment  and  was
observed  in  38%  of  patients  on  placebo,  70%  of  patients  in  the  10  mg  Ocaliva  group  and  56%  of  patients  in  the  Ocaliva
titration group. Eight patients discontinued due to pruritus, of whom none were in the placebo group, seven (10%) were in
the 10 mg Ocaliva group and one (1%) was in the Ocaliva titration group. Decreases in high density lipoprotein (“HDL”)
cholesterol were also observed during treatment.

Following the completion of the double-blind portion of the POISE trial described above, patients were given the option
to enroll in a five-year open-label long-term safety and efficacy extension trial. Patients received Ocaliva at a once-daily 5
mg  dose  for  three  months,  after  which  patients  were  titrated  based  on  tolerability. The  data  from  the  open-label  extension
portion of the trial showed that 46% of patients responded after 12 months of treatment with Ocaliva and 50% to 56% of
patients responded after 48 to 72 months of treatment with Ocaliva (based on the same criteria used to define

5

Table of Contents

the primary endpoint in the 12 month placebo controlled trial). Reductions in ALP were sustained through the double-blind
and extension portions of the trial and total bilirubin levels remained stable and within the normal range for most patients for
the duration of the trial (ALP p < 0.0001 for all post-baseline visits; total bilirubin: p-values were not consistently significant
throughout the extension portion of the POISE trial). Adverse events were consistent with the safety profile of Ocaliva in
patients  with  PBC.  The  most  commonly  reported  adverse  events  were  pruritis  and  fatigue,  which  were  generally  mild  to
moderate in severity.

Ongoing Confirmatory Clinical Outcomes Trial and Other Post Marketing Requirements

In connection with Ocaliva’s accelerated approval in the United States and conditional approval in the European Union,
we committed to conduct a Phase 4 confirmatory outcomes trial of Ocaliva, known as the COBALT trial, and other clinical
trials to satisfy post-marketing regulatory requirements. In addition, we have agreed to develop and characterize a lower dose
formulation of Ocaliva to allow for once daily dosing in patients with moderate or advanced hepatic impairment. Continued
approval  of  Ocaliva  for  PBC  in  the  United  States,  the  European  Union  and  other  jurisdictions  is  contingent  upon  the
verification  and  description  of  clinical  benefit  in  the  COBALT  trial  and  our  satisfaction  of  our  other  post-marketing
regulatory requirements. Any delay or failure by us to satisfy such requirements, including any delay or failure relating to our
Phase 4 COBALT trial, may jeopardize the continued approval of Ocaliva for PBC in the United States, European Union and
other jurisdictions.

The goal of the COBALT trial is to confirm that reduction of ALP based upon Ocaliva treatment is associated with a
longer-term  benefit  on  liver-related  clinical  outcomes.  This  trial  is  currently  enrolling  patients  and  is  expected  to  be
completed on a post-marketing basis. COBALT is designed to assess the effect of a once-daily dose of 5 mg or 10 mg of
Ocaliva in approximately 430 PBC patients with an inadequate therapeutic response to UDCA or who are unable to tolerate
UDCA. In this trial, eligible patients with PBC continue their UDCA treatment, except for those patients unable to tolerate
UDCA,  and  are  being  randomized  into  one  of  two  treatment  arms  of  approximately  215  patients  each.  Patients  are
randomized to receive either (i) placebo or (ii) Ocaliva starting at 5 mg and increasing over the course of the trial to 10 mg of
Ocaliva  based  on  tolerability.  Dosing  frequency  will  be  determined  by  disease  stage.  The  primary  endpoint  of  the  trial  is
based on clinical outcomes as measured by time to first occurrence of any of the following adjudicated events: death (all-
cause),  liver  transplant,  Model  of  End  Stage  Liver  Disease  (“MELD”)  score  greater  than  15,  uncontrolled  ascites  or
hospitalization  due  to  variceal  bleeding,  hepatic  encephalopathy  or  spontaneous  bacterial  peritonitis.  The  study  evaluates
subjects across the spectrum of PBC disease, including early and advanced PBC.

In  addition,  we  are  undertaking  a  Phase  2  clinical  trial  of  Ocaliva  in  pediatric  patients  with  biliary  atresia,  a  life-
threatening condition in infants in which the bile ducts inside or outside the liver do not have normal openings. This trial,
known  as  the  CARE  trial,  is  a  part  of  an  EMA-approved  Pediatric  Investigation  Plan  (“PIP”)  supporting  the  conditional
approval of Ocaliva for PBC in the European Union as PBC is not believed to occur in the pediatric population. The CARE
trial is designed to evaluate the effects of 11 weeks of Ocaliva treatment where patients with biliary atresia are randomized to
varying doses. The primary endpoint is to evaluate the pharmacokinetics and the safety and tolerability of Ocaliva treatment.
In  addition,  Ocaliva’s  effect  on  hepatobiliary  indices  and  biomarkers  will  be  assessed.  This  trial  is  targeted  to  enroll
approximately 60 patients in the United States and Europe.

Further, as part of our post-marketing requirements for Ocaliva, we are undertaking a Phase 4 clinical trial of Ocaliva in
patients  with  PBC  who  have  moderate  to  severe  hepatic  impairment  (Child-Pugh  B  and  C).  This  double-blind,  placebo-
controlled study is designed to evaluate the pharmacokinetics of Ocaliva and its conjugates, as well as safety and tolerability.
Additional  objectives  include  an  evaluation  of  Ocaliva  treatment  compared  to  placebo  on  liver  biochemistry,  Child-Pugh
scores and non-invasive markers of liver fibrosis and stiffness. This double blind trial is targeted to enroll approximately 50
patients in the United States, Europe and other jurisdictions for 48 weeks.

Ocaliva Label Update

In  the  course  of  our  post-marketing  pharmacovigilance  activities,  deaths  have  been  reported  in  PBC  patients  with
moderate or severe hepatic impairment. In an analysis performed by us and in consultation with the FDA, we concluded that
certain  of  these  patients  were  prescribed  once  daily  doses  of  Ocaliva,  which  is  seven  times  higher  than  the  recommended
weekly dose in such patients. As a result, in September 2017, we issued a Dear Health Care Provider

6

Table of Contents

(“DHCP”) letter, and the FDA also subsequently issued its own drug safety communication to reinforce recommended label
dosing. Both communications remind healthcare providers of the importance of the recommended reduced dosing of Ocaliva
in PBC patients with moderate or severe hepatic impairment, while reiterating the importance of monitoring PBC patients for
progression  of  their  disease  and  the  occurrence  of  liver-related  adverse  reactions.  In  addition  to  the  DHCP  letter,  we  took
actions  to  enhance  education  about  appropriate  use  of  Ocaliva.  These  initiatives  included:  reeducating  physicians  on  the
label,  with  a  focus  on  ensuring  appropriate  dosing  for  patients  with  moderate  or  severe  hepatic  impairment;  enhancing
monitoring of patients for liver-related adverse reactions; and adjudicating reported cases of serious liver injury, including in
patients with no or mild hepatic impairment.

In February 2018, we announced that the Ocaliva label in the United States had been updated by the FDA to include a
boxed warning and a dosing table that reinforced the then-existing dosing schedule for patients with Child-Pugh Class B or C
or decompensated cirrhosis. In addition, the FDA issued an updated drug safety communication to accompany the revised
label. We remain focused on the safety of all of the patients using Ocaliva within and outside of our ongoing clinical studies
and have engaged with relevant regulatory authorities to ensure that the Ocaliva label sufficiently reinforces the importance
of appropriate dosing in patients with advanced cirrhosis.

Our Product Candidates

The  following  summarizes  the  current  status  and  the  anticipated  next  steps  in  our  development  plans  for  our  product
candidates.  We  continually  evaluate  each  product  candidate  in  an  effort  to  efficiently  allocate  research  and  development
funds to projects we deem to be in our best interests based on, among other factors, the product candidate’s performance in
pre-clinical  and/or  clinical  studies,  our  expectations  regarding  the  potential  future  regulatory  approval  of  the  product
candidate and our view of the potential commercial viability of the product candidate in light of market conditions.

OCA for liver fibrosis due to NASH

Our  lead  product  candidate  is  OCA  for  the  potential  treatment  of  liver  fibrosis  due  to  NASH.  In  February  2019,  we
announced topline results from the planned 18-month interim analysis of our pivotal Phase 3 clinical trial of OCA in patients
with liver fibrosis due to NASH, known as the REGENERATE trial. In the primary efficacy analysis, once-daily OCA 25 mg
met the primary endpoint agreed with the FDA of fibrosis improvement by at least one stage with no worsening of NASH at
the planned 18-month interim analysis. Adverse events were generally mild to moderate in severity and the most common
were consistent with the known profile of OCA. OCA has received breakthrough therapy designation from the FDA for the
treatment  of  NASH  patients  with  liver  fibrosis.  In  September  2019,  we  submitted  a  NDA  seeking  accelerated  approval  of
OCA for liver fibrosis due to NASH in the United States and, in December 2019, we submitted a MAA seeking conditional
approval of OCA for liver fibrosis due to NASH in Europe. The FDA subsequently accepted our NDA for filing and granted
a priority review designation for OCA for liver fibrosis due to NASH. The FDA has set a PDUFA target action date of June
26,  2020  for  the  completion  of  its  review  of  our  NDA  and  has  notified  us  that  it  has  tentatively  scheduled  an  advisory
committee  meeting  relating  to  our  NDA  for  April  22,  2020.  In  January  2020,  the  EMA  validated  our  MAA  and  thereby
confirmed  that  our  MAA  was  sufficiently  complete  to  begin  the  formal  review  process.  In  addition,  we  are  conducting  a
number of other trials and studies in connection with our NASH development program, including our ongoing Phase 3 trial
in NASH patients with compensated cirrhosis, known as the REVERSE trial.

Overview of NASH

NASH  is  a  serious  progressive  liver  disease  caused  by  excessive  fat  accumulation  in  the  liver  (steatosis)  that  induces
chronic inflammation, resulting in progressive fibrosis (scarring) that can lead to cirrhosis, eventual liver failure, cancer and
death.  More  than  20%  of  patients  with  NASH  are  estimated  to  progress  to  cirrhosis  within  a  decade  of  diagnosis  and,
compared to the general population, have a ten-fold greater risk of liver-related mortality. The proportion of liver transplants
attributable to NASH has increased rapidly in recent years and as early as 2020 the disease is projected to become the leading
cause  of  liver  transplants  in  the  United  States.  Additionally,  NASH  is  now  considered  to  be  the  leading,  and  a  rapidly
increasing, cause of hepatocellular carcinoma (primary liver cancer), of which up to 40% of cases in NASH patients develop
prior to developing cirrhosis.

7

Table of Contents

Although  difficult  to  precisely  estimate,  epidemiology  research  estimates  that  the  global  prevalence  of  NASH  is
approximately  3  –  5%  and  is  expected  to  increase  markedly  by  2030.  Fibrosis  is  the  most  robust  predictor  of  long-term
overall  mortality,  liver  transplantation  and  liver-related  events  in  patients  with  NASH  and  advanced  fibrosis  is  associated
with a substantially higher risk of liver-related morbidity and mortality in patients with NASH. We believe that a majority of
NASH patients diagnosed and under specialist care have fibrosis of stage 2 or greater. Although the prevalence of NASH is
lower  in  children,  it  has  also  become  a  serious  disease  burden  in  the  pediatric  population.  Other  common  co-existing
conditions  such  as  obesity  and  type  2  diabetes,  which  are  present  in  a  majority  of  NASH  patients,  raise  important  risks.
NASH  has  been  linked  in  both  developed  and  developing  countries  to  the  adoption  of  a  Western  diet,  with  increased
consumption of processed foods containing polyunsaturated fatty acids and fructose.

Generally in clinical trials in NASH, a definitive diagnosis requires a histologic assessment of a liver biopsy for several
key features associated with NASH, including, but not limited to, steatosis, lobular inflammation and hepatocyte ballooning.
However, we believe that the majority of NASH patients currently under treater care have been assessed for liver fibrosis
without  a  liver  biopsy.  Several  imaging  and  circulating  biomarkers  are  being  investigated  as  non-invasive  diagnostic
methods,  including  transient  elastography  (an  ultrasound  technology  approved  in  the  United  States  and  Europe  for  the
measurement  of  liver  fibrosis),  magnetic  resonance  imaging  and  serum  biomarkers.  NASH  diagnosis  rates  in  the  United
States  and  the  EU5  countries  are  very  low,  owing  to  a  lack  of  approved  treatment  options  and  a  lack  of  validated  non-
invasive  diagnosis  options.  We  believe  the  availability  of  novel  therapeutics  and  non-invasive  technologies  will  be
instrumental in improving diagnosis rates.

There are currently no medications approved for the treatment of NASH. However, various therapeutics are used “off-
label”, such as vitamin E (an antioxidant), insulin sensitizers (e.g., metformin, pioglitazone), antihyperlipidemic agents (e.g.,
gemfibrozil),  pentoxifylline  and  UDCA.  Lifestyle  changes,  including  modification  of  diet  and  exercise  to  reduce  body
weight, as well as treatment of concomitant diabetes and dyslipidemia, are commonly accepted as the standard of care, but
have not conclusively been shown to prevent disease progression. Although some of the off-label treatments described above
have been studied as possible treatments for NASH, none has been approved by the FDA or EMA as a treatment for this
disease. Currently, treatment options for NASH patients with advanced cirrhosis are limited. Although liver transplant can be
life-saving, many patients fail to receive a donor organ in time, and for those who do, there are very significant clinical risks,
such as infection and organ rejection, as well as significant costs. In addition, the post-transplant recurrence rate of NASH
has been shown to be as high as 25% at 18 months. Given the lack of available treatment options, we believe that there is a
significant unmet need for novel therapies for NASH, particularly in those patients with advanced fibrosis and cirrhosis and
those with a high risk of disease progression due to other co-morbidities such as type 2 diabetes.

FXR  activation  has  been  shown  to  play  a  key  role  in  the  regulation  of  the  metabolic  pathways  relevant  to  NASH,
highlighting FXR as a potential drug target for treatment of the disease. Given the significant unmet medical need of patients
with  NASH,  we  believe  that  the  ability  of  OCA  to  potently  activate  FXR  has  the  potential  to  convey  clinical  benefit  by
improving key histologic parameters of the disease. This is supported by our preclinical and clinical results to date, and is
being further investigated in our ongoing clinical trial program.

Phase 3 REGENERATE Trial

We are currently conducting a pivotal Phase 3 clinical trial of OCA in patients with liver fibrosis due to NASH, known
as the REGENERATE trial. REGENERATE is a randomized, double-blind, placebo-controlled, multicenter study assessing
the safety and efficacy of OCA on liver-related clinical outcomes in patients with liver fibrosis due to NASH. Patients with
biopsy  proven  NASH  with  fibrosis  are  randomized  1:1:1  to  receive  placebo,  OCA  10  mg  or  OCA  25  mg  once  daily.  In
August 2019, we announced the completion of the enrollment of the clinical outcomes cohort of REGENERATE, with 2,480
adult  NASH  patients  with  fibrosis  randomized  at  over  300  qualified  centers  worldwide.  REGENERATE  will  continue
through  clinical  outcomes  for  verification  and  description  of  clinical  benefit.  The  end-of-study  analysis  will  evaluate  the
effect of OCA on all-cause mortality and liver-related clinical outcomes.

An 18-month interim analysis was conducted to assess the effect of OCA in liver histology comparing month 18 biopsy
with baseline. Patients without a repeat biopsy due to study discontinuation or other reason were treated as non-responders in
the primary efficacy analysis and full efficacy analysis (each as described below). A smaller exploratory cohort of patients
with stage 1 liver fibrosis and at least one accompanying comorbidity (specified as diabetes, obesity or

8

Table of Contents

alanine transaminase (“ALT”) greater than 1.5 times ULN) were also enrolled in REGENERATE, but were not included in
the  primary  efficacy  analysis.  As  described  below,  these  patients  were  included  in  the  full  efficacy  analysis  and  safety
analysis. The end-of-study analysis will evaluate the effect of OCA on all-cause mortality and liver-related clinical outcomes.

In February 2019, we announced topline results from the REGENERATE trial. In the primary efficacy analysis, once-
daily OCA 25 mg met, with statistical significance, the primary endpoint agreed with the FDA of fibrosis improvement by at
least one stage with no worsening of NASH (defined as no worsening of hepatocellular ballooning, no worsening of lobular
inflammation  and  no  worsening  of  steatosis)  at  the  planned  18-month  analysis  and  adverse  events  were  generally  mild  to
moderate in severity and the most common were consistent with the known profile of OCA. Although a numerically greater
proportion of patients in both OCA treatment arms compared to placebo achieved the primary endpoint of NASH resolution
with no worsening of liver fibrosis in the primary efficacy analysis, this result did not reach statistical significance. NASH
resolution is defined as the overall histopathologic interpretation of (i) no fatty liver disease or (ii) fatty liver disease (simple
or isolated steatosis) without steatohepatitis AND a nonalcoholic fatty liver disease (“NAFLD”) activity score (“NAS”) of 0
for ballooning and 0-1 for inflammation. As agreed with the FDA, in order for the primary objective to be met, the study was
required to achieve one of the two primary endpoints. In November 2019, the results of the 18-month interim analysis from
the REGENERATE trial were published in The Lancet.

The “primary efficacy analysis” (Intent-to-Treat or “ITT”) assessed efficacy at 18 months in 931 patients with stage 2 or
3  liver  fibrosis  due  to  NASH.  Overall  study  discontinuations  in  the  primary  efficacy  analysis  population  were  balanced
across  treatment  arms:  16%  in  placebo,  17%  in  OCA  10  mg  and  15%  in  OCA  25  mg.  An  additional  pre-specified  “full
efficacy analysis” at 18 months added an exploratory cohort of 287 NASH patients with stage 1 liver fibrosis and additional
risk factors who were at increased risk of progression to cirrhosis (N = 1,218).

Set forth below is a summary of the 18-month primary efficacy analysis and additional full efficacy analysis from the

REGENERATE trial.

Fibrosis Improvement at Month 18

Primary Efficacy Analysis 
(ITT population: NASH with stage 2 and 3 liver fibrosis)

Fibrosis improvement (≥ 1 stage) with no worsening of NASH*

Additional Full Efficacy Analysis  
     (ITT population plus stage 1 liver fibrosis patients)
Fibrosis improvement (≥ 1 stage) with no worsening of NASH*

Placebo
n = 311

11.9%

Placebo 
n=407
10.6%

OCA 10 mg
n = 312

OCA 25 mg
n= 308

17.6%
p = 0.0446
OCA 10 mg
n = 407
15.7%
p = 0.0286

23.1%
p = 0.0002**
OCA 25 mg
n = 404
21.0%
p < 0.0001

*    Defined as no worsening of hepatocellular ballooning, no worsening of lobular inflammation and no worsening of 
steatosis.
** Statistically significant in accordance with the statistical analysis plan agreed with the FDA.

9

Table of Contents

NASH Resolution at Month 18

Primary Efficacy Analysis
(ITT population: NASH with stage 2 and 3 liver fibrosis
NASH resolution‡ with no worsening of liver fibrosis stage

OCA 25 mg
n = 308
11.7%
p = 0.1268
OCA 25 mg
n = 404
14.9%
p = 0.0013
‡ Defined as the overall histopathologic interpretation of (i) no fatty liver disease or (ii) fatty liver disease (simple or isolated
steatosis) without steatohepatitis AND a NAS of 0 for ballooning and 0-1 for inflammation.

Additional Full Efficacy Analysis
    (ITT population plus stage 1 liver fibrosis patients)
NASH resolution‡ with no worsening of liver fibrosis stage

OCA 10 mg
n = 312
11.2%
p = 0.1814
OCA 10 mg
n = 407
11.3%
p = 0.0903

Placebo
n = 407
7.9%

Placebo
n = 311
8.0%

The “safety population” in the planned 18-month analysis of REGENERATE included 1,968 randomized patients who

received at least one dose of investigational product (OCA or placebo).

Adverse  events  were  generally  mild  to  moderate  in  severity  and  the  most  common  were  consistent  with  the  known
profile of OCA. The frequency of serious adverse events was similar across treatment arms (11% in placebo, 11% in OCA 10
mg and 14% in OCA 25 mg) and no serious adverse event occurred in > 1% of patients in any treatment arm. There were 3
deaths (2 in placebo: bone cancer and cardiac arrest, 1 in OCA 25 mg: glioblastoma) and none were considered related to
treatment.

The most common adverse event reported was dose-related pruritus (19% in placebo, 28% in OCA 10 mg and 51% in
OCA 25 mg). The large majority of pruritus events were mild to moderate, with severe pruritus occurring in a small number
of  patients  (<  1%  in  placebo,  <  1%  in  OCA  10  mg  and  5%  in  OCA  25  mg).  A  higher  incidence  of  pruritus  associated
treatment discontinuation was observed for OCA 25 mg (< 1% in placebo, < 1% in OCA 10 mg and 9% in OCA 25 mg).
According to the clinical study protocol, investigator assessed severe pruritus mandated treatment discontinuation.

Consistent  with  observations  from  previous  NASH  studies,  OCA  treatment  was  associated  with  an  increase  in  low
density lipoprotein (“LDL”) cholesterol, with a peak increase of 22.6 mg/dL at four weeks and subsequently reversing and
approaching baseline at month 18 (4.0 mg/dL increase from baseline). Statin therapy was initiated in 10% of placebo patients
and 24% of each OCA treatment arm. Among OCA patients who initiated statins, LDL cholesterol increases reversed and
fell to below baseline levels by month 6. Triglycerides rapidly and continually decreased in the OCA treatment arms through
month 18. There were few and varied serious cardiovascular events and incidence was balanced across the three treatment
arms (2% in placebo, 1% in OCA 10 mg and 2% in OCA 25 mg).

In patients with type 2 diabetes, OCA treatment was associated with an early transient increase in fasting glucose and
hemoglobin A1c with return to levels similar to placebo by month 6. No clinically meaningful changes were noted in non-
diabetic patients.

With  respect  to  hepatobiliary  events,  more  patients  (3%)  on  OCA  25  mg  experienced  gallstones  or  cholecystitis
compared to < 1% on placebo and 1% on OCA 10 mg. While numerically higher in the OCA 25 mg treatment arm, serious
hepatic adverse events were uncommon with < 1% incidence in each of the three treatment arms.

Phase 3 REVERSE Trial

We  are  currently  conducting  a  Phase  3  clinical  trial  in  NASH  patients  with  compensated  cirrhosis,  known  as  the
REVERSE  trial.  REVERSE  is  a  randomized,  double-blind,  placebo-controlled,  multicenter  trial  evaluating  the  safety  and
efficacy  of  OCA  in  NASH  patients  with  compensated  cirrhosis.  In  January  2020,  we  announced  that  we  completed
enrollment  of  the  REVERSE  trial  with  over  900  patients  with  a  biopsy-confirmed  diagnosis  of  cirrhosis  due  to  NASH
randomized.

10

Table of Contents

The primary endpoint for REVERSE is the percentage of subjects with histological improvement in fibrosis by at least
one  stage  with  no  worsening  of  NASH  using  the  NASH  Clinical  Research  Network  scoring  system  after  18  months  of
treatment. Patients are randomized 1:1:1 into one of three treatment arms receiving a once-daily dose of placebo, OCA 10
mg or OCA 10 mg for the first three months with titration in accordance with the study protocol up to OCA 25 mg for the
remaining study period. Patients who successfully complete the double-blind phase of REVERSE will be eligible to enroll in
an open-label extension phase for up to 12 additional months.

Phase 2 CONTROL Trial

In December 2015, we initiated a Phase 2 clinical trial, known as the CONTROL trial, to characterize the lipid metabolic
effects  of  OCA  and  cholesterol  management  effects  of  concomitant  statin  administration  in  NASH  patients.  CONTROL
enrolled approximately 80 NASH patients who were naïve to statin therapy or had undergone a statin washout period. Statin-
naïve or washout patients were randomized to receive one of three doses of OCA (5 mg, 10 mg or 25 mg) or placebo. The
study included a 16-week double-blind phase followed by an optional long-term safety extension (“LTSE”).

In July 2017, we announced that CONTROL met its primary objective by showing that newly initiated treatment with
atorvastatin rapidly reversed OCA-associated increases in LDL cholesterol to below baseline levels. Most of the effect was
observed  four  weeks  after  initiation  of  the  lowest  available  dose  of  atorvastatin  and  was  sustained  throughout  the  study
period. OCA treatment in the absence of statin therapy over the first four weeks resulted in an increase in LDL cholesterol
across all OCA treatment groups, while the placebo group was relatively unchanged. Treatment with atorvastatin beginning
at week four and continuing through week 16 reversed OCA-related increases in LDL cholesterol to below baseline levels in
all  OCA  treatment  groups.  Dose-dependent  pruritus  was  the  most  common  adverse  event  in  patients  treated  with  OCA,
occurring in 5% of patients on placebo, 5% of patients in the OCA 5 mg group, 10% of patients in the OCA 10 mg group and
55% of patients in the OCA 25 mg group. All adverse events were mild to moderate and two patients discontinued treatment
in the OCA 25 mg group due to pruritus. Over 95% of the patients completing the double-blind phase of CONTROL enrolled
in  the  LTSE  phase  of  the  trial.  During  the  LTSE  phase  of  CONTROL,  there  was  one  patient  death,  which  the  principal
investigator determined was unlikely related to OCA.

Phase 2 Sumitomo Dainippon Trial

In October 2015, we announced the results of a 72-week Phase 2 dose ranging trial of OCA in 200 adult patients with
NASH in Japan. The trial was conducted by our former collaborator, Sumitomo Dainippon Pharma Co., Ltd. (“Sumitomo
Dainippon”). In this trial, 202 Japanese biopsy-proven NASH patients (NAS of 5-8) were randomized into one of four arms
to  receive  either  a  10  mg,  20  mg  or  40  mg  dose  of  OCA  or  placebo,  and  200  of  these  patients  (50  per  group)  initiated
treatment for a 72-week double-blind treatment phase, followed by a 24-week off treatment phase. The primary endpoint was
histologic improvement defined as at least a two-point improvement in NAS with no worsening of fibrosis.

The primary efficacy analysis was conducted on an ITT basis, testing the dose dependent effects of once daily OCA (10
mg,  20  mg  and  40  mg)  versus  placebo  on  the  primary  endpoint.  The  ITT  analysis  included  all  randomized  patients  who
received  treatment  (50  per  group),  and  patients  who  discontinued  or  did  not  have  a  repeat  biopsy  were  treated  as  non-
responders.  A  pre-specified  completer  analysis  was  conducted  on  the  patients  who  had  biopsies  at  both  baseline  and  72
weeks (45, 44, 44 and 37 patients in the placebo, OCA 10 mg, OCA 20 mg and OCA 40 mg groups, respectively).

The Sumitomo Dainippon trial did not meet statistical significance for the primary endpoint. The ITT results in the table
below  show  a  dose  dependent  increase  in  the  percentage  of  OCA-treated  patients  compared  to  placebo  who  achieved  the
primary  endpoint  (p  =  0.053).  Dose-dependent  trends  not  reaching  statistical  significance  were  observed  for  several  other
pre-specified histologic endpoints, including the percentage of patients with steatosis and inflammation

11

Table of Contents

improvement,  ballooning  resolution  and  NASH  resolution.  No  difference  was  seen  in  fibrosis  improvement  in  the  OCA
groups compared to placebo.

ITT Results
NAS improvement > 2 points with
   no worsening of fibrosis

Placebo
N = 50
10 (20%)  

OCA 10 mg
N = 50
11 (22%)
p = 0.8070** 

OCA 20 mg
N = 50
14 (28%)
p = 0.3378** 

OCA 40 mg
N = 50
19 (38%)
p = 0.0496** 

p = 0.053*

*            Primary  efficacy  analysis  is  a  stratified  Cochran-Armitage  test  with  multiple  contrast  coefficients.  Statistical

significance is based on a p-value < 0.05.

**    The secondary efficacy analysis is a Cochran-Mantel-Haenszel (“CMH”) test stratified by baseline fibrosis stage for

Pairwise comparison of each OCA group compared to the placebo group. The multiplicity was not adjusted.

In the completer analysis, similar dose dependent effects were observed, with 51% of patients in the OCA 40 mg dose

group compared to 22% in the placebo group meeting the primary endpoint (p = 0.0061).

With the exception of dose dependent pruritus, OCA appeared to be generally safe and well tolerated. The number of
pruritus associated discontinuations were 0, 0, 2 and 5 patients in the placebo, OCA 10 mg, OCA 20 mg and OCA 40 mg
groups, respectively. Changes in lipid parameters, including LDL cholesterol, HDL cholesterol and triglycerides, appeared to
be consistent with previously reported lipid changes in Western NASH patients. No other meaningful differences in the rate
of adverse events between the OCA and placebo groups were noted.

Phase 2b FLINT Trial

In  November  2014,  the  results  from  a  Phase  2b  clinical  trial  for  the  treatment  of  NASH,  known  as  the  FLINT  trial,
which was sponsored by the NIDDK, a part of the National Institutes of Health, were published in The Lancet. The FLINT
trial was a double-blind, placebo-controlled trial of a once-daily dose of OCA 25 mg or placebo given for 72 weeks in 283
patients  with  biopsy-proven  NASH.  OCA  achieved  the  primary  endpoint  in  the  FLINT  trial,  which  was  defined  as  an
improvement of two or more points in NAS with no worsening of liver fibrosis.

The  percentage  of  patients  meeting  the  primary  histological  endpoint,  based  on  liver  biopsies,  in  the  FLINT  trial  was
45% in the OCA treatment group and 21% in the placebo group (p = 0.0002, n = 219). The mean pre-treatment baseline NAS
for  patients  in  the  OCA  treatment  group  was  5.3  of  a  total  possible  score  of  eight  (comprised  of  a  NAS  of  0-2  for
hepatocellular  ballooning,  0-3  for  lobular  inflammation  and  0-3  for  steatosis).  Subgroup  analyses  showed  significant
response rates in the OCA treatment group in patients with risk factors for disease progression, including baseline fibrosis
stage,  co-morbid  type  2  diabetes  mellitus,  ALT,  insulin  resistance  and  severe  obesity  (each  factor  p  <  0.05  for  OCA
compared to placebo based on 95% confidence interval of published odds ratios).

A significantly greater number of OCA-treated patients also achieved the secondary endpoint of improvement of at least
one fibrosis stage (35% versus 19%, p = 0.004), with OCA showing greater response rates as compared to placebo across all
stages  of  fibrosis.  Based  on  our  retrospective  analyses  of  the  FLINT  data,  more  OCA-treated  patients  exhibited  fibrosis
improvement of at least two fibrosis stages (15% versus 6%, not significant) and exhibited fibrosis improvements regardless
of baseline fibrosis stage and a significantly greater number of OCA-treated patients also achieved complete resolution of
fibrosis (17% versus 5%, p = 0.0018). Also, our retrospective analysis of the FLINT data showed that fewer OCA-treated
patients  progressed  to  bridging  fibrosis  (15%  versus  18%,  not  significant)  or  to  cirrhosis  (2%  versus  5%,  not  significant).
Retrospective analyses after the unblinding of results can potentially introduce bias and regulatory authorities typically give
greatest weight to results from pre-specified analyses as compared to retrospective analyses. The NASH Clinical Research
Network fibrosis staging system was used to categorize the pattern of fibrosis and architectural remodeling of the liver: no
fibrosis (F0), perisinuoidal or periportal fibrosis (F1), perisinusoidal and periportal fibrosis (F2), bridging fibrosis (F3) and
cirrhosis (F4). Fibrosis sub-stages 1a, 1b and 1c were considered F1 for the analysis.

The  secondary  endpoint  of  NASH  resolution,  based  on  a  global  histological  assessment,  also  showed  improvement,

although not statistically significant (22% versus 13%, p = 0.0832). A central reading of all baseline and end-of-trial

12

    
    
    
    
       
  
 
 
  
 
  
Table of Contents

biopsies was performed at the end of the trial, based on which only 80% of patients were confirmed to have definite NASH,
while the remaining 20% were diagnosed as borderline NASH (10%) or not-NASH (10%). A retrospective subgroup analysis
on the completer population comprised only of definite NASH patients at baseline showed that a significantly greater number
of OCA-treated patients achieved NASH resolution compared with placebo-treated patients (19% versus 8%; p = 0.0278).

In  an  additional  retrospective  analysis  of  data  from  the  FLINT  trial  conducted  in  a  REGENERATE-matched  patient
cohort published in 2018, (i) approximately 40% of OCA-treated patients as compared to approximately 21% of patients on
placebo  achieved  at  least  a  one-stage  improvement  in  liver  fibrosis  without  any  worsening  of  NASH  (p  =  0.02)  and  (ii)
approximately  20%  of  OCA-treated  patients  as  compared  to  approximately  7%  of  patients  on  placebo  achieved  NASH
resolution  with  no  worsening  of  fibrosis  (p  =  0.03)  using  the  definition  we  selected  for  NASH  resolution  in  the
REGENERATE trial.

In the FLINT trial, more OCA-treated patients experienced significant improvements in the major histological features
of  NASH,  including  steatosis  (61%  versus  38%,  p  =  0.001),  lobular  inflammation  (53%  versus  35%,  p  =  0.006)  and
hepatocellular  ballooning  (46%  versus  31%,  p  =  0.03),  as  compared  to  the  placebo  treatment  group.  Trends  were  similar
between the two treatment groups for portal inflammation, which is not a component of NAS and is typically mild in adult
NASH patients.

The  histological  improvements  observed  in  OCA-treated  patients  versus  placebo  were  accompanied  by  statistically
significant  reductions  in  relevant  biochemical  parameters,  including  the  serum  liver  enzymes  ALT  (p  <  0.0001),  aspartate
aminotransferase (“AST”) (p = 0.0001) and gamma-glutamyl transferase (“GGT”) (p < 0.0001), each of which were above
generally accepted normal limits at baseline, and total bilirubin (p = 0.002). A modest but statistically significant increase in
ALP (p < 0.0001) in the OCA treatment group was also observed, but levels remained within typical normal limits.

OCA treatment was associated with serum lipid changes, including increases in total cholesterol and LDL cholesterol
and a decrease in HDL cholesterol, that developed within 12 weeks of treatment initiation, then reversed through the end of
treatment  and  returned  to  baseline  during  the  24-week  post-treatment  follow-up  phase.  Based  on  these  observations,  lipid
management  was  emphasized  partway  into  the  trial,  using  accepted  guidelines.  At  72  weeks  as  compared  to  baseline,  the
following effects were observed in the OCA treatment group: an increase in mean total cholesterol (0.16 mmol/L or 6 mg/dL
increase  OCA  versus  0.19  mmol/L  or  7mg/dL  decrease  placebo,  p  =  0.0009),  an  increase  in  mean  LDL  cholesterol  (0.22
mmol/L or 9 mg/dL increase OCA versus 0.22 mmol/L or 8 mg/dL decrease placebo, p < 0.0001), a decrease in mean HDL
cholesterol  (0.02  mmol/L  or  1  mg/dL  decrease  OCA  versus  0.03  mmol/L  or  1  mg/dL  increase  placebo,  p  =  0.01)  and  a
decrease in triglycerides (0.22 mmol/L or 20 mg/dL decrease OCA versus 0.08 mmol/L or 7 mg/dL decrease placebo, p =
0.88, not significant). These changes in cholesterol levels, along with the achievement of predefined efficacy criteria, played
a role in the decision of the FLINT data and safety monitoring board to terminate the treatment phase of the FLINT trial, and
the publication of the FLINT results noted the need for further study of these changes.

A post-hoc analysis showed OCA-treated patients who initiated statins during the FLINT trial (n = 26) experienced a
rapid reversal of their observed mean LDL cholesterol increase to below baseline levels, with a mean decrease after 72 weeks
of treatment of -18.9 mg/dL. In contrast, other OCA-treated patients with no reported initiation or change in statin therapy
experienced an increase in LDL cholesterol that peaked at week 12 and was sustained over the 72-week treatment period.
Patients treated with statins at baseline who maintained statin treatment over the duration of the study (n = 50) experienced a
mean  LDL  cholesterol  increase  of  8.7  mg/dL  at  72  weeks.  Patients  not  treated  with  statins  during  the  study  (n  =  65)
experienced  a  mean  LDL  cholesterol  increase  of  16.0  mg/dL.  Treatment  related  LDL  cholesterol  increases  in  all  groups
reversed with treatment discontinuation. This analysis suggests that the OCA-associated LDL cholesterol increase reaches a
maximum peak and plateaus soon after initiation of therapy and that concomitant statin use in NASH patients receiving OCA
may mitigate treatment-related LDL cholesterol increases.

In  the  FLINT  trial,  statistically  significant  weight  loss  of  an  average  of  2.3  kilograms  was  observed  in  OCA  patients
compared to no weight loss in the placebo group (p = 0.008), and this weight loss reverted towards baseline during the 24-
week follow-up phase. A pre-specified sensitivity analysis conducted by the investigators showed that weight loss was not a
driver  of  the  primary  endpoint.  An  increase  in  a  marker  of  hepatic  insulin  resistance  known  as  homoeostasis  model
assessment – estimated insulin resistance (“HOMA-IR”) (calculated using the product of fasting plasma insulin and

13

Table of Contents

glucose) was observed at 72 weeks in the OCA treatment group (p = 0.01). However, there was an imbalance in baseline
plasma  insulin  levels  (201  pmol/L  OCA  versus  138  pmol/L  placebo),  and  an  even  larger  relative  and  absolute  increase  in
HOMA-IR  was  observed  in  the  placebo  group  at  the  conclusion  of  the  24-week  follow-up  phase.  This  is  potentially
attributable  to  the  inherent  variability  in  HOMA-IR  measurements,  particularly  in  patients  with  type  2  diabetes,  that  have
been  shown  to  make  single  time-point  to  time-point  changes  of  this  magnitude  clinically  uninterpretable.  There  were
virtually  no  changes  in  mean  hemoglobin  A1c,  a  measure  of  average  blood  sugar  control  over  a  period  of  approximately
three  months,  in  either  OCA  or  placebo  groups  at  72  weeks.  In  an  earlier  study  of  OCA  in  diabetic  NAFLD  patients
employing  the  hyperinsulinemic-euglycemic  insulin  clamp,  the  gold  standard  for  detecting  changes  in  insulin  resistance,
OCA improved the glucose disposal rate consistent with reduced insulin resistance.

OCA was generally well tolerated in the FLINT trial. Adverse events were generally mild to moderate in severity and
the incidence in the OCA and placebo treatment groups was similar for all symptoms except pruritus. Pruritus occurred more
frequently in the OCA treatment group than in the placebo treatment group (23% vs. 6%, p < 0.0001) and at a higher grade
(predominately  moderate  pruritus)  but  resulted  in  only  one  patient  discontinuation.  The  incidence  of  severe  or  life-
threatening events was not different between the two treatment groups and most of the events in both groups were deemed to
be unrelated to treatment, including all severe or life-threatening cardiovascular events. There were two patient deaths in the
Phase 2b FLINT trial and neither death was considered related to OCA treatment.

OCA and Bezafibrate

In December 2018, we entered into the Aralez Agreement, pursuant to which we acquired (i) Aralez’s license to develop
and  commercialize  bezafibrate  in  the  United  States  (as  amended  and  restated  in  connection  therewith,  the  “Bezafibrate
License”), (ii) Aralez’s IND on file with the FDA and other associated regulatory documentation and (iii) a non-exclusive
license  to  certain  of  Aralez’s  intellectual  property.  Pursuant  to  the  Aralez  Agreement,  we  paid  $9.0  million  to  Aralez  in
connection  with  the  closing  of  the  transactions  in  December  2018  and  are  obligated  to  make  a  $2.0  million  milestone
payment to Aralez based on the occurrence of specified regulatory-related events. Bezafibrate, a PPAR agonist that has been
studied  in  PBC,  is  not  approved  in  the  U.S.  for  any  indication.  We  are  evaluating  the  efficacy,  safety  and  tolerability  of
bezafibrate in combination with OCA in patients with PBC in a Phase 2 study, with the longer-term goal of developing and
seeking  regulatory  approval  for  a  fixed  dose  combination  regimen  in  this  indication  and  potentially  may  study  this
combination  in  other  liver  diseases.  Pursuant  to  the  Bezafibrate  License,  we  are  also  obligated  to  make  a  $2.5  million
milestone  payment  based  on  the  occurrence  of  specified  regulatory-related  events  with  respect  to  such  a  combination
product, as well as mid-single digit percentage royalty payments based on the net sales of such a combination product.

Other Product Candidates

The discovery and development of safe and effective new product candidates and the development of additional uses for
our existing product candidates and approved products, are important for the continued strength of our business. We, together
with our collaborators, have discovered several bile acid chemistry-based compounds that are in the early stages of research
and  development.  Among  these  compounds  is  INT-787.  INT-787  is  an  FXR  agonist  that  we  are  currently  evaluating  in
preclinical studies. INT-787 has distinct pharmacological properties that differ from those of OCA and has shown potential
anti-fibrotic and anti-inflammatory effects in animal models. We believe that bile acid analogs may have utility in a broad
range  of  diseases  beyond  non-viral  liver  disease  and  we  have  in  the  past,  and  may  in  the  future,  explore  the  potential
application of our development compounds outside of our core areas of focus.

The process from discovery to development to regulatory approval of a product candidate can take more than ten years.
Product candidates can fail at any stage of the process, and product candidates may not receive regulatory approval even after
many years of research and development and significant investment. In addition, we may decide to terminate or deprioritize
the  development  of  our  product  candidates  due  to  a  number  of  factors,  including  our  views  of  the  relevant  regulatory
development pathway, competitive landscape, commercial viability of the product candidate, or superior alternative uses of
capital.  For  example,  we  have  studied  OCA  for  PSC,  a  rare,  serious,  chronic  cholestatic  liver  disease  characterized  by  a
progressive, autoimmune-based destruction of bile ducts with eventual onset of cirrhosis. While we believe that the results of
our Phase 2 AESOP trial announced in 2017 established a proof of concept of OCA in a second cholestatic liver disease, we
have deprioritized development of OCA in PSC based, in part, on the lack of clarity on the

14

Table of Contents

regulatory  pathway  for  this  rare  but  serious  disease.  In  addition,  we  are  no  longer  actively  developing  INT-767,  an  orally
administered dual FXR and TGR5 agonist derived from the primary human bile acid chenodeoxycholic acid.

Sumitomo Dainippon Collaboration

In March 2011, we entered into an exclusive license agreement (the “Original Sumitomo Agreement”) with Sumitomo
Dainippon,  pursuant  to  which  we  granted  to  Sumitomo  Dainippon  an  exclusive  license  to  research,  develop  and
commercialize OCA for the treatment of PBC and NASH in Japan and China (excluding Taiwan) and an option to research,
develop  and  commercialize  OCA  in  certain  countries  outside  of  such  territories  (the  “Country  Option”).  We  received  an
upfront payment from Sumitomo Dainippon of $15.0 million under the terms of the Original Sumitomo Agreement. In May
2014, Sumitomo Dainippon exercised the Country Option in part to add Korea as part of its licensed territories and paid us a
$1.0 million upfront fee in connection therewith. In February 2018, we and Sumitomo Dainippon entered into Amendment
No.  3  (the  “Sumitomo  Amendment”)  to  the  Original  Sumitomo  Agreement  (as  amended,  the  “Sumitomo  Agreement”),
pursuant  to  which  (i)  Sumitomo  Dainippon  agreed  to  return  the  rights  to  develop  and  commercialize  OCA  in  Japan  and
Korea  and  waived  its  rights  to  the  Country  Option,  (ii)  we  agreed  to  forego  any  further  milestone  or  royalty  payments
relating  to  the  development  and  commercialization  of  OCA  in  Japan  and  Korea  and  (iii)  certain  milestone  payment
obligations  with  respect  to  the  development  and  commercialization  of  OCA  were  adjusted.  In  October  2019,  we  and
Sumitomo Dainippon mutually agreed to terminate with immediate effect the Sumitomo Agreement. In connection with the
termination  of  the  Sumitomo  Agreement,  Sumitomo  Dainippon  agreed  to  return  to  us  the  rights  to  develop  and
commercialize OCA in China and we agreed to forego any further milestone or royalty payments relating to the development
and commercialization of OCA in China. No payment is due from us to Sumitomo Dainippon as a result of the termination of
the Sumitomo Agreement.

Competition

The  biotechnology  and  pharmaceutical  industries  are  intensely  competitive  and  subject  to  rapid  and  significant
technological  change.  We  have  competitors  in  the  United  States,  Europe  and  other  jurisdictions,  including  major
multinational  pharmaceutical  companies,  established  biotechnology  companies,  specialty  pharmaceutical  and  generic  drug
companies  and  universities  and  other  research  institutions.  Many  of  our  competitors  have  financial,  sales  and  marketing,
manufacturing and distribution, legal, regulatory and product development resources substantially greater than ours. Smaller
or early-stage companies may also prove to be significant competitors, particularly through collaborative arrangements with
large, established companies.

The ability of Ocaliva for PBC, OCA for liver fibrosis due to NASH, if approved, and other future approved products, if
any, to compete with products sold by other companies will depend on a number of factors, including efficacy, safety and
tolerability, reliability, convenience of dosing, price, the level of branded and generic competition and reimbursement. We
believe that the competitive environment for Ocaliva for PBC and, if approved, OCA for liver fibrosis due to NASH is as
follows.

Ocaliva for PBC

Ocaliva  competes  with  UDCA  (or  ursodiol),  a  first-line  therapy  approved  for  the  treatment  of  PBC  that  is  available
generically  at  a  significantly  lower  cost  than  Ocaliva.  Ocaliva  is  an  FXR  agonist  and  we  are  aware  of  several  other
companies  that  have  FXR  agonists  in  Phase  2  or  earlier  clinical  or  preclinical  development  for  the  treatment  of  PBC,
including FXR agonists from Novartis AG (tropifexor), Gilead Sciences, Inc. (GS-9674) and Enanta Pharmaceuticals, Inc.
(EDP-305). Additional product candidates in Phase 3 or earlier clinical or preclinical development for the treatment of PBC
include  Genfit  SA’s  dual  PPAR  alpha/delta  agonist  (elafibranor),  Arena  Pharmaceuticals,  Inc.’s  S1P  receptor  modulator
(etrasimod), Bristol-Myers Squibb Company’s anti-CTL4 fusion protein (abatacept) and Fast Forward Pharmaceuticals BV’s
anti-CD40  monoclonal  antibody  (FFP104).  Additionally,  several  companies  have  product  candidates  aimed  at  the
cholestatic-induced  pruritus  associated  with  PBC,  including  apical  sodium  dependent  bile  acid  transport  inhibitors  being
developed by GlaxoSmithKline plc (GSK2330672).

15

Table of Contents

Off-label uses of other potential treatments may also compete with Ocaliva for PBC. For example, while fibrates are not
approved for use in PBC, off-label use of fibrate drugs has been reported. Bezafibrate, a fibrate that is not approved by the
FDA for any indication and is only available outside of the United States, has been studied in PBC.

OCA for Liver Fibrosis Due to NASH

There are currently no medications approved for the treatment of NASH. However, various therapeutics are used off-
label  for  the  treatment  of  NASH,  including  vitamin  E  (an  antioxidant),  insulin  sensitizers  (e.g.,  metformin,  pioglitazone),
antihyperlipidemic agents (e.g., gemfibrozil), pentoxifylline and UDCA. There are several product candidates in Phase 3 or
earlier  clinical  or  preclinical  development  for  the  treatment  of  NASH,  including  Genfit  SA’s  PPAR  alpha/delta  agonist
(elafibranor),  Gilead  Sciences,  Inc.’s  ASK-1  inhibitor  (selonsertib)  and  Allergan  plc’s  dual  CCR2  and  CCR5  inhibitor
(cenicriviroc),  as  well  as  FXR  agonists  from  Novartis  AG  (tropifexor),  Gilead  Sciences,  Inc.  (cilofexor)  and  Enanta
Pharmaceuticals, Inc. (EDP-305).

Additional  pharmaceutical  and  biotechnology  companies  with  product  candidates  in  development  for  the  treatment  of
NASH  include  AstraZeneca  plc,  Boehringer  Ingelheim  GmbH,  Bristol-Myers  Squibb  Company,  Durect  Corporation,
Galectin  Therapeutics  Inc.,  Galmed  Pharmaceuticals  Ltd.,  Immuron  Ltd.,  Ionis  Pharmaceuticals,  Inc.,  Islet  Sciences,  Inc.,
Madrigal Pharmaceuticals, Inc., MediciNova, Inc., MiNA Therapeutics, NGM Biopharmaceuticals, Inc., Novo Nordisk A/S,
NuSirt Sciences Inc., Viking Therapeutics, Inc. and Zydus Pharmaceuticals (USA) Inc. NASH is a complex disease and we
believe that it is unlikely that any one therapeutic option will be optimal for every NASH patient.

In addition, many universities and private and public research institutions may become active in our target disease areas.
The  results  from  our  clinical  trials  and  the  approval  of  Ocaliva  for  PBC  have  brought  more  attention  to  our  targeted
indications and bile acid chemistry. As a result, we believe that additional companies and organizations may seek to compete
with us in the future. Our competitors may succeed in developing, acquiring or licensing on an exclusive basis, technologies
and  drug  products  that  are  more  effective  or  less  costly  than  OCA  or  any  other  product  candidates  that  we  are  currently
developing or that we may develop, which could render our products or product candidates obsolete and noncompetitive. Our
ability to compete may also be affected because, in many cases, insurers or other third-party payors seek to encourage the use
of generic products.

Intellectual Property

Protecting  our  intellectual  property,  such  as  our  patents,  is  a  key  part  of  our  strategy.  We  are  the  owner  of  record  of
numerous  issued  U.S.  and  non-U.S.  patents  with  claims  directed  to  pharmaceutical  compounds,  pharmaceutical
compositions,  methods  of  making  these  compounds  and  methods  of  using  these  compounds  in  various  indications.  In
addition,  we  are  the  owner  of  record  of  numerous  pending  U.S.  and  non-U.S.  patent  applications,  and  regularly  pursue
additional patent applications in various jurisdictions. We also have numerous trademark and service mark registrations and
pending trademark and service mark applications in the United States and abroad.

The  patent  portfolio  for  OCA  contains  U.S.  and  non-U.S.  patents  and  patent  applications  directed  to  compositions  of
matter, methods of use and manufacturing methods. Our primary composition of matter patent for OCA expires in 2022. In
light of the U.S. marketing approval of Ocaliva for PBC in May 2016, we have applied for an extension of the patent term for
this patent in the United States through 2027. In addition, in connection with the conditional approval of Ocaliva for PBC in
the European Union, we have applied for supplementary patent certification (“SPC”) to extend the patent term for this patent
in the European Union through 2027. To date, we have received grants of SPC in Austria, Cyprus, Denmark, Finland, France,
Germany,  Greece,  Ireland,  Italy,  Norway,  Portugal,  Spain  and  Sweden  and  we  expect  to  take  similar  actions  in  other
jurisdictions and countries where similar regulations exist.

The table set forth below summarizes the U.S. patents covering OCA that are listed in the FDA’s Orange Book List of
Approved Drug Products With Therapeutic Equivalence Evaluations (the “Orange Book”). The issued composition of matter
patents for OCA are expected to expire in 2022 at the earliest and 2036 at the latest if the appropriate maintenance, renewal,
annuity, or other government fees are paid. We expect that the other patents in the OCA portfolio that are listed

16

Table of Contents

in  the  Orange  Book  would  expire  as  set  forth  below,  assuming  the  appropriate  maintenance,  renewal,  annuity  or  other
governmental fees are paid.

Patent No.
7,138,390
8,058,267
8,377,916
9,238,673
10,047,117
10,052,337
10,174,073

Type of Patent(1)

Brief Summary of Patent

  Composition of Matter   Claims OCA compound

Method of Use
Method of Use

  Claims methods of treating PBC with OCA
  Claims methods of treating PBC with OCA

  Composition of Matter   Claims OCA active pharmaceutical ingredient (“API”)

Method of Use

  Claims methods of treating FXR mediated diseases with OCA API

  Composition of Matter   Claims OCA finished drug product
  Composition of Matter   Claims OCA API produced by a specified process

    U.S. Patent
Expiration
  2022(2)
2022
2022
2033
2033
2036
2033

(1) You  should  read  the  risk  factors  included  elsewhere  in  this  Annual  Report  on  Form  10-K  for  important  information
about risks posed by the loss of patent protection, in particular the risks described under “Risk Factors — Risks Related
to Our Intellectual Property.”

(2) In light of the U.S. marketing approval of Ocaliva for PBC in May 2016, we have applied for an extension of the patent

term for this patent in the United States through 2027.

In addition, we have intellectual property protecting OCA that we would expect to list in the Orange Book if OCA is

approved for the treatment of NASH.

We  may  rely  on  trade  secrets  to  protect  our  proprietary  technologies,  especially  where  we  do  not  believe  patent
protection  is  appropriate  or  obtainable.  However,  trade  secrets  are  difficult  to  protect.  We  rely  in  part  on  confidentiality
agreements  with  our  employees,  consultants,  outside  scientific  collaborators,  sponsored  researchers  and  other  advisors  to
protect our trade secrets and other proprietary information. We also seek to preserve the integrity and confidentiality of our
data, trade secrets and know-how by maintaining physical security of our premises and physical and electronic security of
our information technology systems.

Our  commercial  success  will  depend  in  part  on  our  ability  to  obtain  and  maintain  patent,  trademark  and  trade  secret
protection covering our products such as Ocaliva and product candidates, as well as our ability to successfully defend our
intellectual property against third-party challenges. Our ability to stop third parties from making, using, selling, offering to
sell or importing our products is dependent upon the extent to which we have regulatory exclusivity or intellectual property-
based exclusivity rights under valid and enforceable patents or other intellectual property that cover our products. If we fail
to obtain and maintain adequate intellectual property protection, we may not be able to prevent third parties from launching
generic versions of our products, from using our proprietary technologies or from marketing products that are very similar or
identical to ours. The patent positions of pharmaceutical companies can be highly uncertain and involve complex legal and
factual  questions  for  which  important  legal  principles  remain  unresolved.  No  consistent  policy  regarding  the  breadth  of
claims allowed in pharmaceutical patents has emerged to date in the United States or in foreign jurisdictions, and the legal
standards relating to the patentability, validity and enforceability of pharmaceutical patents are evolving.

Changes in either the patent laws or in interpretations of patent laws in U.S. and foreign jurisdictions may diminish the
value of our intellectual property. Accordingly, we cannot predict the breadth of claims that may be enforced in the patents
that we currently own or that may issue from the applications we have filed or may file in the future or those that we may
license from third parties. Additionally, our currently pending or future patent applications may not result in issued patents,
and any term extensions that we seek may not be granted. Further, if any patents we obtain or license are deemed invalid or
unenforceable, it could impact our ability to commercialize or license our technology or enable third parties to develop and
market products that are similar or identical to ours.

Manufacturing and Supply

We  do  not  own  or  operate  manufacturing  facilities  for  the  production  of  Ocaliva,  OCA  or  any  of  our  other  product

candidates, and we do not have any plans to develop our own manufacturing operations in the foreseeable future. We rely

17

    
    
 
 
 
 
 
 
 
 
 
Table of Contents

on  third-party  contract  manufacturers  for  all  of  our  required  raw  materials,  API  and  finished  product  for  our  commercial
sales and for our clinical trials and preclinical studies.

We currently have an agreement with PharmaZell GmbH (“PharmaZell”) for the manufacture and commercial supply of
API for use in Ocaliva and, if approved, OCA for liver fibrosis due to NASH. Pursuant to our agreement with PharmaZell,
we  have  purchased  quantities  of  API  that  we  believe  will  be  sufficient  to  meet  our  PBC  and  NASH  commercial  supply
requirements during the initial stages of our NASH launch following the expected approval of OCA for liver fibrosis due to
NASH.  The  initial  term  of  our  agreement  with  PharmaZell  expires  on  December  31,  2020  and  thereafter  automatically
renews for successive two-year periods unless either party provides notice of non-renewal at least 12 months prior to the end
of the initial term or then-current renewal term. The agreement is also subject to customary early termination rights.

We are not obligated to purchase from PharmaZell a specific percentage of our annual commercial requirements of API
for use in Ocaliva and, if approved, OCA for liver fibrosis due to NASH, and expect to shift our longer-term API supply
requirements  to  other  suppliers.  Accordingly,  we  have  qualified  an  additional  API  supplier  from  which  we  may  currently
acquire API on a purchase order basis and continue to engage in activities intended to ensure that our long-term commercial
supply  requirements  are  satisfied.  In  connection  with  such  efforts,  we  entered  into  an  agreement  with  a  third  potential
supplier of API for the manufacture of Ocaliva and, if approved, OCA for liver fibrosis due to NASH, under which we may
in the future be obligated to purchase a portion of our API requirements in the event of the achievement of agreed regulatory
and product development milestones.

We do not have long-term supply agreements for any of our product candidates other than OCA, and regularly obtain
supplies and services relating to our product candidates from third-party contract manufacturers on a purchase order basis.
Contract  manufacturers  are  subject  to  extensive  governmental  regulation  and  we  depend  on  them  for  compliance  with  the
requirements of U.S. and non-U.S. regulators for the manufacture of our finished products, including Ocaliva. We intend to
continue  to  rely  on  third-party  manufacturers  for  the  manufacture  of  clinical  supplies  of  our  product  candidates  and
commercial supplies of our approved products, including Ocaliva and, if approved, OCA for liver fibrosis due to NASH. We
believe this manufacturing strategy will enable us to direct financial resources to the development and commercialization of
products rather than diverting resources to establishing a manufacturing infrastructure. If PharmaZell and our other current
and future suppliers are not able to meet our on-going commercial supply requirements, including those relating to Ocaliva
or, if approved, OCA for liver fibrosis due to NASH, on acceptable terms, or at all, our business may be may be materially
and adversely affected. See “Risk Factors — Risks Related to the Development and the Regulatory Review and Approval of
Our Products and Product Candidates — We rely entirely on third parties for the manufacture of our product requirements for
our  preclinical  studies  and  clinical  trials,  as  well  as  our  commercial  supply  of  Ocaliva  and,  if  approved,  OCA  for  liver
fibrosis due to NASH and our other product candidates, and also depend on third-party vendors and CROs for certain of our
clinical  trial  and  product  development  activities.  Our  business  could  be  harmed  if  our  third-party  manufacturers  fail  to
provide us with sufficient quantities of drug product, or fail to do so at acceptable quality levels or prices, or if our third-party
vendors or CROs assisting us with our clinical trials and product development activities fail to comply with their contractual
commitments or applicable regulatory obligations or if we lose our relationships with our third-party vendors and CROs.

Sales and Marketing

Ocaliva is our first approved product and the commercial launch of Ocaliva for PBC is our first product launch. We are
commercializing Ocaliva for PBC using a combination of our internal commercial organization, a contract sales organization
and  third-party  distributors  depending  on  the  jurisdiction.  We  are  developing  our  commercialization  strategy  for  OCA  for
liver  fibrosis  due  to  NASH,  if  approved,  and  have  not  yet  decided  on  our  commercialization  strategy  for  OCA  for  other
indications  or  for  our  other  product  candidates,  in  each  case,  if  approved.  We  intend  to  continue  to  evaluate  how  best  to
commercialize our product candidates, if approved, in the United States and internationally, and may choose to collaborate
with third parties that have sales and marketing capabilities and established distribution systems, either to augment our own
capabilities or in lieu thereof.

18

Table of Contents

Customers

We  commenced  our  commercial  launch  of  Ocaliva  for  the  treatment  of  PBC  in  the  United  States  in  June  2016.  In
December  2016,  the  European  Commission  granted  conditional  approval  for  Ocaliva  for  the  treatment  of  PBC  and  we
commenced  our  European  commercial  launch  in  January  2017.  Since  January  2017,  Ocaliva  has  also  received  regulatory
approval in several of our target markets outside the United States and Europe, including Canada, Israel and Australia. We
recognized net product sales of Ocaliva of $249.6 million, $177.8 million and $129.2 million for the years ended December
31,  2019,  2018  and  2017,  respectively.  We  sell  Ocaliva  to  a  limited  number  of  specialty  pharmacies  which  dispense  the
product  directly  to  patients.  The  specialty  pharmacies  are  referred  to  as  our  customers.  For  a  discussion  of  our  customer
concentration, see Note 2 to our audited consolidated financial statements included elsewhere in this Annual Report on Form
10-K.

Government Regulation and Product Approval

Government  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, recordkeeping, approval,
labeling,  packaging,  promotion,  storage,  advertising,  distribution,  marketing,  sampling,  post-approval  monitoring  and
reporting and export and import of products such as Ocaliva and those we are developing. Our product candidates must be
approved  by  the  FDA  through  the  NDA  process  before  they  may  be  legally  marketed  in  the  United  States  and  by  the
European  Commission  following  a  favorable  assessment  provided  by  the  EMA  through  the  MAA  process  for  a  product
falling  within  the  scope  of  the  Centralized  procedure  or  a  national  MAA  process  (albeit  through  the  process  of  Mutual
Recognition  or  Decentralized  procedure)  before  they  may  be  legally  marketed  in  the  European  Union.  Our  product
candidates  will  be  subject  to  similar  requirements  in  other  countries  prior  to  marketing  in  those  countries.  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 financial resources.

United States Government Regulation

NDA Approval Processes

In  the  United  States,  the  FDA  regulates  drugs  under  the  Federal  Food,  Drug,  and  Cosmetic  Act,  as  amended  (the
“FDCA”) and implementing regulations. 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 human clinical testing may begin;

● approval by an independent institutional review board (“IRB”), representing each clinical site before each clinical

trial may be initiated;

● performance  of  adequate  and  well-controlled  human  clinical  trials  in  accordance  with  good  clinical  practices
(“GCP”) to establish the safety and efficacy of the new drug product for each indication for which FDA approval is
sought;

● preparation and submission to the FDA of a NDA;

● review of the new drug product by an FDA advisory committee, where appropriate or if applicable, although the

FDA is not bound by the recommendation of an advisory committee;

● satisfactory completion of one or more FDA inspections of the manufacturing facility or facilities at which the new

drug product, or components thereof, are produced to assess compliance with current Good Manufacturing

19

Table of Contents

Practices (“cGMP”) requirements and to assure that the facilities, methods and controls are adequate to preserve the
new drug product’s identity, strength, quality and purity;

● satisfactory completion of FDA audits of clinical trial sites to assure compliance with GCP and the integrity of the

clinical data;

● payment of user fees and procurement of FDA approval of the NDA; and

● compliance  with  any  post-approval  requirements,  including,  as  applicable,  Risk  Evaluation  and  Mitigation

Strategies (“REMS”) and post-approval studies required by the FDA.

Preclinical and Clinical Studies

Once  a  pharmaceutical  candidate  is  identified  for  development,  it  enters  the  preclinical  or  nonclinical  testing  stage.
Nonclinical tests include laboratory evaluations of product chemistry, toxicity and formulation, as well as animal studies. An
IND sponsor must submit the results of the nonclinical tests, together with manufacturing information and analytical data, to
the  FDA  as  part  of  the  IND.  Some  nonclinical  testing  may  continue  even  after  the  IND  is  submitted.  In  order  to  conduct
clinical research, an IND sponsor must submit an IND. An IND automatically becomes effective 30 days after receipt by the
FDA, unless the FDA, within the 30-day time period, or any time thereafter, 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 or continue. A clinical
hold may affect one or more specific studies or all studies conducted under the IND.

All  clinical  trials  must  be  conducted  under  the  supervision  of  one  or  more  qualified  investigators  in  accordance  with
GCPs.  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  the  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 investigation 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 IRB
at  each  institution  must,  among  other  things,  review  and  approve  the  protocol  before  a  clinical  trial  commences  at  such
institution, and approve 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 regulations applicable to the IRB.

Human  clinical  trials  are  typically  conducted  in  three  sequential  phases,  although  the  phases  may  overlap  or  be

combined:

● Phase 1. The drug is initially introduced into healthy human subjects and tested to assess pharmacological actions,
safety, dosage tolerance, absorption, metabolism, distribution and elimination and, in some cases, early evidence of
effectiveness. In the case of some products intended for the treatment of severe or life-threatening diseases, such as
cancer, especially when the product may be inherently too toxic to ethically administer to healthy volunteers, the
initial human testing is often conducted in patients.

● 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. Clinical trials are undertaken to further evaluate dosage, clinical efficacy and safety in an expanded patient
population  generally  at  geographically  dispersed  clinical  study  sites.  These  studies  are  intended  to  establish  the
overall risk-benefit ratio of the product and provide an adequate basis for product labeling, should it ultimately be
approved for marketing. In most cases the FDA requires two adequate and well-controlled Phase 3 clinical trials
with statistically significant results to demonstrate the efficacy of the drug. A single Phase 3 clinical trial with other
confirmatory evidence may be sufficient in certain instances.

20

Table of Contents

Human  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, or the clinical monitoring board or data
safety  monitoring  board  (“DSMB”).  This  group  provides  authorization  for  whether  or  not  a  trial  may  move  forward  at
designated check points. These decisions are based on the DSMB’s independent review of data from the ongoing trial.

Sponsors of clinical trials of certain FDA-regulated products, including prescription drugs, are required to register and
disclose  clinical  trial  information  related  to  the  product,  patient  population,  phase  of  investigation,  clinical  trial  sites  and
investigator, and other aspects of the clinical trial on a public website maintained by the U.S. National Institutes of Health.
Sponsors  are  also  obligated  to  disclose  the  results  of  these  clinical  trials  after  completion.  For  a  new  product  or  a  new
indication for a previously approved product, sponsors can delay submission of clinical study results for up to two years until
the  product  has  been  approved  or  approved  for  the  new  use.  Competitors  and  others  may  use  this  publicly-available
information to gain knowledge regarding the design and progress of our development programs.

During  the  development  of  a  new  drug,  sponsors  are  given  opportunities  to  meet  with  the  FDA  at  certain  points,
including prior to the submission of an IND, at the end of Phase 2 and before a 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 and feedback on the next phase of development. Sponsors typically use the meeting
at the end of Phase 2 to discuss their Phase 2 clinical results and present their plans for the pivotal Phase 3 clinical trial(s)
that they believe will support the approval of the new drug. If a Phase 2 clinical trial is the subject of discussion at the end of
Phase  2  meeting  with  the  FDA,  a  sponsor  may  be  able  to  request  a  special  protocol  assessment  (“SPA”),  the  purpose  of
which  is  to  reach  agreement  with  the  FDA  on  the  Phase  3  clinical  trial  protocol  design  and  analysis  that  will  form  the
primary basis of an efficacy claim.

According  to  published  guidance  on  the  SPA  process,  a  sponsor  which  meets  the  prerequisites  may  make  a  specific
request for an SPA and provide information regarding the design and size of the proposed clinical trial. The FDA is supposed
to evaluate the protocol within 45 days of the request to assess whether the proposed trial is adequate, and that evaluation
may result in discussions and a request for additional information. An SPA request must be made before the proposed trial
begins, and all open issues must be resolved before the trial begins. If a written agreement is reached, it will be documented
and  made  part  of  the  record.  The  agreement  is  generally  expected  to  be  binding  on  the  FDA,  in  that  the  critical  design
elements agreed to as part of an SPA agreement may not be changed by the sponsor or the FDA after the trial begins except
with the written agreement of the sponsor and the FDA or if the FDA determines that a substantial scientific issue essential to
determining the safety or efficacy of the drug was identified after the testing began. The presence of an SPA agreement does
not  guarantee  that  a  marketing  application  will  be  filed  or  approved,  even  if  the  trial  is  conducted  in  accordance  with  the
protocol and achieves the specified endpoints. In rare cases, the FDA may rescind an SPA agreement.

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  prior  to  release.  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, nonclinical 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 a NDA requesting approval to market the product. The submission of a NDA is subject to the payment of user
fees,  but  a  waiver  of  such  fees  may  be  obtained  under  specified  circumstances.  Currently,  the  application  fee  is
approximately $2.9 million for NDAs with clinical data and approximately $1.5 million for NDAs without clinical data. The
sponsor under an approved NDA is also subject to annual program user fees, currently

21

Table of Contents

approximately $325,000. Program fees are assessed for each approved prescription drug product identified in an approved
application, up to five program fees per application. These fees are typically modified annually. The FDA reviews all NDAs
submitted to ensure that they are sufficiently complete for substantive review before it accepts them for filing. It may request
additional information rather than accept a 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.

Once the NDA is accepted for filing, the FDA begins an in-depth review. NDAs receive either standard or, as discussed
more  fully  below,  priority  review.  The  FDA  may  refuse  to  approve  a  NDA  if  the  applicable  regulatory  criteria  are  not
satisfied or may require additional clinical or other data. Even if such data are submitted, the FDA may ultimately decide that
the NDA does not satisfy the criteria for approval. The FDA reviews a NDA to determine, among other things, whether a
product is safe, effective, and can be properly manufactured for its intended use or uses. 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. Before approving a NDA, the FDA will
inspect the facility or facilities where the product is manufactured and tested to ensure compliance with cGMPs. An approval
letter  from  the  FDA  authorizes  commercial  marketing  of  the  product  and  specifies  the  prescribing  information  for  the
approved indication(s).

Fast Track, Breakthrough Therapy, Priority Review and Accelerated Approval

The  FDA  is  authorized  to  designate  certain  products  for  expedited  review  if  they  are  intended  to  address  an  unmet
medical  need  in  the  treatment  of  a  serious  or  life-threatening  disease  or  condition.  These  programs  include  fast  track
designation, breakthrough therapy designation and priority review designation.

Specifically, the FDA may designate a product for fast track review if it is intended, whether alone or in combination
with one or more other drugs, for the treatment of a serious or life-threatening disease or condition, and it demonstrates the
potential to address unmet medical needs for such a disease or condition. For fast track designated products, sponsors may
have  a  higher  number  of  interactions  with  the  FDA  and  the  FDA  may  initiate  review  of  sections  of  a  fast  track  product’s
NDA before the application is complete.

A product may also be designated as a breakthrough therapy if it is intended, either alone or in combination with one or
more other drugs, to treat a serious or life-threatening disease or condition and preliminary clinical evidence indicates that
the product may demonstrate substantial improvement over existing therapies on one or more clinically significant endpoints,
such as substantial treatment effects observed early in clinical development. The FDA may take certain actions with respect
to  breakthrough  therapies,  including  holding  meetings  with  the  sponsor  throughout  the  development  process;  providing
timely advice to the product sponsor regarding development and approval; involving more senior staff in the review process;
assigning  a  cross-disciplinary  project  lead  for  the  review  team;  and  taking  other  steps  to  design  the  clinical  trials  in  an
efficient manner.

The FDA may also designate a product for priority review if it would provide a significant improvement in the safety or
effectiveness of the treatment, diagnosis or prevention of a serious condition. Certain other applications may also qualify for
priority  review.  The  FDA  determines,  on  a  case-by-case  basis,  whether  the  proposed  drug  represents  a  significant
improvement  when  compared  with  other  available  therapies.  A  priority  designation  by  the  FDA  is  intended  to  direct  the
agency’s attention and resources to the evaluation of such applications, and to shorten the FDA’s goal for taking action on a
marketing application from ten months to six months.

In addition, the FDA may grant accelerated approval to a drug for a serious or life-threatening condition that provides
meaningful therapeutic advantage to patients over existing treatments based upon a determination that the drug has an effect
on a surrogate endpoint that is reasonably likely to predict clinical benefit. The FDA may also grant accelerated approval for
such a condition when the product has an effect on an intermediate clinical endpoint that can be measured earlier than an
effect  on  irreversible  morbidity  or  mortality,  and  that  is  reasonably  likely  to  predict  an  effect  on  irreversible  morbidity  or
mortality or other clinical benefit, taking into account the severity, rarity, or prevalence of the condition and the availability
or lack of alternative treatments. Drugs granted accelerated approval must meet the same statutory standards for safety and
effectiveness  as  those  granted  traditional  approval.  In  the  case  of  unprecedented  accelerated  approval  endpoints,  this
determination occurs during the review of the NDA. Unless otherwise informed by the FDA, an

22

Table of Contents

applicant must submit to the FDA for consideration during the preapproval review period copies of all promotional materials,
including  promotional  labeling  as  well  as  advertisements,  intended  for  dissemination  or  publication  within  120  days
following  marketing  approval.  After  120  days  following  marketing  approval,  unless  otherwise  informed  by  the  FDA,  the
applicant must submit promotional materials at least 30 days prior to the intended time of initial dissemination of the labeling
or initial publication of the advertisement.

As a condition of a grant of accelerated approval, the FDA may require that the sponsor perform one or more controlled
post-marketing  clinical  trials.  Approval  of  a  drug  may  be  withdrawn  if  these  trials  fail  to  verify  clinical  benefit  or  do  not
demonstrate  sufficient  clinical  benefit  to  justify  the  risks  associated  with  the  drug  (e.g.,  show  a  significantly  smaller
magnitude or duration of benefit than was anticipated based on the observed effect on the surrogate).

Ocaliva was granted fast track designation by the FDA for the treatment of patients with PBC who have an inadequate
response to or are intolerant of UDCA. In August 2015, the FDA accepted for review our NDA and granted priority review
for Ocaliva in PBC. On May 27, 2016, Ocaliva was approved under the accelerated approval pathway in the United States
for PBC in combination with UDCA in adults with an inadequate response to UDCA, or as monotherapy in adults unable to
tolerate UDCA.

In January 2015, OCA for liver fibrosis due to NASH was granted breakthrough therapy designation by the FDA for the
treatment of patients with NASH with liver fibrosis. In November 2019, the FDA accepted for review our NDA and granted
priority review for OCA for liver fibrosis due to NASH.

Post-approval Requirements

Drugs manufactured or distributed pursuant to FDA approvals are subject to pervasive and continuing regulation by the
FDA  post-approval,  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
safety or other problems occur after the product reaches the market. Later discovery of previously unknown problems with a
product  may  result  in  new  labeling  information  (e.g.,  warnings),  customer  training  and/or  education  requirements,
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.  In  addition,  the  FDA  may  require  studies,  trials,  analyses,  and  surveillance
programs to monitor or evaluate the effect of approved products that have been commercialized, and the FDA has the power
to  limit  further  marketing  of  a  product,  or  seek  withdrawal  of  approval,  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  cGMP  and  other  laws.  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 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 judicial, regulatory or statutory 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;

23

Table of Contents

● imposition of a clinical hold;

● warning or untitled letters;

● product recalls;

● product seizures;

● total or partial suspension of production or distribution; and

● injunctions, fines, disgorgement, civil penalties and criminal prosecution.

The FDA and other U.S. state and federal authorities regulate marketing, labeling, advertising and promotion of products
that  are  placed  on  the  market.  Drugs  may  be  promoted  only  for  the  approved  indications  and  in  a  manner  otherwise
consistent with the provisions of the approved label and FDA regulations. The FDA and other authorities actively enforce the
laws  and  regulations  prohibiting  false,  misleading,  deceptive,  or  off-label  promotional  practices;  violations  of  these
prohibitions can lead to significant liability. Additional regulations apply for advertising and promotion of products approved
under the accelerated approval pathway. For example, unless otherwise informed by the FDA, an applicant must submit to
the FDA for consideration during the preapproval review period copies of all promotional materials, including promotional
labeling as well as advertisements, intended for dissemination or publication within 120 days following marketing approval.
After 120 days following marketing approval, unless otherwise informed by the FDA, the applicant must submit promotional
materials  at  least  30  days  prior  to  the  intended  time  of  initial  dissemination  of  the  labeling  or  initial  publication  of  the
advertisement.

We rely, and expect to continue to rely, on third parties for the production of clinical and commercial quantities of our
products. Future FDA and state inspections may identify compliance issues at the facilities of our contract manufacturers that
may disrupt production or distribution, or require substantial resources to correct.

From  time  to  time,  legislation  is  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 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 FDA regulations, guidance or
interpretations changed or what the impact of such changes, if any, may be.

In  accordance  with  the  applicable  requirements  under  the  accelerated  approval  pathway,  we  initiated  our  Phase  4
COBALT clinical outcomes confirmatory trial for Ocaliva in PBC in December 2014, following discussions with the FDA.
COBALT is expected to be completed on a post-marketing basis. The study evaluates subjects across the spectrum of PBC
disease, including early and advanced PBC. We have also agreed to evaluate the safety and efficacy of Ocaliva in patients
with  moderate  to  severe  hepatic  impairment  and  as  monotherapy  in  patients  with  PBC.  In  addition,  we  have  agreed  to
develop and characterize a lower dose formulation of Ocaliva to allow for once daily dosing in patients with moderate or
advanced hepatic impairment.

Risk Evaluation and Mitigation Strategy

The Food and Drug Administration Amendments Act of 2007 created a new section of the FDCA which authorizes the
FDA to require a REMS as a condition of NDA approval, or based upon new safety information regarding an approved drug,
when the FDA determines a REMS is necessary to ensure that the benefits of a drug outweigh the potential risks. Under a
REMS, the FDA may require various measures to address serious risks, such as medication guides, communication plans,
training  or  registries,  as  well  as  steps  to  monitor  and  assess  the  effectiveness  of  those  measures.  Such  requirements  may
impose significant burdens on prescribers, pharmacists or patients. The requirement for a REMS may materially affect the
potential market and profitability of the drug.

We do not have a REMS for Ocaliva for the treatment of PBC.

24

Table of Contents

Patent Term Extension and Data Exclusivity

Depending upon the timing, duration and specifics of FDA approval of the use of our drug candidates, some 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, (the “Hatch-Waxman Act”). The Hatch-Waxman Act permits an extension of a patent term of up to five years as
compensation  for  patent  term  lost  during  product  development  and  the  FDA  regulatory  review  process.  However,  the
extension of patent term cannot extend the remaining term of a patent beyond a total of 14 years from the product’s approval
date.  The  patent  term  extension  period  is  generally  one-half  the  time  between  the  effective  date  of  an  IND,  and  the
submission date of a NDA, plus the time between the submission date of a NDA and the approval of that application. Only
one patent applicable to an approved drug is eligible for the extension and the application for extension must be made prior
to  expiration  of  the  patent.  The  United  States  Patent  and  Trademark  Office,  in  consultation  with  the  FDA,  reviews  and
approves  the  application  for  any  patent  term  extension  or  restoration.  Our  primary  composition  of  matter  patent  for  OCA
expires in 2022. In light of the U.S. marketing approval of Ocaliva for PBC in May 2016, we have applied for an extension
of the patent term for this patent in the United States through 2027. In addition, in connection with the conditional approval
of Ocaliva for PBC in the European Union, we have applied for SPC to extend the patent term for this patent in the European
Union  through  2027.  To  date,  we  have  received  grants  of  SPC  in  Austria,  Cyprus,  Denmark,  Finland,  France,  Germany,
Greece, Ireland, Italy, Norway, Portugal, Spain and Sweden and we expect to take similar actions in other jurisdictions and
countries where similar regulations exist.

Data exclusivity provisions under the FDCA also can delay the submission or the approval of certain applications. The
FDCA  provides  a  five-year  period  of  non-patent  data  exclusivity  within  the  United  States  to  the  first  applicant  to  gain
approval  of  a  NDA  for  a  new  chemical  entity.  A  drug  is  considered  a  new  chemical  entity  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 as further defined in FDA regulations. During the exclusivity period, the FDA may not accept for review
an abbreviated new drug application (“ANDA”) or a 505(b)(2) NDA for a drug with the same active moiety. However, an
application  may  be  submitted  four  years  from  the  NDA  approval  date  if  it  contains  a  paragraph  IV  certification  that  a
reference product patent is invalid or not infringed by the ANDA or 505(b)(2) product. The FDCA also provides three years
of marketing exclusivity for a NDA, 505(b)(2) NDA or supplement to an approved 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,  for  new  indications,  dosages  or  strengths  of  an  existing  drug.  This  three-year
exclusivity covers only the conditions associated with the new clinical investigations and does not prohibit the FDA from
approving ANDAs or 505(b)(2) NDAs for drugs containing the original active moiety for other conditions of use. Five-year
and three-year exclusivity will not delay the submission or approval of a full NDA; however, an applicant submitting a full
NDA  may  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.

Pediatric Exclusivity and Pediatric Use

Under the Best Pharmaceuticals for Children Act, sponsors may obtain a six month extension of unexpired regulatory
exclusivities  and  terms  of  unexpired  Orange  Book-listed  patents  relating  to  their  drug,  if  pediatric  studies  substantially
complying with a written request are completed and submitted by the sponsor to the FDA within the statutory time frame. We
have not received such a written request from the FDA for such pediatric studies, although we may ask the FDA to issue a
written request for such studies in the future.

In addition, under the Pediatric Research Equity Act (the “PREA”), a NDA or supplement to a NDA for certain drugs
must  contain  data  to  assess  the  safety  and  effectiveness  of  the  drug  for  the  claimed  indications  in  all  relevant  pediatric
subpopulations and to support dosing and administration for each pediatric subpopulation for which the product is safe and
effective,  unless  the  sponsor  receives  a  deferral  or  waiver.  However,  the  FDA  has  recently  issued  guidance  limiting  a
sponsor’s ability to waive the PREA study requirements.

Orphan Drug Designation

Under  the  Orphan  Drug  Act,  the  FDA  may  grant  orphan  drug  designation  to  drugs  intended  to  treat  a  rare  disease  or

condition, which is generally a disease or condition that affects fewer than 200,000 individuals in the United States, or

25

Table of Contents

more  than  200,000  individuals  in  the  United  States  and  for  which  there  is  no  reasonable  expectation  that  the  cost  of
developing and making available in the United States a drug for this type of disease or condition will be recovered from sales
in  the  United  States  for  that  drug.  Orphan  drug  designation  must  be  requested  before  submitting  a  NDA.  After  the  FDA
grants orphan drug designation, the identity of the therapeutic agent and its potential orphan use are disclosed publicly by the
FDA.  Orphan  drug  designation  does  not  convey  any  advantage  in  or  shorten  the  duration  of  the  regulatory  review  and
approval process.

If a product that has orphan drug designation subsequently receives the first FDA approval for the disease for which it
has  such  designation,  the  product  is  entitled  to  orphan  drug  exclusivity,  which  means  that  the  FDA  may  not  approve  any
applications  from  any  other  party  to  market  the  same  drug  for  the  same  indication  for  seven  years,  except  in  very  limited
circumstances such as where there is a demonstration of clinical superiority. Orphan drug exclusivity, however, could also
work to block the approval of one of our product candidates for seven years if a competitor develops the same drug as one of
our product candidates and obtains approval and orphan exclusivity for the same indication or disease for which our product
candidate is being developed. Orphan drug exclusivity would not block approval of the same drug developed by a competitor
for  a  use  different  from  our  orphan-protected  approved  use.  If  a  drug  or  drug  product  designated  as  an  orphan  product
ultimately receives marketing approval for an indication broader than what was designated in its orphan product application,
it may not be entitled to orphan exclusivity for the full scope of its approved use.

As  in  the  United  States,  we  may  apply  for  designation  of  a  product  as  an  orphan  drug  for  the  treatment  of  a  specific
indication in the European Union before the application for marketing authorization is made. Orphan drugs in Europe enjoy
economic and marketing benefits, including up to ten years of market exclusivity for the approved indication. The market
exclusivity period for the authorized therapeutic indication may be reduced to six years if, at the end of the fifth year, it is
established that the orphan designation criteria are no longer met, including where it is shown that the product is sufficiently
profitable not to justify maintenance of market exclusivity. In addition, a competing similar medicinal product may in limited
circumstances be authorized prior to the expiration of the market exclusivity period, including if it is shown to be safer, more
effective or otherwise clinically superior to the orphan-designated product.

OCA has received orphan drug designation in the United States and the European Union for the treatment of PBC and
PSC. In the United States, Ocaliva has also received orphan exclusivity for its approved PBC indication that runs until May
27, 2023.

Regulation Outside of the United States

In addition to regulations in the United States, we are subject to regulations of other countries governing clinical trials
and commercial sales and distribution of our products. Whether or not 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, pricing and reimbursement vary greatly from place to place, and the time may be longer or
shorter than that required for FDA approval.

Under  European  Union  regulatory  systems,  a  company  may  submit  marketing  authorization  applications  under  the
centralized, decentralized or mutual recognition marketing authorization procedure. The centralized procedure provides for
the grant of a single marketing authorization for a medicinal product by the European Commission on the basis of an opinion
provided  by  the  EMA’s  Committee  for  Medicinal  Products  for  Human  Use  (the  “CHMP”).  A  centralized  marketing
authorization is valid for all European Union member states and the European Economic Area States (Iceland, Liechtenstein
and Norway). The decentralized marketing authorization procedure involves the submission of an application for marketing
authorization to the competent authorities in each of the European Union member states chosen by the applicant in which the
product is to be marketed. One national competent authority, selected by the applicant (Reference Member State) leads the
assessment  of  the  application  for  marketing  authorization.  The  competent  authorities  of  the  other  chosen  European  Union
member  states  concerned  by  the  procedure  (Concerned  Member  States)  are  subsequently  required  to  review  the  initial
evaluation and, if the assessment is positive and all issues are resolved, grant marketing authorization for their territory on
the  basis  of  the  assessment,  except  where  grounds  of  potential  serious  risk  to  public  health  require  the  application  for
authorization to be refused. The mutual recognition procedure provides for mutual

26

Table of Contents

recognition of a marketing authorization which has already been granted by the national competent authority of a European
Union  member  state  by  the  competent  authorities  of  the  other  European  Union  member  states  where  further  marketing
authorizations are progressively sought. The holder of a national marketing authorization may submit an application to the
competent authority of a European Union member state requesting the recognition of the marketing authorization granted by
the competent authority of another European Union member state.

Prior to obtaining a marketing authorization in the European Union submitted as a full stand-alone dossier, applicants
have to demonstrate compliance with all measures included in an EMA-approved PIP covering all subsets of the pediatric
population, unless the EMA has granted (1) a product-specific waiver, (2) a class waiver, or (3) a deferral for one or more of
the measures included in the PIP. In the case of orphan medicinal products, completion of an approved PIP can result in an
extension of the aforementioned market exclusivity period from ten to twelve years.

It  is  also  possible  that  a  centralized  marketing  authorization  could  be  conditional  on  post-approval  studies  and  not
considered a full approval, but subject to annual renewal until comprehensive data are provided to confirm the benefit/risk
assessment. A manufacturer’s ability to obtain and maintain conditional marketing authorization in the European Union will
be  limited  to  specific  circumstances  and  subject  to  several  conditions  and  obligations,  if  obtained  at  all.  Conditional
marketing  authorizations  can  be  granted,  based  on  a  clinical  dataset  that  is  not  comprehensive.  Granting  of  such  an
authorization  may  be  granted  for  a  limited  number  of  medicinal  products  for  human  use  referenced  in  the  applicable
European  Union  law  governing  conditional  marketing  authorization,  including  products  designated  as  orphan  medicinal
products under European Union law, if (1) the risk-benefit balance of the product is positive, (2) it is likely that the applicant
will be in a position to provide the required comprehensive clinical trial data, (3) unmet medical needs will be fulfilled and
(4)  the  benefit  to  public  health  of  the  immediate  availability  on  the  market  of  the  medicinal  product  outweighs  the  risk
inherent in the fact that additional data are still required. Specific obligations, including with respect to the completion of
ongoing or new studies, and with respect to the collection of pharmacovigilance data, may be specified in the conditional
marketing authorization. Conditional marketing authorizations are valid for one year, and may be renewed annually, if the
risk-benefit balance remains positive, and after an assessment of the need for additional or modified conditions.

Similarly to the United States, both marketing authorization holders and manufacturers of medicinal products are subject
to comprehensive regulatory oversight by the EMA and the competent authorities of the individual European Union member
states both before and after grant of the manufacturing and marketing authorizations. This includes European Union cGMP
rules, which govern quality control of the manufacturing process and require documentation policies and procedures. We and
our third-party manufacturers are required to ensure that all of our processes, methods, and equipment are compliant with
cGMP.

Failure by us or by any of our third-party partners, including suppliers, manufacturers, and distributors to comply with
European Union laws and the related national laws of individual European Union member states governing the conduct of
clinical trials, manufacturing approval, marketing authorization of medicinal products and manufacturing and marketing of
such  products,  both  before  and  after  grant  of  marketing  authorization,  may  result  in  administrative,  civil  or  criminal
penalties.  These  penalties  could  include  delays  in  or  refusals  to  authorize  the  conduct  of  clinical  trials  or  the  grant  of
marketing  authorizations,  product  withdrawals  and  recalls,  product  seizures,  suspensions,  withdrawals,  or  variations  of
previously  granted  marketing  authorizations,  total  or  partial  suspensions  of  production,  distribution,  manufacturing,  or
clinical trials, operating restrictions, injunctions, suspension of licenses, fines and criminal penalties.

In  October  2016,  the  CHMP  of  the  EMA  adopted  a  positive  opinion  recommending  the  granting  of  a  conditional
marketing  authorization  of  Ocaliva  in  PBC.  Based  on  the  CHMP’s  positive  recommendation,  the  European  Commission
granted a conditional marketing authorization of Ocaliva in PBC in December 2016. Although we have successfully renewed
our conditional marketing authorization in the European Union in the past, there can be no assurance that we will be able to
continue to do so in the future. Failure to renew our conditional marketing authorization would prevent us from continuing to
market Ocaliva for PBC in Europe. PBC is not believed to occur in the pediatric population. Therefore, in accordance with
applicable regulations, the PBC marketing authorization required demonstration of compliance with all measures included in
an EMA-approved Pediatric Investigation Plan for OCA for the treatment of biliary atresia, a pediatric cholestatic disease.

27

Table of Contents

Pricing and Reimbursement

Sales of our products will depend, in part, on the extent to which the costs of our products will be covered by third-party
payors, such as government healthcare programs, commercial insurance plans and managed healthcare organizations. These
third-party  payors  are  increasingly  challenging  the  prices  charged  for  medical  products  and  services.  Additionally,  the
containment of healthcare costs has become a priority for federal and state governments and the prices of drugs have been a
focus  in  this  effort.  The  U.S.  government,  state  legislatures  and  foreign  governments  have  shown  significant  interest  in
implementing  cost-containment  programs,  including  price  controls,  restrictions  on  reimbursement  and  requirements  for
substitution  of  generic  products.  Adoption  of  new  or  more  restrictive  price  controls  and  cost-containment  measures  in  the
jurisdictions in which we operate could materially and adversely impact our net sales and financial results.

Third-party  payers  are  responsible  for  managing  overall  pharmaceutical  drug  spending  for  their  client  membership.
Third-party payers continue to scrutinize and manage the prices charged for pharmaceutical products and services, and many
also  limit  reimbursement  for  newly-approved  or  innovating  products  and  indications.  If  these  third-party  payors  do  not
consider our products to be cost-effective compared to other therapies, they may (i) not cover our approved products as part
of their plans’ benefits, (ii) apply utilization management restrictions or high patient cost-sharing obligations or (iii) restrict
the  level  of  reimbursement  for  our  approved  products  and  any  such  actions  may  affect  our  ability  to  sell  our  approved
products on a profitable basis or at all.

Medicare  is  a  U.S.  federal  healthcare  program  that  provides  coverage  for  certain  healthcare  items  and  services  to
individuals  aged  65  years  or  older,  as  well  as  individuals  of  any  age  with  certain  disabilities  and  illnesses.  The  Medicare
Prescription Drug, Improvement, and Modernization Act of 2003 (“MMA”) imposed new requirements for the distribution
and pricing of prescription drugs for Medicare beneficiaries. Under Part D of the MMA, Medicare beneficiaries may enroll in
prescription  drug  plans  offered  by  private  entities  which  provide  coverage  for  outpatient  prescription  drugs.  Part  D  plans
include both stand-alone prescription drug benefit plans and prescription drug coverage as part of Medicare Advantage plans.
Unlike Medicare Part A and B, Part D prescription drug plan sponsors are not required to pay for all outpatient drugs, and
each  Part  D  plan  can  develop  its  own  drug  formulary  that  identifies  which  drugs  it  will  cover  and  at  what  tier  or  level.
However, Part D plan drug formularies must include at least two drugs within each therapeutic category and class of Part D
drugs, though not necessarily all the drugs in each category or class. Any formulary used by a Part D prescription drug plan
must be developed and reviewed by a pharmacy and therapeutics committee. Part D plan coverage and reimbursement may
increase  demand  for  our  products  for  which  we  receive  marketing  approval  in  the  United  States.  Moreover,  while  Part  D
provides prescription drug benefits only to Medicare beneficiaries, private payors often follow Medicare coverage policy and
payment limitations in setting their own payment rates. Any reduction in reimbursement by Medicare may result in a similar
reduction  in  payments  from  non-governmental  payors.  Medicare  Part  D  may  affect  reimbursement  of  our  products  upon
approval.

Medicaid is a U.S. healthcare program that provides coverage for certain healthcare items and services to low-income
children, families, pregnant women and people with disabilities. It is jointly funded by the federal and state governments, and
it  is  administered  by  individual  states  within  parameters  established  by  the  federal  government.  Therefore,  coverage  and
reimbursement  for  drugs  may  vary  by  state  Medicaid  program.  A  manufacturer  must  enter  into  a  Medicaid  Drug  Rebate
Agreement  to  have  its  products  covered  by  Medicaid.  Under  the  Medicaid  program,  and  per  the  Medicaid  Drug  Rebate
Agreement, manufacturers agree to report certain prices to the government and pay rebates to state Medicaid programs based
on Medicaid utilization of the manufacturer’s covered drugs.

In  addition  to  the  Medicaid  Drug  Rebate  Program,  federal  law  requires  companies  to  participate  in  the  Public  Health
Service’s 340B Drug Pricing Program in order to have the manufacturer’s drugs covered under Medicaid. The 340B Drug
Pricing Program requires participating manufacturers to charge statutorily-defined covered entities no more than the 340B
“ceiling price” for the manufacturer’s covered outpatient drugs. The Patient Protection and Affordable Care Act, as amended
by the Health Care and Education Affordability Reconciliation Act of 2010 (collectively, the “ACA”), extended eligibility to
participate in the 340B program to certain additional types of hospitals (including critical access hospitals, sole community
hospitals, rural referral centers and freestanding cancer hospitals). For purposes of these newly eligible covered entities, the
ACA  specifically  excluded  from  the  definition  of  “covered  outpatient  drugs”  certain  drugs  designated  as  “orphan  drugs”
under section 526 of the FDCA. We are also required as a condition of Medicaid participation to discount

28

Table of Contents

our  products  to  authorized  users  of  the  Federal  Supply  Schedule  of  the  General  Services  Administration,  including  the
TRICARE retail pharmacy program, under which additional laws and requirements apply.

These  programs  require  submission  of  pricing  data  and  calculation  of  discounts  and  rebates  pursuant  to  complex
statutory formulas, and the guidance governing such calculations is not always clear. Compliance with such requirements can
require significant investment in personnel, systems and resources, but failure to properly calculate prices, or offer required
discounts or rebates can subject manufacturers to substantial penalties.

In 2010, the ACA was enacted to, among other things, expand access and increase consumer insurance protections while
reducing  the  cost  of  health  care  for  consumers.  The  law  substantially  changed  the  way  health  care  is  financed  by  both
governmental and private insurers in the United States. The ACA requires manufacturers to provide discounts on the prices
of  brand  named  drugs  in  the  coverage  gap  under  Medicare  Part  D  and  increased  the  rebates  paid  by  pharmaceutical
companies  on  drugs  covered  by  Medicaid.  The  ACA  also  imposes  an  annual  fee,  which  increases  each  year,  on  sales  by
branded pharmaceutical manufacturers. Since its enactment, there have been a number of judicial, executive and legislative
challenges  to  the  ACA,  including  tax  legislation  that  removed  the  financial  penalties  for  people  who  do  not  carry  health
insurance (known as the “individual mandate”) and an Executive Order signed in October 2017 by President Trump directing
federal  agencies  to  modify  how  the  ACA  is  implemented.  Congress  may  continue  to  consider  legislation  to  repeal  and
replace some or all elements of the ACA. Further, in December 2018, a federal district court in Texas ruled that the entire
ACA  was  unconstitutional  because  it  could  not  be  considered  an  exercise  of  Congressional  taxing  authority  following  the
repeal of the individual mandate penalties. In December 2019, a federal court of appeals upheld the district court's decision
that the ACA individual mandate was unconstitutional absent financial penalties, but remanded the case back to the district
court to determine whether the remaining provisions of the ACA were nonetheless valid. Pending appeals, which could take
some time, the ACA is still operational in all respects. We cannot predict the outcome of this litigation, including a possible
decision  by  the  United  States  Supreme  Court,  and  there  is  still  uncertainty  whether  the  ACA  will  undergo  additional
revisions. We cannot predict the impact of any future modifications.

There has been particular and increasing legislative and enforcement interest in the United States with respect to drug
pricing practices, particularly with respect to drugs that have been subject to relatively large price increases over relatively
short time periods. At the federal level, there have been several U.S. Congressional inquiries, proposed bills, and proposed
administrative  rules  designed  to,  among  other  things,  bring  more  transparency  to  drug  pricing,  review  the  relationship
between  pricing  and  manufacturer  patient  programs,  and  reform  government  program  reimbursement  methodologies  for
drugs. The outcome and potential effects of these proposals is unclear, but Congress and the Trump administration have each
indicated that they will continue to seek new legislative and/or administrative measures to control drug costs. At the state
level, legislatures have increasingly passed legislation and implemented 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, to encourage importation from other
countries and bulk purchasing.

In  addition,  in  some  non-U.S.  jurisdictions,  the  proposed  pricing  for  a  drug  must  be  approved  before  its  cost  may  be
funded within the respective national healthcare systems. The requirements governing drug pricing vary widely from country
to country. For example, European Union member states can restrict the range of medicinal products for which their national
health insurance systems provide reimbursement and may control the prices of medicinal products for human use. A member
state may approve a specific price for the medicinal product or it may instead adopt a system of direct or indirect controls on
the  profits  the  medicinal  product  generates  for  the  company  placing  it  on  the  market.  There  can  be  no  assurance  that  any
country that has price controls or reimbursement limitations for pharmaceutical products will allow favorable reimbursement
and pricing arrangements for any of our products on cost-effectiveness grounds. Historically, products launched in countries
in the European Union do not follow price structures of the United States and generally their prices tend to be significantly
lower.

U.S. Fraud and Abuse Laws

Interactions and arrangements with third-party payors, healthcare providers and professionals and customers are subject
to  broadly  applicable  fraud  and  abuse  and  other  healthcare  laws  and  regulations  that  may  restrict  certain  marketing  and
contracting practices. These laws include, federal and state anti-kickback and false claims statutes as well as other

29

Table of Contents

statutes  and  regulations  pertaining  to  healthcare  fraud  and  abuse.  Other  pharmaceutical  companies  have  settled  alleged  or
admitted violations of these fraud and abuse laws with state and federal authorities in recent years and in some cases these
settlements have amounted to hundreds of millions, or even billions, of dollars in damages, fines, and penalties, as well as the
imposition  of  compliance  program  obligations  through  Corporate  Integrity  Agreements  and  other  means.  Lawsuits,  or
enforcement actions brought under fraud and abuse laws, can be extremely costly to defend, even if a company has strong
defenses and ultimately succeeds in getting the allegations or enforcement action dismissed.

The  federal  Anti-Kickback  Statute  (42  U.S.C.  §1320a-7b(b))  prohibits,  among  other  things,  knowingly  and  willfully
soliciting, receiving, offering or providing remuneration, directly or indirectly, to induce either the referral of an individual,
or the furnishing, recommending, or arranging for any good or service, for which payment may be made under federal and
state healthcare programs such as Medicare, Medicaid or other federally financed healthcare programs. Remuneration is not
defined  in  the  federal  Anti-Kickback  Statute  and  has  been  broadly  interpreted  by  regulators  to  include  for  example,  cash
payments, gifts, discounts, coupons, and the furnishing of free or discounted services or supplies, and other items or services
of value to the recipient. This statute has been broadly interpreted to apply to manufacturer arrangements with prescribers,
purchasers,  formulary  managers  and  patients,  among  others.  Although  there  are  a  number  of  statutory  exceptions  and
regulatory safe harbors protecting certain common activities from prosecution or other regulatory sanctions, the exceptions
and safe harbors are drawn narrowly, and practices that involve remuneration intended to induce prescribing, purchases or
recommendations may be subject to scrutiny if they do not qualify for such exceptions or safe harbors.

The  federal  False  Claims  Act  imposes  civil  penalties,  including  treble  damages  and  significant  per-claim  penalties,
which  may  be  pursued  through  civil  whistleblower  or  qui  tam  actions,  against  individuals  or  entities  for  knowingly
presenting, or causing to be presented, to the federal government, 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. The government and qui
tam relators have brought False Claims Act actions against pharmaceutical companies on the theory that their practices have
caused  false  claims  to  be  presented  to  the  government.  There  is  also  a  separate  false  claims  provision  imposing  criminal
penalties.

Other federal healthcare fraud-related laws also impose criminal liability for violations. The Criminal Healthcare Fraud
statute (18 U.S.C. §1347) prohibits knowingly and willfully executing a scheme to defraud any healthcare benefit program,
including  private  third-party  payers.  Federal  criminal  law  also  prohibits  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.

A number of states also have statutes or regulations similar to the federal Anti-Kickback Statute and False Claims Act
that apply to items and services reimbursed under Medicaid and other state programs. Some state anti-kickback statutes apply
not just to government payors, but to all payors, including commercial payors and patients.

Other Laws

The Health Insurance Portability and Accountability Act of 1996, as amended by the Health Information Technology for
Economic  and  Clinical  Health  Act  (collectively,  “HIPAA”),  imposes  obligations,  on  “covered  entities,”  including  health
plans  and  healthcare  providers,  and  their  business  associates  with  respect  to  safeguarding  the  privacy,  security  and
transmission of individually identifiable health information. Although drug manufacturers are not directly subject to HIPAA,
we could be subject to criminal penalties if we knowingly obtain individually identifiable health information from a HIPAA-
covered  entity  in  a  manner  that  is  not  authorized  or  permitted  by  HIPAA.  We  are  also  subject  to  state,  federal  and
international privacy and security laws governing the processing and security of personal identifiable information.

The federal Physician Payments Sunshine Act requirements under the ACA, and its implementing regulations, require
manufacturers  of  drugs,  devices,  biologics  and  medical  supplies  to  report  to  the  U.S.  Department  of  Health  and  Human
Services information related to certain direct and indirect payments and other transfers of value made to covered recipients,
such  as  physicians  and  teaching  hospitals,  as  well  as  ownership  and  investment  interests  held  by  physicians  and  their
immediate family members. Payments made to physicians and research institutions for clinical trials are included within

30

Table of Contents

the ambit of this law. We are also subject to similar laws in several states and various European Union countries where we
have operations. Some of these state and EU laws are broader in scope than federal laws.

In  addition,  several  states  now  require  prescription  drug  companies  to  report  expenses  relating  to  the  marketing  and
promotion of drug products. Several states prohibit providing certain payments or items of value to healthcare providers or
other  enumerated  individuals  or  entities,  as  well  as  various  other  marketing-related  activities.  Certain  states  require  the
posting  of  information  relating  to  clinical  studies  and  their  outcomes.  In  addition,  California,  Connecticut,  Nevada  and
Massachusetts  require  pharmaceutical  companies  to  implement  compliance  programs  and  marketing  codes.  Several
additional states are considering similar proposals. Some of the state laws are broader in scope than federal laws. Compliance
with these laws is challenging and requires significant time and resources, and any failure to comply with such laws could
result in significant civil penalties and other adverse consequences.

Employees

As of December 31, 2019, we had 583 employees, of which 429 were based in the United States and 154 were based
outside the United States. None of our employees are represented by a labor union and we consider our employee relations to
be good.

Corporate and Available Information

We were incorporated in Delaware in September 2002. Our principal executive offices are located at 10 Hudson Yards,
37th Floor, New York, NY 10001 and our telephone number is (646) 747-1000. We have several additional offices, including
those in San Diego, California and London, United Kingdom. Our corporate website address is www.interceptpharma.com.
We  make  available  on  our  website,  free  of  charge,  our  Annual  Reports  on  Form  10-K,  Quarterly  Reports  on  Form  10-Q,
Current Reports on Form 8-K and any amendments to those reports filed or furnished pursuant to Section 13(a) or 15(d) of
the  Securities  Exchange  Act  of  1934,  as  amended  (the  “Exchange  Act”)  ,  as  soon  as  reasonably  practicable  after  we
electronically file such material with, or furnish it to, the Securities and Exchange Commission (“SEC”). Our SEC reports
can be accessed through the Investors & Media section of our internet website. The references to www.interceptpharma.com
herein are inactive textual references only, and the information found on our internet website is not incorporated by reference
into this Annual Report on Form 10-K or any other report we file with or furnish to the SEC. The SEC maintains an internet
website  that  contains  reports,  proxy  and  information  statements  and  other  information  about  issuers,  like  us,  that  file
electronically with the SEC. The address of that site is http://www.sec.gov.

31

Table of Contents

Item 1A.  Risk Factors

Investing in our securities involves a high degree of risk. The following risk factors and other information included in
this  Annual  Report  on  Form  10-K  should  be  carefully  considered  before  deciding  whether  to  invest  in  our  securities.  The
risks  and  uncertainties  described  below  and  in  our  other  filings  are  not  the  only  ones  we  face.  Additional  risks  and
uncertainties not presently known to us or that we presently deem less significant may also impair our business operations. If
any of the following risks, or such unknown risks, occur, our business, financial condition, results of operations and future
growth prospects could be materially and adversely affected. In that case, the market price of our securities could decline,
and you may lose all or part of your investment.

Risks Related to Our Financial Position and Need for Additional Capital

We  are  currently  dependent  on  the  successful  commercialization  of  Ocaliva  for  PBC.  To  the  extent  Ocaliva  is  not
commercially  successful,  our  business,  financial  condition  and  results  of  operations  may  be  materially  and  adversely
affected and the price of our common stock may decline.

Ocaliva  is  our  only  drug  that  has  been  approved  for  sale  and  it  has  only  been  approved  for  the  treatment  of  PBC  in
combination  with  UDCA  in  adults  with  an  inadequate  response  to  UDCA  or  as  monotherapy  in  adults  unable  to  tolerate
UDCA.

Our  ability  to  generate  profits  from  operations  and  become  profitable  currently  depends  on  the  commercial  success  of
Ocaliva  for  PBC.  However,  the  successful  commercialization  of  Ocaliva  for  PBC  is  subject  to  many  risks.  We  have  not
launched or commercialized a drug before, and there is no guarantee that we will be able to do so successfully. There are
numerous  examples  of  unsuccessful  product  launches  and  commercial  efforts,  as  well  as  failures  to  meet  expectations  of
market potential, including by pharmaceutical companies with greater experience and resources than us.

The commercial success of Ocaliva for PBC depends on the extent to which patients, physicians and payers accept and
adopt Ocaliva as a treatment for PBC, and we do not know whether our or others’ estimates in this regard will be accurate.
As such, there is significant uncertainty in the degree of market acceptance that Ocaliva will have for PBC. For example, if
the  patient  population  suffering  from  PBC  is  smaller  than  we  estimate,  or  even  if  the  patient  population  matches  our
estimates but Ocaliva is not widely accepted as a treatment for PBC, the commercial potential of Ocaliva for PBC will be
limited. Physicians may not prescribe Ocaliva and patients may be unwilling to use Ocaliva if coverage is not provided or
reimbursement is inadequate to cover a significant portion of the cost. Additionally, the use of Ocaliva in a non-trial setting
may  result  in  the  occurrence  of  unexpected  or  a  greater  incidence  of  side  effects,  adverse  reactions  or  misuse  that  may
negatively  affect  the  commercial  prospects  of  Ocaliva  for  PBC.  Furthermore,  any  negative  development  in  any  other
development  program  for  OCA  or  our  failure  to  satisfy  the  post-marketing  regulatory  commitments  and  requirements  to
which we are or may become subject, including the completion of our Phase 4 COBALT trial, may materially and adversely
impact  the  commercial  results  and  potential  of  Ocaliva  for  PBC.  See  “—Risks  Related  to  the  Development  and  the
Regulatory Review and Approval of Our Products and Product Candidates” and “—Risks Related to the Commercialization
of Our Products” below.

As a result, it is uncertain whether Ocaliva net sales for PBC will sustain our operations and it may take a significant
amount of time before Ocaliva net sales for PBC sustain our operations. Furthermore, Ocaliva may not receive regulatory
approval for PBC in jurisdictions beyond those in which it is currently approved, which may also limit our prospects. If the
commercialization of Ocaliva for PBC is unsuccessful or perceived to be unsuccessful, the long-term prospects of Ocaliva
for PBC, as well as the long-term prospects of our company, may be materially and adversely affected.

We have never been profitable. We expect to incur losses for the foreseeable future, and we may never achieve or sustain
profitability.

We  have  never  been  profitable  and  do  not  expect  to  be  profitable  in  the  foreseeable  future.  We  incurred  net  losses  of
$344.7 million, $309.2 million and $360.4 million for the years ended December 31, 2019, 2018 and 2017, respectively. To
date, we have financed our operations primarily through public offerings and private placements of our securities, sales

32

Table of Contents

of product and payments received under our licensing and collaboration agreements. At December 31, 2019, we had $657.4
million in cash, cash equivalents, restricted cash and investment debt securities.

We have devoted substantially all of our resources to the development of our product candidates, including the conduct
of our clinical trials, the launch and commercialization of Ocaliva for PBC, preparation for the potential launch of OCA for
liver fibrosis due to NASH and general and administrative operations, including the protection of our intellectual property.

We expect to continue to incur losses for the foreseeable future, and we expect these losses to be significant as we, among
other things, continue to commercialize Ocaliva for PBC, develop and seek and maintain regulatory approvals for OCA for
liver  fibrosis  due  to  NASH  and  other  indications,  and  build  out  the  infrastructure  in  the  United  States  and  internationally
necessary  to  support  our  product  development  and  commercialization  efforts.  We  believe  our  prospects  and  ability  to
significantly grow revenues will be dependent on our ability to successfully develop and commercialize OCA for indications
other than PBC, such as NASH. As a result, we expect a significant amount of resources to continue to be devoted to our
development programs for OCA.

As part of our product development activities, we anticipate that we will continue our Phase 4 COBALT trial of Ocaliva
for  PBC.  We  also  expect  to  continue  our  Phase  3  clinical  program  of  OCA  for  liver  fibrosis  due  to  NASH,  including  our
Phase  3  REGENERATE  trial  in  patients  with  liver  fibrosis  due  to  NASH  through  clinical  outcomes  for  verification  and
description of clinical benefit and our Phase 3 REVERSE trial for NASH patients with compensated cirrhosis. We intend to
evaluate the efficacy, safety and tolerability of bezafibrate in combination with OCA in patients with PBC in a Phase 2 study
and  to  continue  to  develop  OCA  and  our  other  existing  product  candidates,  alone  or  in  combination,  for  non-viral  liver
diseases. Our overall development program for OCA for liver fibrosis due to NASH is expected to include a number of trials,
including clinical trials required to file for approval of OCA for liver fibrosis due to NASH and to confirm clinical benefit.
Our  expenses  could  increase  if  we  are  required  by  the  FDA  or  the  EMA  to  perform  studies  or  trials  in  addition  to  those
currently expected, if our current trials are modified for any reason, or if there are any delays in completing our clinical trials
or the development of any of our product candidates.

If OCA or any of our other product candidates fails in clinical trials or does not gain or maintain regulatory approval, or
if OCA or any of our other product candidates does not achieve market acceptance, we may never become profitable. Our net
losses  and  negative  cash  flows  have  had,  and  will  continue  to  have,  an  adverse  effect  on  our  stockholders’  equity  and
working capital. Because of the numerous risks and uncertainties associated with pharmaceutical product development and
commercialization, we are unable to predict with certainty the timing or amount of our expenses, whether such expenses may
increase, or when, or if, we will be able to achieve profitability. The amount of our future net losses will depend, in part, on
our future expenses, whether and by how much such expenses increase and our ability to generate revenues.

We will require substantial additional funding, which may not be available to us on acceptable terms, if at all. If adequate
funds are not available to us, we may be required to delay, limit, reduce or cease our operations.

We  are  currently  advancing  OCA  through  clinical  development  for  multiple  indications,  including  NASH,  and  other
product  candidates  through  various  stages  of  clinical  and  preclinical  development.  Developing  pharmaceutical  products,
including conducting preclinical studies and clinical trials, is expensive. If, for example, the FDA, EMA or other regulatory
authorities  require  that  we  perform  additional  studies  beyond  those  that  we  currently  expect,  our  expenses  could  increase
materially beyond what we currently anticipate, and the timing of any potential product approval may be delayed.

In addition, we have incurred and anticipate that we will continue to incur significant research and development, product
sales, marketing, manufacturing and distribution expenses relating to the commercialization of Ocaliva for PBC and OCA for
liver  fibrosis  due  to  NASH,  if  approved.  As  part  of  our  longer-term  strategy,  we  anticipate  that  we  will  incur  significant
expenses  in  connection  with  our  research  and  development  efforts,  the  commercialization  of  our  approved  products  other
than  Ocaliva  for  PBC  and  OCA  for  liver  fibrosis  due  to  NASH,  if  approved,  and  the  build-out  of  our  general  and
administrative infrastructure in the United States and abroad. We may also engage in business development activities

33

Table of Contents

that  involve  potential  in-  or  out-licensing  of  products  or  technologies  or  acquisitions  of  other  products,  technologies  or
businesses.

As  of  December  31,  2019,  we  had  $657.4  million  in  cash,  cash  equivalents,  restricted  cash  and  investment  debt
securities.  We  currently  expect  to  continue  to  incur  significant  operating  expenses  in  the  fiscal  year  ending  December  31,
2020. These expenses are planned to support, among other initiatives, the continued commercialization of Ocaliva for PBC in
the  United  States  and  our  other  markets,  launch  preparation  and  commercialization  activities  associated  with  the  potential
approval  and  commercialization  of  OCA  for  liver  fibrosis  due  to  NASH,  our  continued  clinical  development  of  OCA  for
PBC  and  NASH  and  our  other  earlier  stage  research  programs.  Although  we  believe  that  our  existing  capital  resources,
together with our net sales of Ocaliva for PBC, will be sufficient to fund our anticipated operating requirements for the next
twelve months and the initial phase of the anticipated U.S. launch of OCA for liver fibrosis due to NASH, we may need to
raise additional capital to fund our operating requirements beyond that period. Furthermore, in light of the numerous risks
and  uncertainties  associated  with  pharmaceutical  product  development  and  commercialization,  any  delays  in,  or
unanticipated costs associated with, our development, regulatory or commercialization efforts could significantly increase the
amount  of  capital  required  by  us  to  fund  our  operating  requirements.  Accordingly,  we  may  seek  to  access  the  public  or
private capital markets whenever conditions are favorable, even if we do not have an immediate need for additional capital at
that time. Our forecast regarding the period of time through which our financial resources will be adequate to support our
operations  is  a  forward-looking  statement  that  involves  risks  and  uncertainties,  and  actual  results,  including  the  costs  to
maintain our currently planned operations, could vary materially.

Our  forecasts  regarding  the  period  of  time  that  our  existing  capital  resources  will  be  sufficient  to  meet  our  operating
requirements and the timing of our future funding requirements, both near and long-term, will depend on a variety of factors,
many of which are outside of our control. Such factors include, but are not limited to:

● our ability to successfully commercialize Ocaliva for PBC;

● our ability to maintain our regulatory approval of Ocaliva for PBC in the United States, Europe, Canada, Israel,

Australia and other jurisdictions in which we have or may receive marketing authorization;

● the initiation, timing, cost, conduct, progress and results of our research and development activities, preclinical
studies  and  clinical  trials,  including  any  issues,  delays  or  failures  in  identifying  patients,  enrolling  patients,
treating patients, retaining patients, meeting specific endpoints in the jurisdictions in which we intend to seek
approval or completing and timely reporting the results of our NASH or PBC clinical trials;

● our  ability  to  timely  and  cost-effectively  file  for  and  obtain  regulatory  approval  of  our  product  candidates,
including  the  regulatory  approval  of  our  NDA  for  NASH;  any  advisory  committee  recommendation  that  our
product candidates, including OCA for liver fibrosis due to NASH, should not be approved or approved only
under certain conditions; or any determination that the regulatory applications and subsequent information we
submit  for  our  product  candidates,  including  OCA  for  liver  fibrosis  due  to  NASH,  do  not  contain  adequate
clinical or other data or meet applicable regulatory requirements for approval;

● conditions  that  may  be  imposed  by  regulatory  authorities  on  our  marketing  approvals  for  our  products  and
product candidates, such as the need for clinical outcomes data (and not just results based on achievement of a
surrogate endpoint), and any related restrictions, limitations and/or warnings contained in the label of any of
our products or product candidates;

● any potential side effects associated with Ocaliva for PBC, OCA for liver fibrosis due to NASH or our other
product  candidates  that  could  delay  or  prevent  approval,  require  that  an  approved  product  be  taken  off  the
market, require the inclusion of safety warnings or precautions or otherwise limit the sale of such product or
product candidate;

● our  ability  to  establish  and  maintain  relationships  with,  and  the  performance  of,  third-party  manufacturers,
contract research organizations and other vendors upon whom we are substantially dependent for, among

34

Table of Contents

other things, the manufacture and supply of our products, including Ocaliva for PBC and, if approved, OCA for
liver fibrosis due to NASH, and our clinical trial activities;

● our ability to identify, develop and successfully commercialize our products and product candidates, including

our ability to timely and successfully launch OCA for liver fibrosis due to NASH, if approved;

● our  ability  to  obtain  and  maintain  intellectual  property  protection  for  our  products  and  product  candidates,
including  our  ability  to  cost-effectively  file,  prosecute,  defend  and  enforce  any  patent  claims  or  other
intellectual property rights;

● the  size  and  growth  of  the  markets  for  our  products  and  product  candidates  and  our  ability  to  serve  those

markets;

● the degree of market acceptance of Ocaliva for PBC and, if approved, OCA for liver fibrosis due to NASH or

our other product candidates among physicians, patients and healthcare payors;

● the availability of adequate coverage and reimbursement from governmental and private healthcare payors for
our products, including Ocaliva for PBC and, if approved, OCA for liver fibrosis due to NASH, and our ability
to obtain adequate pricing for such products;

● our ability to establish and maintain effective sales, marketing and distribution capabilities, either directly or

through collaborations with third parties;

● competition from existing drugs or new drugs that become available;

● our ability to prevent system failures, data breaches or violations of data protection laws;

● costs  and  outcomes  relating  to  any  disputes,  governmental  inquiries  or  investigations,  legal  proceedings  or
litigation, including any securities, intellectual property, employment, product liability or other litigation;

● our collaborators’ election to pursue research, development and commercialization activities;

● our  ability  to  establish  and  maintain  relationships  with  collaborators  with  development,  regulatory  and

commercialization expertise;

● our need for and ability to generate or obtain additional financing;

● our estimates regarding future expenses, revenues and capital requirements and the accuracy thereof;

● our use of cash and short-term investments;

● our ability to acquire, license and invest in businesses, technologies, product candidates and products;

● our ability to attract and retain key personnel to manage our business effectively;

● our ability to manage the growth of our operations, infrastructure, personnel, systems and controls;

● our ability to obtain and maintain adequate insurance coverage;

● the impact of general U.S. and foreign economic, industry, market, regulatory or political conditions, including

the potential impact of Brexit; and

35

Table of Contents

● the other risks and uncertainties identified under the captions “Risk Factors”, “Business” and “Management’s
Discussion  and  Analysis  of  Financial  Condition  and  Results  of  Operations”  and  elsewhere  in  this  Annual
Report on Form 10-K and in our other periodic filings filed with the SEC.

We have no committed external sources of funding and additional funds may not be available when we need them on
terms that are acceptable to us, or at all. In addition, our restated certificate of incorporation authorizes us to issue 45 million
shares of common stock. Following the 2019 Public Offering and the 2019 Concurrent Private Placement, and after taking
into  account  shares  of  common  stock  reserved  for  issuance  upon  the  exercise  of  outstanding  stock  options,  the  vesting  of
outstanding restricted stock units (including performance restricted stock units) and the conversion of the Convertible Notes,
together with shares of common stock available for future grants under our equity incentive plan, we have a limited number
of remaining unreserved and authorized shares available for issuance, which could impact our ability to raise additional funds
in the future. If adequate funds are not available to us, we may not be able to make scheduled debt payments on a timely
basis, or at all, and may be required to delay, limit, reduce or cease our operations.

Raising additional capital may cause dilution to our stockholders, restrict our operations or require us to relinquish rights
to our technologies or product candidates.

Unless  and  until  we  generate  sufficient  cash  flow  from  sales  of  our  products,  including  Ocaliva  for  PBC  and,  if
approved, OCA for liver fibrosis due to NASH, we expect to finance our future cash needs through public or private equity
or debt financings, government or other third-party funding, marketing and distribution arrangements or other collaborations,
strategic alliances and licensing arrangements, or a combination of these sources. Additional funding may not be available to
us on acceptable terms, if at all.

The terms of any future financing may adversely affect the interests of our existing securityholders. For example, to the
extent that we raise additional capital through the sale of equity or convertible debt securities, our stockholders’ ownership
interest will be diluted, and the terms of these securities may include liquidation or other preferences that adversely affect the
rights of our common stockholders. Debt 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.  We  also  could  be  required  to  seek  funds  through  arrangements  with  licensing  or  collaborative  partners  or
otherwise that may require us to relinquish rights to some of our technologies or product candidates or otherwise agree to
terms unfavorable 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 product development or future commercialization efforts or grant rights to
develop and market product candidates that we would otherwise prefer to develop and market ourselves.

We  have  a  limited  operating  history  as  a  commercial  organization,  which  may  make  it  difficult  to  predict  our  future
performance, and we expect to continue to face a number of factors that may cause operating results to fluctuate.

We are a biopharmaceutical company with a limited operating history as a commercial organization. Prior to the launch
and  commercialization  of  Ocaliva  for  PBC,  our  operations  were  limited  to  developing  our  technology,  undertaking
preclinical studies and clinical trials of our product candidates and preparing for the commercial launch of Ocaliva for PBC.
Other  than  Ocaliva  for  PBC,  none  of  our  other  product  candidates  have  received  regulatory  approval.  Consequently,  any
predictions regarding our future success or viability may not be as accurate as they could be if we had a longer operating
history or greater experience commercializing approved products.

The commercialization of Ocaliva for PBC has been and will continue to be, and, if approved, the commercialization of
OCA for liver fibrosis due to NASH will be, expensive and time-consuming, and we cannot be certain that we will be able to
generate  sufficient  revenues  from  sales  of  Ocaliva  for  PBC  and,  if  approved,  OCA  for  liver  fibrosis  due  to  NASH  in  our
target markets to offset such costs. Furthermore, our financial condition and operating results have varied significantly in the
past  and  are  expected  to  continue  to  significantly  fluctuate  from  quarter-to-quarter  and  year-to-year  due  to  a  variety  of
factors, many of which are outside of our control. Such factors include, but are not limited to:

● our ability to successfully commercialize Ocaliva for PBC;

36

Table of Contents

● our ability to maintain our regulatory approval of Ocaliva for PBC in the United States, Europe, Canada, Israel,

Australia and other jurisdictions in which we have or may receive marketing authorization;

● the initiation, timing, cost, conduct, progress and results of our research and development activities, preclinical
studies  and  clinical  trials,  including  any  issues,  delays  or  failures  in  identifying  patients,  enrolling  patients,
treating patients, retaining patients, meeting specific endpoints in the jurisdictions in which we intend to seek
approval or completing and timely reporting the results of our NASH or PBC clinical trials;

● our  ability  to  timely  and  cost-effectively  file  for  and  obtain  regulatory  approval  of  our  product  candidates,
including  the  regulatory  approval  of  our  NDA  for  NASH;  any  advisory  committee  recommendation  that  our
product candidates, including OCA for liver fibrosis due to NASH, should not be approved or approved only
under  certain  conditions;  any  determination  that  the  regulatory  applications  and  subsequent  information  we
submit  for  our  product  candidates,  including  OCA  for  liver  fibrosis  due  to  NASH,  do  not  contain  adequate
clinical or other data or meet applicable regulatory requirements for approval;

● conditions  that  may  be  imposed  by  regulatory  authorities  on  our  marketing  approvals  for  our  products  and
product candidates, such as the need for clinical outcomes data (and not just results based on achievement of a
surrogate endpoint), and any related restrictions, limitations and/or warnings contained in the label of any of
our products or product candidates;

● any potential side effects associated with Ocaliva for PBC, OCA for liver fibrosis due to NASH or our other
product  candidates  that  could  delay  or  prevent  approval,  require  that  an  approved  product  be  taken  off  the
market, require the inclusion of safety warnings or precautions or otherwise limit the sale of such product or
product candidate;

● our  ability  to  establish  and  maintain  relationships  with,  and  the  performance  of,  third-party  manufacturers,
contract research organizations and other vendors upon whom we are substantially dependent for, among other
things, the manufacture and supply of our products, including Ocaliva for PBC and, if approved, OCA for liver
fibrosis due to NASH, and our clinical trial activities;

● our ability to identify, develop and successfully commercialize our products and product candidates, including

our ability to timely and successfully launch OCA for liver fibrosis due to NASH, if approved;

● our  ability  to  obtain  and  maintain  intellectual  property  protection  for  our  products  and  product  candidates,
including  our  ability  to  cost-effectively  file,  prosecute,  defend  and  enforce  any  patent  claims  or  other
intellectual property rights;

● the  size  and  growth  of  the  markets  for  our  products  and  product  candidates  and  our  ability  to  serve  those

markets;

● the degree of market acceptance of Ocaliva for PBC and, if approved, OCA for liver fibrosis due to NASH or

our other product candidates among physicians, patients and healthcare payors;

● the availability of adequate coverage and reimbursement from governmental and private healthcare payors for
our products, including Ocaliva for PBC and, if approved, OCA for liver fibrosis due to NASH, and our ability
to obtain adequate pricing for such products;

● our ability to establish and maintain effective sales, marketing and distribution capabilities, either directly or

through collaborations with third parties;

● competition from existing drugs or new drugs that become available;

● our ability to prevent system failures, data breaches or violations of data protection laws;

37

Table of Contents

● costs  and  outcomes  relating  to  any  disputes,  governmental  inquiries  or  investigations,  legal  proceedings  or
litigation, including any securities, intellectual property, employment, product liability or other litigation;

● our collaborators’ election to pursue research, development and commercialization activities;

● our  ability  to  establish  and  maintain  relationships  with  collaborators  with  development,  regulatory  and

commercialization expertise;

● our need for and ability to generate or obtain additional financing;

● our estimates regarding future expenses, revenues and capital requirements and the accuracy thereof;

● our use of cash and short-term investments;

● our ability to acquire, license and invest in businesses, technologies, product candidates and products;

● our ability to attract and retain key personnel to manage our business effectively;

● our ability to manage the growth of our operations, infrastructure, personnel, systems and controls;

● our ability to obtain and maintain adequate insurance coverage;

● the impact of general U.S. and foreign economic, industry, market, regulatory or political conditions, including

the potential impact of Brexit; and

● the other risks and uncertainties identified under the captions “Risk Factors”, “Business” and “Management’s
Discussion  and  Analysis  of  Financial  Condition  and  Results  of  Operations”  and  elsewhere  in  this  Annual
Report on Form 10-K and in our other periodic filings filed with the SEC.

Risks Related to the Development and the Regulatory Review and
Approval of Our Products and Product Candidates

We cannot be certain whether Ocaliva will receive full approval for PBC in jurisdictions where it has previously received
accelerated or conditional approval, or that Ocaliva will be approved for PBC in any jurisdictions beyond those in which
it is currently approved. Furthermore, OCA may not be approved for NASH or any other indication beyond PBC and we
may not receive regulatory approval for any other product candidate. Without regulatory approval, we will not be able to
market and commercialize our product candidates.

The  development,  testing,  manufacture,  packaging,  labeling,  storage,  approval,  promotion,  advertising,  distribution,
marketing  and  export  and  import,  among  other  things,  of  our  products  and  product  candidates  are  subject  to  extensive
regulation by the FDA in the United States, the EMA in Europe and various regulatory authorities in other countries, with
regulations differing from country to country. We are not permitted to market our product candidates in the United States or
Europe until we receive approval of a NDA, from the FDA, or a MAA, from the EMA, respectively. Currently, our ability to
generate product sales depends on the successful marketing of Ocaliva for PBC in the jurisdictions in which it has received
regulatory approval. In the future, our ability to generate product sales in addition to those of Ocaliva for PBC will depend on
whether we are successful in obtaining regulatory approval of our other product candidates, including OCA for liver fibrosis
due to NASH.

Ocaliva  is  our  only  drug  that  has  been  approved  for  sale  and  it  has  only  been  approved  for  the  treatment  of  PBC  in
combination  with  UDCA  in  adults  with  an  inadequate  response  to  UDCA  or  as  monotherapy  in  adults  unable  to  tolerate
UDCA. In the United States, Ocaliva was approved for PBC under the accelerated approval pathway. Accelerated approval
was  granted  for  Ocaliva  for  PBC  based  on  a  reduction  in  ALP;  however,  an  improvement  in  survival  or  disease-related
symptoms has not yet been established. Continued approval of Ocaliva for PBC in the United States is contingent upon

38

Table of Contents

the  verification  and  description  of  clinical  benefit  in  confirmatory  trials  and  our  satisfaction  of  our  other  post-marketing
regulatory requirements. Our Phase 4 COBALT confirmatory outcomes trial may fail to show a clinical benefit for Ocaliva
for  PBC  or  may  not  satisfy  applicable  regulatory  requirements  for  other  reasons.  As  specified  by  the  applicable  post-
marketing  requirements,  our  COBALT  trial  includes  subjects  across  the  spectrum  of  PBC  disease,  including  early  and
advanced PBC. We have agreed to evaluate the safety and efficacy of Ocaliva in patients with moderate to severe hepatic
impairment and as a monotherapy in patients with PBC. In addition, we have agreed to develop and characterize a lower dose
formulation of Ocaliva to allow for once daily dosing in patients with moderate or advanced hepatic impairment.

We  commenced  our  commercial  launch  of  Ocaliva  for  PBC  in  certain  European  countries  in  2017  following  the
European  Commission’s  grant  of  conditional  approval  in  December  2016.  Our  marketing  authorization  in  the  European
Union  is  conditioned  on  the  completion  of  the  COBALT  trial  and  a  trial  evaluating  the  safety  and  efficacy  of  Ocaliva  in
patients with moderate to severe hepatic impairment.

Since January 2017, Ocaliva has also received regulatory approval in several of our target markets outside the United
States and Europe, including Canada, Israel and Australia, and we are pursuing marketing approval of Ocaliva for PBC in
our  other  international  target  markets.  If  obtained,  continued  approval  of  Ocaliva  for  PBC  in  such  jurisdictions  may  be
contingent upon the verification and description of clinical benefit in confirmatory trials. Any delay or failure in satisfying
the post-marketing regulatory commitments and requirements to which we are or may become subject, including our Phase 4
COBALT trial, may jeopardize the continued approval of Ocaliva for PBC in the United States, European Union and other
jurisdictions.

Ocaliva is not approved for any indication other than PBC. We currently have no other products approved for sale and
we  cannot  guarantee  that  we  will  ever  have  additional  marketable  products  or  that  OCA  will  be  approved  for  use  in
additional indications such as NASH. NDAs and MAAs must include extensive preclinical and clinical data and supporting
information to establish the product candidate’s safety and effectiveness for each desired indication. NDAs and MAAs must
also include significant information regarding the chemistry, manufacturing and controls for the product. Obtaining approval
of a NDA or a MAA is a lengthy, expensive and uncertain process, and we may not be successful in obtaining approval. The
FDA and the EMA review processes can take years to complete and approval is not guaranteed. Even after the submission of
a NDA, the FDA may decide not to accept the submission for filing and review. Similarly, there may be delays in the EMA’s
review  process  following  the  submission  of  a  MAA,  or  the  EMA  may  determine  that  the  submission  does  not  support
approval.  In  addition,  in  June  2016,  eligible  members  of  the  electorate  in  the  United  Kingdom  decided  by  referendum  to
leave  the  European  Union,  in  what  is  often  referred  to  as  “Brexit”.  Because  a  significant  proportion  of  the  regulatory
framework  in  the  United  Kingdom  is  derived  from  European  Union  directives  and  regulations,  Brexit  could  materially
change the regulatory regime applicable to our operations, including with respect to Ocaliva for PBC and, if approved, OCA
for liver fibrosis due to NASH and our other product candidates.

As  is  the  case  with  the  approval  of  Ocaliva  for  PBC,  any  future  approvals  or  potential  future  approvals  may  also  be
conditional  upon  the  completion  of  one  or  more  clinical  trials.  In  addition,  delays  in  approvals  or  rejections  of  marketing
applications  in  the  United  States,  Europe  or  other  countries  may  be  based  upon  many  factors,  including,  for  example,
regulatory  requests  for  additional  analyses,  reports,  data,  preclinical  studies  and  clinical  trials,  regulatory  endpoint
requirements,  regulatory  questions  regarding  safety  or  risk-benefit  profile,  different  interpretations  of  data  and  results,
changes in regulatory policy during the period of product development and the emergence of new information regarding our
product candidates or approved products. Initial and continued regulatory approval is also dependent on successfully passing
regulatory inspection requirements applicable to us, our clinical sites and our key vendors, including requirements that we
and  such  parties  comply  with  applicable  good  clinical,  pharmacovigilance,  laboratory  and  manufacturing  practices
regulations. Critical findings could jeopardize or delay the approval of our NDAs or MAAs or impair our ability to maintain
our marketing approvals.

Prior  to  receiving  regulatory  approval,  we  must  finalize  the  product  label  for  each  of  our  product  candidates  in  each
jurisdiction  in  which  we  seek  regulatory  approval.  Even  if  our  product  is  approved,  the  FDA,  EMA  or  other  applicable
regulatory authority may limit the indications or uses for which our product may be marketed, require extensive warnings on
the  product  labeling  or  require  expensive  and  time-consuming  clinical  trials,  risk  mitigation  programs  such  as  a  REMS,
monitoring or reporting as a condition of approval. Also, regulatory approval for our approved products may be withdrawn.

39

Table of Contents

In addition, obtaining regulatory approval for the marketing of our product in one country does not ensure that we will be
able to obtain regulatory approval for such product in any other country.

In order to obtain regulatory approval for OCA for indications other than PBC, we will need to complete a number of
additional clinical trials and studies. For example, in connection with our Phase 3 clinical program of OCA for liver fibrosis
due  to  NASH,  we  are  currently  conducting  our  Phase  3  REGENERATE  trial  in  patients  with  liver  fibrosis  due  to  NASH
through  clinical  outcomes  for  verification  and  description  of  clinical  benefit  and  our  Phase  3  REVERSE  trial  for  NASH
patients with compensated cirrhosis. Our ability to obtain and maintain the regulatory approvals necessary to commercialize
OCA  for  indications  other  than  PBC,  including  NASH,  will  depend  on  our  ability  to  successfully  design,  conduct  and
complete  these  trials,  the  efficacy,  safety  and  risk-benefit  profile  of  OCA  demonstrated  by  such  trials  and  our  ability  to
prepare and submit complex regulatory filings in accordance with applicable regulatory requirements.

There can be no assurance that OCA will receive marketing approval for PBC in jurisdictions where it has not yet been
approved or for NASH in any jurisdiction, or that any of our other product candidates will receive marketing approval for
any  indication  in  any  jurisdiction.  We  cannot  predict  whether  our  clinical  trials  and  studies  for  our  product  candidates,
including OCA for PBC, NASH or any other indication, will be successful, whether regulatory authorities will agree with our
conclusions  relating  to  the  clinical  trials  and  studies  we  conduct,  or  whether  such  regulatory  authorities  will  require  us  to
conduct  additional  clinical  trials  or  studies.  For  example,  while  OCA  received  breakthrough  therapy  designation  from  the
FDA in January 2015 for the treatment of NASH patients with liver fibrosis and we filed a NDA in the United States and a
MAA in Europe based on the results from the 18-month analysis of our Phase 3 REGENERATE trial in patients with liver
fibrosis due to NASH, we do not know if one pivotal clinical trial will be sufficient for marketing approval or if regulatory
authorities in the United States, Europe or our other target markets will approve OCA for liver fibrosis due to NASH on an
accelerated or conditional basis, or at all. Our Phase 3 REGENERATE trial remains blinded after the interim analysis and
will  continue  to  follow  patients  until  the  occurrence  of  a  pre-specified  number  of  adverse  clinical  outcomes,  including
progression to cirrhosis, for verification and description of clinical benefit on a post-marketing basis, if approved.

If we are unable to obtain regulatory approval for OCA for PBC in the jurisdictions in which it is not currently approved
or  obtain  regulatory  approval  in  the  United  States,  European  Union  and  other  jurisdictions  for  OCA  for  other  indications,
such as NASH, or for our other product candidates, we may not be able to generate sufficient revenue to become profitable or
to continue our operations.

We  are  developing  product  candidates  for  the  treatment  of  rare  diseases  or  diseases  for  which  there  are  no  or  limited
therapies,  such  as  PBC  and  NASH,  and  for  some  of  which  there  is  little  clinical  experience,  and  our  development
approach involves new endpoints and methodologies. As a result, there is a heightened risk that we will not be able to gain
agreement with regulatory authorities regarding an acceptable development plan, that the outcome of our clinical trials
will not be favorable or that, even if favorable, regulatory authorities may not find the results of our clinical trials to be
sufficient for marketing approval.

We  are  focused  on  developing  therapeutics  for  the  treatment  of  rare  diseases  and  diseases  for  which  there  are  no  or
limited treatments. As a result, the design and conduct of our clinical trials for these indications is subject to heightened risk.

In  the  United  States,  the  FDA  generally  requires  two  adequate  and  well-controlled  pivotal  clinical  trials  to  approve  a
NDA.  Furthermore,  for  full  approval  of  a  NDA,  the  FDA  requires  a  demonstration  of  efficacy  based  on  a  clinical  benefit
endpoint.  The  FDA  may  grant  accelerated  approval  based  on  a  surrogate  endpoint  reasonably  likely  to  predict  clinical
benefit. Even though our pivotal clinical trials for a specific indication, such as our Phase 3 REGENERATE trial of OCA in
patients with liver fibrosis due to NASH and our Phase 3 REVERSE trial for NASH patients with compensated cirrhosis,
may achieve their primary endpoints and are reasonably believed by us to be likely to predict clinical benefit, the FDA may
not accept the results of such trials or approve our product candidate on an accelerated basis, or at all. It is also possible that
the  FDA  may  refuse  to  accept  for  filing  and  review  any  regulatory  application  we  submit  for  regulatory  approval  in  the
United States. Even if our regulatory application is accepted for review, such as the NDA we submitted for liver fibrosis due
to NASH that was accepted for review by the FDA in November 2019, there may be delays in the FDA’s review process and
the  FDA  may  determine  that  such  regulatory  application  does  not  contain  adequate  clinical  or  other  data  or  support  the
approval of the product candidate. In such a case, the FDA may issue a complete response letter that may

40

Table of Contents

require that we conduct and/or complete additional clinical trials and preclinical studies or provide additional information or
data before it will reconsider our application for approval. Any such requirements may be substantial, expensive and time-
consuming, and there is no guarantee that we will continue to pursue such application or that the FDA will ultimately decide
that any such application supports the approval of the product candidate. The FDA may also refer any regulatory application,
and  has  referred  our  NDA  for  OCA  for  liver  fibrosis  due  to  NASH,  to  an  advisory  committee  for  review  and
recommendation as to whether, and under what conditions, the application should be approved. While the FDA is not bound
by the recommendation of an advisory committee, it considers such recommendations carefully when making decisions.

Even if we receive accelerated approval for any of our product candidates, we may be required to conduct or complete a
post-approval  clinical  outcomes  trial  to  confirm  the  clinical  benefit  of  such  product  candidates  by  demonstrating  the
correlation of the surrogate endpoint therapeutic response in patients with a significant reduction in adverse clinical outcomes
over time. For example, interim analysis results at 18 months in our Phase 3 REGENERATE trial were based on surrogate
endpoints and the impact on clinical outcomes has not been confirmed. The REGENERATE trial is ongoing for verification
and  description  of  clinical  benefit  of  OCA  for  liver  fibrosis  due  to  NASH.  There  can  be  no  assurance  that  the  clinical
outcomes  portion  of  our  REGENERATE  trial  will  confirm  that  the  surrogate  endpoint  used  as  the  basis  of  the  regulatory
submissions we have made or expect to make seeking approval of OCA for liver fibrosis due to NASH will eventually show
an adequate correlation with clinical outcomes. In addition, as a condition of the accelerated approval of Ocaliva for PBC in
the  United  States,  we  are  required  to  conduct  a  clinical  outcomes  study  with  respect  to  Ocaliva  for  PBC.  Following
discussions with regulatory authorities, we initiated our COBALT clinical outcomes confirmatory trial for PBC in December
2014  prior  to  the  approval  of  Ocaliva  for  PBC.  The  COBALT  trial  includes  subjects  across  the  spectrum  of  PBC  disease,
including early and advanced PBC. We have agreed to evaluate the safety and efficacy of Ocaliva in patients with moderate
to severe hepatic impairment and as a monotherapy in patients with PBC. There can be no assurance that our COBALT trial
conducted as part of our post-marketing obligations will confirm that the surrogate endpoint used for accelerated approval of
Ocaliva for PBC will eventually show an adequate correlation with clinical outcomes or that our clinical trial in PBC patients
with moderate to severe hepatic impairment will be successful. If any such trial is delayed or fails, we may not be able to
maintain  our  previously  granted  marketing  approval  of  Ocaliva  for  PBC.  Similarly,  if  approved  based  on  a  surrogate
endpoint,  continued  approval  of  OCA  for  other  indications,  or  of  any  of  our  other  product  candidates,  may  be  contingent
upon the verification and description of clinical benefit in confirmatory trials.

Our marketing authorization in the European Union for Ocaliva for the treatment of PBC is not a full approval. Instead,
it is conditional on the conduct of certain post-approval studies. Our ability to maintain conditional marketing authorization
of  Ocaliva  for  PBC  in  the  European  Union  is  limited  to  specific  circumstances  and  subject  to  several  conditions  and
obligations that we may be unable to satisfy in whole or at all, including the completion of one or more clinical outcomes
trials to confirm the clinical benefit of Ocaliva for PBC. Conditional marketing authorizations based on incomplete clinical
data  may  be  granted  for  a  limited  number  of  listed  medicinal  products  for  human  use,  including  products  designated  as
orphan medicinal products under European Union law, if (i) the risk-benefit balance of the product is positive, (ii) it is likely
that the applicant will be in a position to provide the required comprehensive clinical trial data, (iii) unmet medical needs will
be  fulfilled  and  (iv)  the  benefit  to  public  health  of  the  immediate  availability  on  the  market  of  the  medicinal  product
outweighs  the  risk  inherent  in  the  fact  that  additional  data  are  still  required.  Specific  obligations,  including  obligations
relating to the timely and successful completion of ongoing or new studies and the collection of pharmacovigilance data, may
be specified in the conditional marketing authorization. Conditional marketing authorizations are valid for one year, and may
be  renewed  annually,  if  the  risk-benefit  balance  remains  positive,  and  after  an  assessment  of  the  need  for  additional  or
modified conditions. Although we have successfully renewed our conditional marketing authorization in the European Union
in the past, there can be no assurance that we will be able to continue to do so in the future. Failure to renew our conditional
marketing authorization would prevent us from continuing to market Ocaliva for PBC in Europe.

Our ongoing Phase 3 REGENERATE trial of OCA in patients with liver fibrosis due to NASH incorporates an interim
primary surrogate endpoint that may serve as the basis for accelerated approval in the United States and as the basis for a
conditional approval in Europe. Accelerated approval in the United States and conditional approval in the European Union
for OCA for liver fibrosis due to NASH are subject to similar risks as discussed above in relation to OCA for PBC. In the
REGENERATE primary efficacy analysis, once-daily OCA 25 mg met, with statistical significance, the primary endpoint

41

Table of Contents

agreed with the FDA of fibrosis improvement by at least one stage with no worsening of NASH (defined as no worsening of
hepatocellular  ballooning,  no  worsening  of  lobular  inflammation  and  no  worsening  of  steatosis)  at  the  planned  18-month
analysis. Although a numerically greater proportion of patients in both OCA treatment groups compared to placebo achieved
the primary endpoint of NASH resolution with no worsening of liver fibrosis in the primary efficacy analysis, this result did
not  reach  statistical  significance.  As  agreed  with  the  FDA,  in  order  for  the  primary  objective  to  be  met,  the  study  was
required  to  achieve  one  of  the  two  primary  endpoints.  In  November  2018,  the  EMA  issued  draft  regulatory  guidance  in
which it presented its preliminary views with respect to various NASH clinical development matters, including with respect
to  potential  surrogate  endpoints,  and  requested  comments  thereon  by  August  2019.  Although  we  did  not  reach  agreement
with  the  EMA  on  the  definition  and  analysis  of  a  surrogate  endpoint  prior  to  the  readout  of  the  18-month  analysis  of  the
REGENERATE  trial,  we  believe  that  the  totality  of  the  REGENERATE  interim  analysis  data  supports  the  MAA  we  filed
with  the  EMA.  However,  the  data  that  we  have  submitted  to  the  EMA  may  not  ultimately  be  found  by  the  EMA  to  be
sufficient  for  marketing  approval.  In  June  2019,  the  FDA  issued  new  draft  guidance  on  the  development  of  drugs  for  the
treatment of NASH patients with compensated cirrhosis. Although we believe that, if successful, our Phase 3 REVERSE trial
will support a regulatory submission seeking accelerated approval of OCA for liver fibrosis due to NASH with compensated
cirrhosis in the U.S., we do not know if achievement of the primary endpoint will ultimately be found sufficient by the FDA
for approval.

While  OCA  received  breakthrough  therapy  designation  from  the  FDA  in  January  2015  for  the  treatment  of  NASH
patients with liver fibrosis and we have filed a NDA in the United States and a MAA in Europe for approval of OCA for liver
fibrosis due to NASH based on the results from the 18-month interim analysis of our Phase 3 REGENERATE trial in patients
with liver fibrosis due to NASH, we do not know if one pivotal clinical trial will be sufficient for marketing approval or if
regulatory  authorities  in  the  United  States,  Europe  or  our  other  target  markets  will  approve  OCA  for  liver  fibrosis  due  to
NASH patients with liver fibrosis on an accelerated or conditional basis, or at all. In addition, although our NDA has been
accepted  by  the  FDA  for  review,  there  may  be  delays  in  the  FDA’s  review  process  or  the  FDA  may  determine  that  our
submission does not support the approval of OCA for the treatment of NASH. Similarly, there may be delays in the EMA’s
review process or the EMA may determine that our submission does not support the approval of OCA for the treatment of
NASH. Before granting approval, the FDA and/or the EMA may also require that we continue our Phase 3 REGENERATE
trial  until  completion  to  assess  the  potential  benefits  of  OCA  treatment  on  liver-related  and  other  clinical  outcomes.  Our
regulatory pathway for OCA for the treatment of NASH will depend upon our discussions with the FDA and the EMA. As a
result, we may face difficulty in establishing an acceptable registration strategy with respect to our Phase 3 REGENERATE
and REVERSE trials, as well as other trials we may conduct in other subpopulations of NASH patients.

If we continue the development of OCA for PSC, we may seek marketing approval based on a surrogate endpoint. While
the EMA issued draft regulatory guidance in November 2018, the FDA has not issued formal guidance regarding a validated
surrogate endpoint as a basis for seeking approval in PSC. Identifying an acceptable surrogate endpoint may take longer than
we  expect  and  any  surrogate  endpoint  we  select  may  ultimately  not  be  accepted  by  the  FDA,  EMA  or  other  applicable
regulatory authorities.

Prior to any approval of OCA for liver fibrosis due to NASH or OCA for PBC in jurisdictions in which it is not currently
approved  or  the  approval  of  our  other  product  candidates,  the  FDA,  EMA  or  other  applicable  regulatory  authorities  may
require  additional  preclinical  studies  and/or  clinical  trials,  which  may  be  expensive  and  time  consuming  to  conduct  and
complete.  Consequently,  any  such  requirement  that  we  conduct  additional  preclinical  studies  or  clinical  trials  could
materially and adversely affect our business, financial condition and results of operations. Furthermore, even if we receive
such approval, the relevant labeling may include restrictions, limitations and/or warnings that could impact the commercial
success of OCA or our other product candidates in the applicable markets.

Delays or difficulties in the commencement, enrollment and completion of our clinical trials and studies could increase
our product development costs and delay, limit or prevent us from obtaining regulatory approval for OCA and our other
product candidates.

Delays or difficulties in the commencement, enrollment and completion of our clinical trials and studies could increase
our product development costs and limit or prevent us from obtaining or maintaining regulatory approval for OCA and our
other product candidates. We are currently conducting a number of clinical trials, including our Phase 4 COBALT

42

Table of Contents

clinical  outcomes  confirmatory  trial  of  Ocaliva  for  PBC,  our  Phase  3  REGENERATE  trial  of  OCA  in  patients  with  liver
fibrosis due to NASH through clinical outcomes in order to confirm clinical benefit and our Phase 3 REVERSE trial of OCA
for NASH patients with compensated cirrhosis. We are also conducting our CARE trial of OCA in pediatric patients with
biliary atresia as a part of an EMA-approved PIP supporting the conditional approval of Ocaliva for PBC. The results from
these clinical trials and our other clinical trials and studies may not be available when we anticipate and we may be required
to conduct additional clinical trials or studies not currently planned in order for our product candidates, including OCA for
PBC and NASH, to be approved or to maintain approvals in the U.S., Europe or the other jurisdictions in which our products
are approved. In addition, our clinical programs are subject to a number of risks and uncertainties, such as the results of other
trials,  patient  enrollment,  safety  issues  or  regulatory  interactions  that  could  result  in  a  change  of  trial  design  or  timing.
Consequently, we do not know whether our current or future clinical trials or studies of OCA or our other product candidates
will begin or be completed on schedule, if at all.

The  commencement,  enrollment  and  completion  of  our  clinical  trials  and  studies  may  be  delayed,  suspended  or

otherwise adversely affected for a variety of reasons, including:

● our inability to obtain sufficient funds to complete or continue our clinical trials;

● our  inability  to  reach  agreements  on  acceptable  terms  with  prospective  contract  research  organizations
(“CROs”) and trial sites, the terms of which may be subject to extensive negotiation and may vary significantly
among our various CROs and trial sites;

● clinical holds, other regulatory objections to our commencing or continuing a clinical trial or our inability to

obtain regulatory approval to commence clinical trials in countries that require such approvals;

● our discussions with the FDA, EMA or other regulatory authorities prior to, or following, the initiation of our
clinical  trials,  regarding,  among  other  matters,  the  scope  or  design  of  our  clinical  trials,  including  trial
endpoints, protocols and statistical analysis plans, and any modifications thereto;

● our inability to identify and maintain a sufficient number of trial sites, many of which may already be engaged
in other clinical trial programs, including some that may be for the same indications targeted by our product
candidates;

● any delay in receiving results from, or failure to achieve the necessary results in, our clinical trials;

● our inability to obtain approval from institutional review boards or independent ethics committees to conduct

our clinical trials at their respective sites;

● any data monitoring committee recommendation that our clinical trials be modified, suspended or terminated

due to safety, lack of efficacy or other reasons;

● severe or unexpected drug-related adverse events experienced by patients or any determination that a clinical

trial presents unacceptable health risks;

● any  breach  of  the  terms  of  any  relevant  agreement  by  us,  our  current  or  future  collaborators  that  have
responsibility for the clinical development of any of our product candidates or investigators conducting clinical
trials on our product candidates;

● our  inability  to  timely  manufacture,  or  obtain  from  our  contract  manufacturers,  sufficient  quantities  of  our

product candidate required for our clinical trials; and

● any difficulty recruiting, enrolling or retaining patients in our clinical trials based on, among other factors, the
enrollment  criteria  for  our  clinical  trials,  the  rarity  of  the  disease,  the  characteristics  of  the  population  being
studied, the risks of the procedures that may be required as part of the clinical trials, such as a liver

43

Table of Contents

biopsy,  the  availability  of  our  products  to  patients  generally  following  the  approval  of  such  products  or
competition  from  other  clinical  trial  programs  recruiting  patients  for  the  same  indications  as  our  product
candidates.

For example, our Phase 3 REGENERATE trial is a large and complicated clinical trial in a disease without any approved
therapies and involves serial liver biopsies over many years. While we announced topline results from the 18-month analysis
of  our  pivotal  Phase  3  REGENERATE  trial  in  February  2019,  REGENERATE  is  planned  to  continue  through  clinical
outcomes in order to confirm clinical benefit and there can be no assurance that we will retain a sufficient number of patients
in the full study cohort or complete the clinical outcomes trial in accordance with the study protocol or on a timely basis, if at
all.  Similarly,  our  COBALT  clinical  outcomes  confirmatory  trial  for  PBC  includes  subjects  across  the  spectrum  of  PBC
disease, including early and advanced PBC, and there can be no assurance that we will enroll and retain a sufficient number
of patients in the full study or complete the clinical outcomes trial in accordance with the study protocol or on a timely basis,
if at all. As we engage in other large and complicated trials and trials in advanced disease populations, we may experience a
number of challenges that may negatively affect or delay our plans and development programs.

Additionally, we have in the past occasionally experienced difficulties enrolling and retaining patients enrolled in our
clinical trials. Difficulties in enrolling and retaining patients may delay our clinical trials or result in negative or inconclusive
outcomes, and we or our collaborators may decide, or regulatory authorities may require us, to conduct additional clinical
trials or additional analyses of existing clinical trials. Any delay or compromises with respect to the validity of our clinical
trials may have a material adverse effect on our business or decrease our competitive position relative to other biotechnology
or pharmaceutical companies with whom we compete.

In addition, if we or any of our collaborators are required to conduct additional preclinical or clinical studies or other
development  work  on  our  product  candidates  beyond  that  contemplated,  our  ability  to  obtain  regulatory  approval  of  these
product candidates and generate revenue from their sales would be similarly harmed.

Clinical  failure  can  occur  at  any  stage  of  clinical  development.  The  results  of  earlier  clinical  trials  are  not  necessarily
predictive of future results and any product candidate we or our collaborators advance through clinical trials, including
OCA, may not have favorable results in later clinical trials or receive or maintain regulatory approval.

Clinical  failure  can  occur  at  any  stage  of  clinical  development.  Clinical  trials  may  produce  negative  or  inconclusive
results,  and  we  or  our  collaborators  may  decide,  or  regulators  may  require  us,  to  conduct  additional  clinical  trials  or
preclinical studies. In addition, data obtained from trials and studies are susceptible to varying interpretations, and regulators
may  not  interpret  our  data  as  favorably  as  we  do,  which  may  delay,  limit  or  prevent  regulatory  approval.  Success  in
preclinical  studies  and  early  clinical  trials  does  not  ensure  that  subsequent  clinical  trials  will  generate  the  same  or  similar
results  or  otherwise  provide  adequate  data  to  demonstrate  the  efficacy  and  safety  of  our  product  candidates.  A  number  of
companies  in  the  pharmaceutical  industry,  including  those  with  greater  resources  and  experience  than  us,  have  suffered
significant setbacks in Phase 3 clinical trials and at other stages of clinical development, even after seeing promising results
in earlier clinical trials.

In addition, the design of clinical trials, including trial endpoints, protocols and statistical analysis plans, can determine
whether such trials will support product approvals, and flaws in the design of such trials may not become apparent until such
trials  are  well-advanced.  We  may  be  unable  to  design  and  execute  clinical  trials  to  support  regulatory  approval.  Further,
clinical trials of product candidates often reveal that it is not practical or feasible to continue development efforts. If OCA or
our  other  product  candidates  are  found  to  be  unsafe  or  lack  efficacy  for  any  indication,  we  will  not  be  able  to  obtain  or
maintain regulatory approval for them, and our prospects and business may be materially and adversely affected.

There may be significant variability in the safety and/or efficacy results we see in different trials studying OCA or our
other product candidates due to numerous factors, including differences in the underlying disease being studied, changes or
differences in trial protocols or statistical analysis plans, differences in the composition of the patient populations or clinical
trial sites, differences in adherence to the dosing regimen and other aspects of the trial protocols and differences in the rate of
dropouts among clinical trial participants. We do not know whether any Phase 2, Phase 3 or other clinical trials we or any of
our collaborators may conduct on our product candidates will demonstrate consistent or adequate

44

Table of Contents

efficacy and safety or result in the approval of our product candidates by regulatory authorities. If we are unable to bring any
of our current or future product candidates to market, acquire any previously approved products or maintain approval for our
approved products, our ability to create long-term stockholder value will be limited.

Although  Ocaliva  for  PBC  has  received  accelerated  approval  in  the  United  States  and  conditional  approval  in  the
European Union, its full approval depends on the timely completion and results of post-marketing clinical trials, including
our Phase 4 COBALT trial. We cannot assure you that these trials will demonstrate a correlation of the surrogate endpoint
therapeutic response in patients taking Ocaliva for PBC with a significant reduction in adverse clinical outcomes over time.

In  December  2014,  we  received  comprehensive  datasets  from  the  Phase  2b  FLINT  trial  for  the  treatment  of  NASH,
which met its primary endpoint with statistical significance. In October 2015, we announced that the Phase 2 dose ranging
trial of OCA in 200 adult NASH patients in Japan conducted by our former collaborator, Sumitomo Dainippon, did not meet
its primary endpoint with statistical significance. In the Sumitomo Dainippon trial, there was a dose dependent, although not
statistically significant, increase in the percentage of OCA-treated patients compared to placebo who achieved the primary
endpoint (p = 0.053). In addition, no difference was seen in fibrosis improvement in the OCA groups compared to placebo.
The Sumitomo Dainippon Phase 2 trial involved different doses of OCA being administered to the trial subjects than those
utilized in the Phase 2b FLINT trial. Furthermore, the baseline characteristics between the patients in the Japanese Phase 2
dose ranging trial conducted by Sumitomo Dainippon were distinct in a number of ways from those of the Western patients
included in the Phase 2b FLINT trial.

In February 2019, we announced topline results from the 18-month analysis of our pivotal Phase 3 REGENERATE trial
in  patients  with  liver  fibrosis  due  to  NASH.  In  the  primary  efficacy  analysis,  once-daily  OCA  25  mg  met,  with  statistical
significance, the primary endpoint agreed with the FDA of fibrosis improvement by at least one stage with no worsening of
NASH (defined as no worsening of hepatocellular ballooning, no worsening of lobular inflammation and no worsening of
steatosis)  at  the  planned  18-month  analysis.  Although  a  numerically  greater  proportion  of  patients  in  both  OCA  treatment
groups compared to placebo achieved the primary endpoint of NASH resolution with no worsening of liver fibrosis in the
primary efficacy analysis, this result did not reach statistical significance. As agreed with the FDA, in order for the primary
objective to be met, the study was required to achieve one of the two primary endpoints. While OCA received breakthrough
therapy designation from the FDA in January 2015 for the treatment of NASH patients with liver fibrosis and we have filed a
NDA in the United States and a MAA in Europe for approval of OCA for liver fibrosis due to NASH based on the results
from the 18-month analysis of our Phase 3 REGENERATE trial in patients with liver fibrosis due to NASH, we do not know
if one pivotal clinical trial will be sufficient for marketing approval or if regulatory authorities in the United States, Europe or
our other target markets will approve OCA for liver fibrosis due to NASH patients with liver fibrosis on an accelerated or
conditional  basis,  or  at  all.  Additionally,  interim  analysis  results  at  18  months  were  based  on  surrogate  endpoints  and  the
impact on clinical outcomes has not been confirmed. Our Phase 3 REGENERATE trial is ongoing through clinical outcomes
for verification and description of clinical benefit of OCA for liver fibrosis due to NASH.

Our product candidates may have undesirable side effects which may delay or prevent marketing approval, or, if approval
is  received,  require  that  our  products  be  taken  off  the  market  or  include  new  or  additional  safety  warnings.  Any  such
events  may  limit  our  existing  and  future  product  sales  and  materially  and  adversely  affect  our  business,  financial
condition and results of operations.

OCA  has  been  shown  to  be  a  potent  FXR  agonist.  With  the  exception  of  the  endogenous  human  bile  acid
chenodeoxycholic acid and cholic acid, there are no approved FXR agonists and the adverse effects from long-term exposure
to  this  drug  class  are  unknown.  Unforeseen  side  effects  from  any  of  our  product  candidates,  including  OCA,  could  arise
either  during  clinical  development  or,  if  approved,  after  the  approved  product  has  been  marketed.  Serious  adverse  events,
including  deaths,  in  patients  taking  OCA  have  occurred  in  clinical  trials  and  in  the  post-marketing  setting,  and  we  cannot
assure you that additional serious adverse events in patients taking OCA in clinical trials or in the post-marketing setting will
not occur.

The  most  common  side  effects  observed  in  clinical  trials  of  OCA  for  PBC  were  pruritus,  fatigue,  headaches,  nausea,

constipation and diarrhea. In our Phase 3 POISE trial, pruritus, generally mild to moderate, was the most frequently

45

Table of Contents

reported  adverse  event  associated  with  OCA  treatment  for  PBC  and  was  observed  in  38%  of  patients  on  placebo,  70%  of
patients  in  the  OCA  10  mg  group  and  56%  of  patients  in  the  OCA  titration  group  (5  mg  to  10  mg).  Eight  patients
discontinued due to pruritus, of whom none were in the placebo group, seven (10%) were in the OCA 10 mg group and one
(1%)  was  in  the  OCA  titration  group.  Pruritus  also  has  been  observed  in  other  clinical  trials  of  OCA.  Decreases  in  high
density lipoprotein HDL cholesterol were also observed during treatment in our Phase 3 POISE trial. In our Phase 2 trials for
OCA  for  PBC,  a  dose-response  relationship  was  observed  in  the  occurrence  of  liver-related  adverse  reactions,  including
jaundice, ascites and primary biliary cholangitis flare with dosages of OCA of 10 mg once daily to 50 mg once daily (up to 5-
times the highest recommended dosage), as early as one month after starting treatment with OCA. The European label for
Ocaliva  also  notes  that  elevations  in  alanine  amino  transferase  and  aspartate  aminotransferase  were  observed  in  patients
treated with OCA.

In  the  course  of  our  post-marketing  pharmacovigilance  activities,  deaths  have  been  reported  in  PBC  patients  with
moderate or severe hepatic impairment. In an analysis performed by us and in consultation with the FDA, we concluded that
certain  of  these  patients  were  prescribed  once  daily  doses  of  Ocaliva,  which  is  seven  times  higher  than  the  recommended
weekly dose in such patients. As a result, in September 2017, we issued a Dear Health Care Provider (“DHCP”) letter, and
the  FDA  also  subsequently  issued  its  own  drug  safety  communication  to  reinforce  recommended  label  dosing.  Both
communications  remind  healthcare  providers  of  the  importance  of  the  recommended  reduced  dosing  of  Ocaliva  in  PBC
patients  with  moderate  or  severe  hepatic  impairment,  while  reiterating  the  importance  of  monitoring  PBC  patients  for
progression  of  their  disease  and  the  occurrence  of  liver-related  adverse  reactions.  In  addition  to  the  DHCP  letter,  we  took
actions  to  enhance  education  about  appropriate  use  of  Ocaliva.  These  initiatives  included:  reeducating  physicians  on  the
label,  with  a  focus  on  ensuring  appropriate  dosing  for  patients  with  moderate  or  severe  hepatic  impairment;  enhancing
monitoring of patients for liver-related adverse reactions; and adjudicating reported cases of serious liver injury, including in
patients with no or mild hepatic impairment. In February 2018, we announced that the Ocaliva label in the United States had
been updated by the FDA to include a boxed warning and a dosing table that reinforced the then-existing dosing schedule for
patients  with  Child-Pugh  Class  B  or  C  or  decompensated  cirrhosis.  In  addition,  the  FDA  issued  an  updated  drug  safety
communication to accompany the revised label. We remain focused on the safety of all of the patients using Ocaliva within
and outside of our ongoing clinical studies and have engaged with relevant regulatory authorities to ensure that the Ocaliva
label sufficiently reinforces the importance of appropriate dosing in patients with advanced cirrhosis. These events and any
safety  concerns  associated  with  Ocaliva,  perceived  or  real,  may  adversely  affect  the  successful  development  and
commercialization of our product candidates and lead to a loss of revenues.

Ocaliva  is  contraindicated  for  PBC  patients  with  complete  biliary  obstruction  in  the  United  States  and  the  European
Union. For PBC patients with HDL reductions and no response to Ocaliva after one year at the maximum tolerated dose, the
U.S. label asks prescribing physicians to weigh the risks against the benefits of continuing treatment.

In the 18-month analysis of our pivotal Phase 3 REGENERATE trial in patients with liver fibrosis due to NASH, the
safety  population  included  1,968  randomized  patients  who  received  at  least  one  dose  of  investigational  product  (OCA  or
placebo) with exposures up to 37 months. Adverse events were generally mild to moderate in severity and the most common
were consistent with the known profile of OCA. The frequency of serious adverse events was similar across treatment groups
(11% in placebo, 11% in OCA 10 mg and 14% in OCA 25 mg), and no serious adverse event occurred in > 1% of patients in
any treatment group. There were 3 deaths in the study (2 in placebo: bone cancer and cardiac arrest and 1 in OCA 25 mg:
glioblastoma)  and  none  were  considered  related  to  treatment.  The  most  common  adverse  event  reported  was  dose-related
pruritus (19% in placebo, 28% in OCA 10 mg and 51% in OCA 25 mg). The incidence of pruritus across all three treatment
groups  was  highest  in  the  first  three  months  and  decreased  thereafter.  The  large  majority  of  pruritus  events  were  mild  to
moderate, with severe pruritus occurring in a small number of patients (< 1% in placebo, < 1% in OCA 10 mg and 5% in
OCA 25 mg). A higher incidence of pruritus-associated treatment discontinuation was observed for OCA 25 mg (< 1% in
placebo, < 1% in OCA 10 mg and 9% in OCA 25 mg). According to the clinical study protocol, investigator assessed severe
pruritus mandated treatment discontinuation. Consistent with observations from previous NASH studies, OCA treatment was
associated with an increase in low density lipoprotein (“LDL”) cholesterol, with a peak increase of 22.6 mg/dL at 4 weeks
and subsequently reversing and approaching baseline at month 18 (4.0 mg/dL increase from baseline). Triglycerides rapidly
and continually decreased in the OCA treatment groups through month 18. There were few and varied serious cardiovascular
events and incidence was balanced across the three treatment groups (2% in placebo, 1% in OCA 10 mg and 2% in OCA 25
mg). In patients with type 2 diabetes, OCA treatment was

46

Table of Contents

associated with an early transient increase in fasting glucose and hemoglobin A1c with return to levels similar to placebo by
month 6. No clinically meaningful changes were noted in non-diabetic patients.

With  respect  to  hepatobiliary  events,  more  patients  (3%)  on  OCA  25  mg  experienced  gallstones  or  cholecystitis
compared to < 1% on placebo and 1% on OCA 10 mg. While hepatic serious adverse events were rare (< 1% incidence in
each of the three treatment groups), more occurred in the OCA 25 mg group with no pattern attributable to OCA.

In the Phase 2b FLINT trial, pruritus occurred more frequently in the OCA treatment group than in the placebo treatment
group (23% vs. 6%, p < 0.0001) and at a higher grade (predominately moderate pruritus). OCA treatment was also associated
with  changes  in  serum  lipid  levels,  including  increases  in  total  cholesterol  and  LDL  cholesterol  and  a  decrease  in  HDL
cholesterol, that were observed within 12 weeks of initiating treatment, peaked and then decreased in magnitude while on
treatment, and reversed further during the 24-week post-treatment period. These changes in cholesterol levels, along with the
achievement of pre-defined efficacy criteria, played a role in the decision of the FLINT data and safety monitoring board to
terminate the treatment phase of the Phase 2b FLINT trial, and the publication of the FLINT results noted the need for further
study of these changes. There were two patient deaths in the Phase 2b FLINT trial, and neither death was considered related
to OCA treatment.

Furthermore,  the  Phase  2  dose  ranging  trial  of  OCA  in  200  adult  NASH  patients  in  Japan  conducted  by  our  former
collaborator, Sumitomo Dainippon, did not meet statistical significance for the primary endpoint. The primary endpoint in
the Sumitomo Dainippon trial was histologic improvement defined as at least a two-point improvement in the nonalcoholic
fatty  liver  disease  activity  score  with  no  worsening  of  fibrosis.  In  this  trial,  there  was  a  dose  dependent,  although  not
statistically significant, increase in the percentage of OCA-treated patients compared to placebo who achieved the primary
endpoint (p = 0.053). In addition, no difference was seen in fibrosis improvement in the OCA groups compared to placebo.

  In  December  2015,  we  initiated  a  Phase  2  clinical  trial,  known  as  the  CONTROL  trial,  to  characterize  the  lipid
metabolic  effects  of  OCA  and  cholesterol  management  effects  of  concomitant  statin  administration  in  NASH  patients.
CONTROL  enrolled  80  NASH  patients  who  were  naïve  to  statin  therapy  or  had  undergone  a  statin  washout  period.  The
study included a 16-week double-blind phase followed by an optional long-term safety extension (“LTSE”) phase of the trial.
OCA  treatment  in  the  absence  of  statin  therapy  over  the  first  four  weeks  resulted  in  an  increase  in  LDL  across  all  OCA
treatment groups, while the placebo group was relatively unchanged. Treatment with atorvastatin beginning at week four and
continuing through week 16 reversed OCA-related increases in LDL to below baseline levels in all OCA treatment groups.
Dose-dependent pruritus was the most common adverse event in patients treated with OCA, occurring in 5% of patients on
placebo, 5% of patients in the OCA 5 mg group, 10% of patients in the OCA 10 mg group and 55% of patients in the OCA
25 mg group. All adverse events were mild to moderate and two patients discontinued treatment in the OCA 25 mg group
due to pruritus. Over 95% of the patients completing the double-blind phase of CONTROL enrolled in the LTSE phase of the
trial.

During the LTSE phase of CONTROL, there was one patient death. This patient was a 64 year-old male with a history of
NASH  associated  liver  cirrhosis,  morbid  obesity  (BMI  >40)  and  type  2  diabetes.  At  baseline,  this  patient  had  blood  tests
consistent  with  impaired  liver  function  (e.g.,  low  LDL  and  low  platelets).  The  patient  was  randomized  to  placebo  for  the
double-blind phase of the study. Early in the double-blind phase, the patient had serum biochemistry changes consistent with
worsening hepatic impairment (e.g., albumin decline and bilirubin was increasing). Atorvastatin was started per protocol and
then stopped early due to the patient’s persistently low LDL levels. The patient later enrolled in the LTSE phase and began
receiving OCA 25 mg treatment. Over the following four months, the patient’s serum biochemistry remained consistent with
ongoing  hepatic  impairment.  Approximately  five  months  after  starting  the  LTSE  phase,  the  patient  developed  severe
protracted diarrhea, which resulted in weight loss of 30 pounds over the ensuing one-month period. Both an infectious cause
and  possible  inflammatory  bowel  disease  were  suspected,  and  the  patient  subsequently  was  started  on  broad  spectrum
antibiotics and steroid therapy. Due to the diarrhea, the principal investigator stopped treatment with OCA and discontinued
the patient from the study. Concurrently, the patient reported jaundice and was found to have significantly elevated serum
bilirubin  and  ALP,  while  other  liver  enzymes  remained  relatively  stable.  Over  the  ensuing  two-week  period,  various
diagnostic tests and procedures were performed (e.g., magnetic resonance cholangiopancreatography to investigate possible
gallstone  bile  duct  obstruction)  and  the  patient  continued  receiving  a  number  of  other  medications,  including  the  ongoing
course of steroid therapy. During this time, the patient continued to

47

Table of Contents

deteriorate  and  was  hospitalized  with  acute  renal  and  liver  failure,  complicated  by  severe  metabolic  acidosis.  The  patient
rapidly progressed to multi-organ system failure, sepsis and death.

The  principal  investigator  determined  that  the  events  leading  to  the  patient’s  death  were  unlikely  related  to  OCA.
Despite  the  numerous  confounding  factors  in  this  case,  given  the  contemporaneous  administration  of  OCA  during  the
patient’s  ongoing  deterioration,  we  determined  that  it  could  not  be  ruled  out  that  these  events  were  possibly  related  to
treatment. Subsequent to our determination, the independent data safety monitoring committee separately evaluated the case
and determined that the events leading to the patient’s death were unlikely related to OCA.

Additional or unforeseen side effects relating to OCA or any of our other product candidates could arise either during
clinical development or, if approved, after the approved product has been marketed. With the approval of Ocaliva for PBC in
the  United  States,  Europe  and  certain  of  our  other  target  markets,  OCA  is  currently  used  in  an  environment  that  is  less
rigorously controlled than in clinical studies. If new side effects are found, if known side effects are shown to be more severe
than  previously  observed  or  if  OCA  is  shown  to  have  other  unexpected  characteristics,  we  may  need  to  abandon  our
development of OCA for PBC, NASH and other potential indications. Furthermore, our commercial sales of Ocaliva for PBC
may be materially and adversely affected.

The range and potential severity of possible side effects from systemic therapies is significant. The results of our current
or future clinical trials may show that our product candidates, including OCA, cause undesirable or unacceptable side effects,
which could interrupt, delay or halt clinical trials, result in a delay of, or failure to obtain, marketing approval from the FDA
and other regulatory authorities, result in marketing approval from the FDA and other regulatory authorities with restrictive
label warnings or result in the withdrawal of previously granted marketing approvals.

In addition, our product candidates are being developed as potential treatments for severe, life threatening diseases and,
as a result, our trials will necessarily be conducted in patient populations that will be more prone than the general population
to  exhibit  certain  disease  states  or  adverse  events.  For  example,  our  Phase  3  REVERSE  trial  in  NASH  patients  with
compensated cirrhosis has expanded our NASH development program into a more advanced NASH patient population and
accordingly  imposes  certain  eligibility  requirements  for  uptitration,  as  well  as  certain  monitoring  requirements  thereafter.
Ocaliva is prescribed in patients suffering from various stages of PBC, which can be life threatening, and patients may suffer
from  other  concomitant  illnesses  that  may  increase  the  likelihood  of  certain  adverse  events.  It  may  be  difficult  to  discern
whether certain events or symptoms observed during our clinical trials or by patients using our approved products are related
to our product candidates or approved products or some other factor. As a result, we and our development programs may be
negatively  affected  even  if  such  events  or  symptoms  are  ultimately  determined  to  be  unlikely  related  to  our  product
candidates or approved products. We cannot assure you that additional or more severe adverse side effects related to OCA or
our other product candidates will not be observed in our clinical trials or in the commercial setting. If observed, such adverse
side  effects  could  delay  or  preclude  regulatory  approval  of  OCA,  limit  commercial  use  or  result  in  the  withdrawal  of
previously granted marketing approvals.

If we or others identify undesirable or unacceptable side effects caused by our product candidates or products:

● we may be required to modify, suspend or terminate our clinical trials;

● we  may  be  required  to  modify  or  include  additional  dosage  and  administration  instructions,  warnings  and
precautions, contraindications, boxed warnings, limitations, restrictions or other statements in the product label
for our approved products, or issue field alerts to physicians and pharmacies or implement other risk mitigation
programs;

● we may be required to conduct costly additional clinical trials;

● we may be subject to limitations on how we may promote our approved products;

● sales of our approved products may decrease significantly;

48

Table of Contents

● regulatory authorities may require us to take our approved products off the market;

● we may be subject to regulatory investigations, government enforcement actions, litigation or product liability

claims; and

● our products may become less competitive or our reputation may suffer.

Breakthrough therapy designation for OCA may not lead to faster development or regulatory processes or increase the
likelihood that the FDA will approve OCA for the treatment of NASH patients with fibrosis.

If  a  drug  is  intended  for  the  treatment  of  a  serious  or  life-threatening  condition  and  preliminary  clinical  evidence
indicates that the drug may demonstrate substantial improvement over existing therapies on one or more clinically significant
endpoints, such as substantial treatment effects observed early in clinical development, the FDA may grant a breakthrough
therapy designation. Breakthrough therapy designation is intended to facilitate the development, and expedite the review, of
such drugs, but the breakthrough therapy designation does not assure marketing approval by the FDA.

In  January  2015,  we  received  breakthrough  therapy  designation  for  OCA  for  the  treatment  of  NASH  patients  with
fibrosis.  However,  there  is  no  guarantee  that  the  receipt  of  breakthrough  therapy  designation  will  result  in  a  faster
development process, review or approval of OCA for liver fibrosis due to NASH or increase the likelihood that OCA will be
granted marketing approval for NASH patients with fibrosis. Similarly, any future breakthrough therapy designation relating
to any other potential indication of OCA or our other product candidates will neither guarantee a faster development process,
review  or  approval  nor  improve  the  likelihood  of  the  grant  of  marketing  approval  by  the  FDA  compared  to  conventional
FDA procedures. In addition, the FDA may withdraw any breakthrough therapy designation at any time. While we may seek
breakthrough therapy designation for one or more of our product candidates in the future, we can give no assurance that the
FDA will grant such status.

We  may  not  be  able  to  obtain  or,  if  approved,  maintain  orphan  drug  exclusivity  for  our  approved  products  or  product
candidates, which could cause our revenues to suffer.

Regulatory authorities in some jurisdictions, including the United States and Europe, may designate drugs and biologics
for relatively small patient populations as orphan drugs. Under the Orphan Drug Act, the FDA may designate a product as an
orphan drug if it is a drug or biologic intended to treat a rare disease or condition, which is generally defined as a patient
population of fewer than 200,000 individuals annually in the United States. OCA has received orphan drug designation in the
United States and the European Union for the treatment of PBC and PSC.

Generally,  if  a  product  with  an  orphan  drug  designation  subsequently  receives  the  first  marketing  approval  for  the
indication for which it has such designation, the product is entitled to a period of marketing exclusivity, which precludes the
FDA  or  the  EMA  from  approving  another  marketing  application  for  the  same  product  during  the  exclusivity  period.  The
applicable exclusivity period is seven years in the United States and ten years in Europe. Orphan drug exclusivity may be lost
if the FDA or EMA determines that the request for designation was materially defective or if the manufacturer is unable to
assure a sufficient quantity of the product to meet the needs of patients with the rare disease or condition. In addition, the
European exclusivity period can be reduced to six years if, at the end of the fifth year, it is established that the product no
longer meets the criteria for orphan drug designation because, for example, the product is sufficiently profitable not to justify
maintenance of market exclusivity.

Any failure to maintain orphan drug status may subject us to mandatory price discounts in Europe and result in the loss
of other benefits, such as tax exemptions for sales. As such, the loss of orphan drug status may have a negative effect on our
ability to successfully commercialize our products, earn revenues and achieve profitability.

Even if we obtain orphan drug exclusivity for a product, that exclusivity may not effectively protect the product from
competition because different products can be approved for the same condition. Even after an orphan drug is approved, the
FDA or EMA may subsequently approve another product for the same condition if the FDA or EMA concludes that the later
product is clinically superior (i.e., it is shown to be safer, more effective or makes a major contribution to patient

49

Table of Contents

care). Any inability to secure or maintain orphan drug status or the exclusivity benefits of this status could have a material
adverse impact on our ability to develop and commercialize our product candidates and approved products.

We rely entirely on third parties for the manufacture of our product requirements for our preclinical studies and clinical
trials, as well as our commercial supply of Ocaliva and, if approved, OCA for liver fibrosis due to NASH and our other
product  candidates,  and  also  depend  on  third-party  vendors  and  CROs  for  certain  of  our  clinical  trial  and  product
development activities. Our business could be harmed if our third-party manufacturers fail to provide us with sufficient
quantities of drug product, or fail to do so at acceptable quality levels or prices, or if our third-party vendors or CROs
assisting us with our clinical trials and product development activities fail to comply with their contractual commitments
or applicable regulatory obligations or if we lose our relationships with our third-party vendors and CROs.

We do not manufacture the pharmaceutical products that we sell or the product candidates that we are developing. We
rely on third-party contract manufacturers for all of our required raw materials, active pharmaceutical ingredient and finished
product for our commercial sales and for our existing and anticipated clinical trials and preclinical studies. Any inability by
our contract manufacturers to continue to provide services to us for any reason could adversely affect our commercialization
efforts and clinical development program, and we may be unable to identify, qualify and engage replacement suppliers on
terms that are favorable to us on a timely basis, if at all.

We currently have an agreement with PharmaZell GmbH for the manufacture and commercial supply of API for use in
Ocaliva and, if approved, OCA for liver fibrosis due to NASH, but expect to shift our longer-term API supply requirements
to other suppliers. While we have procured supplies of API for the commercialization of Ocaliva for PBC and, if approved,
OCA for liver fibrosis due to NASH that we believe will be sufficient to meet our requirements during the initial stages of
the NASH launch following the expected approval, we may not be able to procure sufficient supplies of API on an ongoing
basis. To address this concern, we have qualified an additional API supplier from which we may currently acquire API on a
purchase  order  basis  and  continue  to  engage  in  activities  intended  to  ensure  that  our  long-term  commercial  supply
requirements are satisfied. Despite these efforts, we may not be able to meet our long-term commercial supply requirements
of API for the manufacture of Ocaliva or, if approved, OCA for liver fibrosis due to NASH or other indications on acceptable
terms, or at all. We do not have agreements for long-term supplies of any of our product candidates other than OCA. We
currently obtain supplies and services relating to our other product candidates from our third-party contract manufacturers on
a purchase order basis.

The facilities used by any contract manufacturer to manufacture OCA or any of our other product candidates are subject
to  inspection  by  the  FDA  and  regulators  in  other  jurisdictions.  We  are  completely  dependent  on  these  third-party
manufacturers  for  compliance  with  the  requirements  of  U.S.  and  non-U.S.  regulators  for  the  manufacture  of  our  finished
products,  including  Ocaliva.  If  our  manufacturers  are  unable  to  meet  our  requirements  in  accordance  with  our  product
specifications  and  applicable  current  Good  Manufacturing  Practices  (“cGMP”)  requirements,  our  products  or  product
candidates will not be approved or, if already approved, may be subject to recall.

Reliance on third-party manufacturers entails risks to which we would not be subject if we manufactured our product

candidates and products ourselves, including:

● the  possibility  that  we  are  unable  to  enter  into  or  renew  our  manufacturing  agreements  with  third  parties  on

acceptable terms, or at all;

● the  possible  termination,  breach  or  non-performance  by  our  third-party  manufacturers  of  our  manufacturing

agreements based on factors beyond our control; and

● our inability to timely identify and qualify a replacement for any of our third-party manufacturers in the event
any  such  third-party  manufacturer  fails  to  meet  our  product  requirements  or  following  the  termination,
expiration or nonrenewal of our agreements with such third-party manufacturer.

Any of these factors could disrupt the supply of our product candidates or approved products, cause us to incur higher
costs,  delay  the  approval  of  our  product  candidates  or  prevent  or  disrupt  the  commercialization  of  our  approved  products.
Furthermore, if any of our product candidates, including OCA for liver fibrosis due to NASH, are approved and our

50

Table of Contents

contract manufacturers fail to deliver the required commercial quantities of API or finished product on a timely basis and at
commercially reasonable prices and we are unable to find one or more replacement manufacturers capable of production at a
substantially  equivalent  cost,  in  substantially  equivalent  volumes  and  quality  and  on  a  timely  basis,  we  would  likely  be
unable  to  meet  demand  for  such  product  candidate  following  its  approval  and  could  lose  potential  revenue.  It  may  take
several  years  to  establish  an  alternative  long-term  source  of  supply  and  to  have  any  such  new  source  approved  by  the
regulatory authorities that regulate our products in the United States, Europe and our other target markets.

We depend on third-party vendors and CROs for certain of our clinical trial and product development activities. If any of
these providers fail to comply with their contractual commitments or applicable regulatory obligations, our business could be
materially and adversely affected. In addition, if we are unable to maintain our relationship with any one or more of these
providers, we could experience a significant delay in both identifying another comparable provider and then contracting for
its services, which could materially and adversely affect our clinical trial and product development efforts. We may be unable
to retain an alternative provider on reasonable terms, or at all. Even if we locate an alternative provider, it is likely that such a
provider  will  need  additional  time  to  respond  to  our  needs  and  may  not  provide  the  same  type  or  level  of  services  as  the
original  provider.  Any  third-party  vendors  and  CROs  that  we  retain  are  subject  to  the  FDA’s  regulatory  requirements  and
similar foreign standards and we do not have control over compliance with these regulations by these providers. The FDA
and  other  regulatory  authorities  enforce  these  regulations  through  periodic  inspections  of  trial  sponsors,  principal
investigators  and  trial  sites.  If  these  regulations  are  not  adhered  to  by  these  providers,  or  if  such  providers  fail  to  timely
correct any non-compliance, the commercialization and development of our product candidates or approved products could
be delayed, which could materially and adversely harm our business and financial condition.

Even  though  we  have  received  conditional  approval  of  Ocaliva  for  PBC,  we  and  our  contract  manufacturers  are  still
subject to strict, ongoing regulatory requirements.

Even though we have received conditional approval of Ocaliva for the treatment of PBC in combination with UDCA in
adults  with  an  inadequate  response  to  UDCA  or  as  monotherapy  in  adults  unable  to  tolerate  UDCA,  we  and  our  contract
manufacturers  are  subject  to  ongoing  regulatory  requirements  relating  to,  among  other  things,  Ocaliva’s  manufacturing,
packaging, labeling and storage. In addition, we and our contract manufacturers and our contract manufacturers’ facilities are
required to comply with extensive FDA and EMA requirements and the requirements of other similar regulatory authorities,
including requirements that quality control and manufacturing procedures conform to current cGMPs. As such, we and our
contract manufacturers are subject to periodic cGMP inspections and other inspections and audits required by law or industry
standard  and  must  continue  to  expend  time,  money  and  effort  to  ensure  compliance  with  applicable  manufacturing,
production  and  quality  control  requirements.  We  are  also  required  to  report  certain  adverse  reactions  and  production
problems,  if  any,  to  the  FDA,  EMA  and  other  similar  regulatory  authorities  and  to  comply  with  certain  requirements
concerning advertising and promotion for our products. Promotional communications with respect to prescription drugs are
subject to a variety of legal and regulatory restrictions and generally must be consistent with the information in the product’s
approved label.

If  a  regulatory  authority  such  as  the  FDA  discovers  previously  unknown  problems  with  one  of  our  products,  such  as
adverse  events  of  unanticipated  severity  or  frequency  or  problems  with  the  facility  where  the  product  is  manufactured,  or
disagrees with the promotion, marketing or labeling of one of our products, it may impose restrictions on that product or us,
including requiring withdrawal of the product from the market. In addition, if we or our contract manufacturers, other third-
party vendors or collaborators fail to comply with applicable regulatory requirements, a regulatory agency may, among other
things:

● issue  Form  483  notices  or  Warning  Letters,  in  the  case  of  the  FDA,  or  similar  notices,  in  the  case  of  other

regulatory agencies;

● mandate  modifications  to  our  promotional  materials  or  require  us  to  provide  corrective  information  to

healthcare practitioners;

● require us or our collaborators to enter into a consent decree or permanent injunction, which may include the
imposition  of  various  fines,  reimbursements  for  inspection  costs,  required  due  dates  for  specific  actions  and
penalties for noncompliance;

51

Table of Contents

● recall our products;

● suspend any of our ongoing clinical studies;

● impose administrative, civil or criminal penalties;

● withdraw  regulatory  approval  or  require  changes  to  our  product  label,  including  the  inclusion  of  additional

warnings or changes to the approved indication;

● refuse  to  approve  pending  applications  or  supplements  to  approved  applications  filed  by  us  or  our

collaborators;

● impose  restrictions  on  our  operations  or  those  of  our  contract  manufacturers,  including  costly  new

manufacturing requirements; or

● seize or detain products.

We must comply with environmental, health and safety laws and regulations.

Our activities involve the controlled storage, use and disposal of hazardous materials. We are subject to federal, state,
city and local laws and regulations, in and outside the United States, governing the use, manufacture, storage, handling and
disposal of these hazardous materials. Although we believe that the safety procedures we use for handling and disposing of
these  materials  comply  with  the  standards  prescribed  by  applicable  laws  and  regulations,  we  cannot  eliminate  the  risk  of
accidental contamination or injury from these materials. In the event of an accident, regulatory authorities may curtail the use
of  these  materials  and  interrupt  our  business  operations.  We  do  not  currently  maintain  hazardous  materials  insurance
coverage.

Risks Related to the Commercialization of Our Products

Sales of Ocaliva may be adversely affected by safety and labeling changes required by the FDA.

In  the  course  of  our  post-marketing  pharmacovigilance  activities,  deaths  have  been  reported  in  PBC  patients  with
moderate or severe hepatic impairment. In an analysis performed by us and in consultation with the FDA, we concluded that
certain  of  these  patients  were  prescribed  once  daily  doses  of  Ocaliva,  which  is  seven  times  higher  than  the  recommended
weekly dose in such patients. As a result, in September 2017, we issued a DHCP letter and the FDA also subsequently issued
its  own  drug  safety  communication  to  reinforce  recommended  label  dosing.  Both  communications  remind  healthcare
providers of the importance of the recommended reduced dosing of Ocaliva in PBC patients with moderate or severe hepatic
impairment, while reiterating the importance of monitoring PBC patients for progression of their disease and the occurrence
of  liver-related  adverse  reactions.  In  February  2018,  we  announced  that  the  Ocaliva  label  in  the  United  States  had  been
updated  by  the  FDA  to  include  a  boxed  warning  and  a  dosing  table  that  reinforced  the  then-existing  dosing  schedule  for
patients  with  Child-Pugh  Class  B  or  C  or  decompensated  cirrhosis.  In  addition,  the  FDA  issued  an  updated  drug  safety
communication to accompany the revised label. We remain focused on the safety of all of the patients using Ocaliva within
and outside of our ongoing clinical studies and have engaged with relevant regulatory authorities to ensure that the Ocaliva
label  sufficiently  reinforces  the  importance  of  appropriate  dosing  in  patients  with  advanced  cirrhosis.  These  events,  the
revised  label,  any  future  label  changes  that  may  be  required  by  the  FDA  or  other  relevant  regulatory  authorities  and  any
safety  concerns  associated  with  Ocaliva,  perceived  or  real,  may  materially  and  adversely  affect  our  Ocaliva
commercialization efforts and, consequently, our financial condition and results of operations.

52

Table of Contents

We are subject to uncertainty relating to pricing and reimbursement. Failure to obtain or maintain adequate coverage,
pricing and reimbursement for Ocaliva for PBC, OCA for liver fibrosis due to NASH, if approved, or our other future
approved products, if any, could have a material adverse impact on our ability to commercialize such products.

The  availability  and  extent  of  coverage  and  reimbursement  from  governmental  and  private  healthcare  payors  for  our
products,  including  Ocaliva  for  PBC  and,  if  approved,  OCA  for  liver  fibrosis  due  to  NASH,  and  our  ability  to  obtain
adequate pricing for such products are key factors that will affect our future commercial prospects. Government authorities
and third-party payors, such as private health insurers and health maintenance organizations, decide which drugs they will
cover  and  establish  payment  levels.  Sales  of  our  products  depend  and  will  depend  substantially,  both  domestically  and
internationally, on the extent to which their cost will be paid by health maintenance, managed care, pharmacy benefit and
similar healthcare management organizations or reimbursed by government health administration authorities, private health
coverage  insurers  and  other  third-party  payors.  Accordingly,  the  coverage  and  reimbursement  decisions  of  such
governmental and private healthcare payors could reduce the demand for, or the price paid for, our products. If these payors
do  not  consider  our  products  to  be  cost-effective  alone,  or  relative  to  other  approved  therapies,  they  may  not  cover  our
products or, if they do, they may apply utilization management restrictions, high patient cost-sharing obligations, or restrict
the level of reimbursement.

Third-party  payors  are  increasingly  challenging  the  prices  charged  for  pharmaceuticals  products,  and  many  also  limit
reimbursement for newly-approved products and indications. Third-party payors often attempt to contain healthcare costs by
demanding price discounts or rebates and limiting both the types and variety of drugs that they will cover and the amounts
that they will pay for drugs. As a result, they may not provide adequate payment for our products. Similarly, the containment
of healthcare costs has become a priority for federal and state governments and the pricing of pharmaceutical products has
been a focus in this effort. The U.S. government, state legislatures and foreign governments have shown significant interest
in  implementing  cost-containment  programs,  including  price  controls,  restrictions  on  reimbursement  and  requirements  for
substitution of generic products. Adoption of price controls and cost-containment measures, and adoption of more restrictive
policies in jurisdictions with existing controls and measures, could adversely affect our ability to successfully commercialize
our  products.  In  addition,  we  may  be  required  to  conduct  post-marketing  studies  in  order  to  demonstrate  the  cost-
effectiveness  of  our  products  to  payors’  satisfaction.  Such  studies  might  require  us  to  commit  a  significant  amount  of
management’s time and our financial and other resources and our products might not ultimately be considered cost-effective.

We  do  not  know  if  Ocaliva  for  PBC  will  obtain  and  maintain  broad  acceptance  from  third-party  payors  in  the
jurisdictions in which it is, or may in the future be, approved. In addition, we do not know if OCA for liver fibrosis due to
NASH will obtain and maintain broad acceptance from third-party payors, if approved. The coverage determination process
is a time-consuming and costly process that requires us to provide scientific and clinical support for the use of Ocaliva for
PBC and, if approved, OCA for liver fibrosis due to NASH to each payor separately, with no assurance that coverage will be
obtained or maintained. The market for a drug depends significantly on access to third-party payors’ drug formularies, or lists
of medications for which third-party payors provide coverage and reimbursement. Third-party payors may refuse to include a
particular drug in their formularies or restrict patient access to a branded drug when a less costly generic equivalent or other
alternative is available, even if not approved for the indication for which the branded drug is approved. Due to there being no
uniform policy of coverage and reimbursement in the United States among commercial payors, coverage and reimbursement
for pharmaceutical products may differ significantly from payor to payor. If we are unable to obtain and maintain adequate
coverage from third-party payors, the adoption of Ocaliva for PBC and, if approved, OCA for liver fibrosis due to NASH by
physicians and patients may be limited. This in turn could affect our ability to successfully commercialize Ocaliva for PBC
and,  if  approved,  OCA  for  liver  fibrosis  due  to  NASH  and  have  a  material  adverse  impact  our  profitability,  results  of
operations, financial condition and future success.

We cannot be certain that we will be able to obtain and maintain adequate coverage, pricing and reimbursement for our
products,  including  Ocaliva  for  PBC,  OCA  for  liver  fibrosis  due  to  NASH,  if  approved,  or  our  other  future  approved
products, if any. If coverage or reimbursement is not available or is available on a limited basis, or if we are unable to obtain
and maintain adequate pricing, we may not be able to successfully commercialize Ocaliva for PBC, OCA for liver fibrosis
due to NASH, if approved, or our other future approved products, if any.

53

Table of Contents

Legislative healthcare reform may adversely affect our business.

In  the  United  States,  the  Medicare  Prescription  Drug,  Improvement,  and  Modernization  Act  of  2003  (the  “MMA”)
changed the way Medicare covers and pays for pharmaceutical products. The legislation established Medicare Part D, which
expanded Medicare coverage for outpatient prescription drug purchases by the elderly but provided authority for limiting the
number of drugs that will be covered in any therapeutic class. The MMA also introduced a new reimbursement methodology
based on average sales prices for physician-administered drugs. Any negotiated prices for our products covered by a Part D
prescription  drug  plan  will  likely  be  lower  than  the  prices  we  might  otherwise  obtain.  Moreover,  while  the  MMA  applies
only  to  drug  benefits  for  Medicare  beneficiaries,  private  payors  often  follow  Medicare  coverage  policy  and  payment
limitations in setting their own payment rates. Any reduction in payment that results from the MMA may result in a similar
reduction in payments from non-governmental payors.

In  March  2010,  the  Patient  Protection  and  Affordable  Care  Act,  as  amended  by  the  Health  Care  and  Education
Affordability  Reconciliation  Act  (collectively,  the  “ACA”),  became  law  in  the  United  States.  Among  other  things,  the
purpose of the ACA was to reduce the cost of healthcare and substantially change the way healthcare is financed by both
governmental and private insurers. The ACA requires discounts under the Medicare drug benefit program and increased the
rebates  paid  by  pharmaceutical  companies  on  drugs  covered  by  Medicaid.  The  ACA  also  imposes  an  annual  fee,  which
increases  each  year,  on  sales  by  branded  pharmaceutical  manufacturers.  Since  its  enactment,  there  have  been  a  number  of
judicial, executive and legislative challenges to the ACA, including recent tax legislation that removed the financial penalties
for people who do not carry health insurance and an Executive Order signed in October 2017 by President Trump directing
federal agencies to modify how the ACA is implemented. There is still uncertainty whether the ACA will undergo additional
revisions, and we cannot predict the impact of any future modifications. Further, in December 2018, a federal district court in
Texas ruled that the entire ACA was unconstitutional because it could not be considered an exercise of Congressional taxing
authority following the repeal of the individual mandate penalties. In December 2019, a federal court of appeals upheld the
district court's decision that the ACA individual mandate was unconstitutional absent financial penalties, but remanded the
case back to the district court to determine whether the remaining provisions of the ACA were nonetheless valid. We cannot
predict the outcome of this, or any other, litigation regarding the ACA or the impact it may have on our business.

Reimbursement in the European Union and many other territories must be negotiated on a country-by-country basis and
in many countries a product cannot be commercially launched until reimbursement is approved. The timing to complete the
negotiation  process  in  each  country  is  highly  uncertain.  Even  after  a  price  is  negotiated,  countries  frequently  request  or
require adjustments to the price and other concessions over time or require approvals regionally. Reimbursement agencies in
Europe  are  often  more  conservative  than  those  in  the  United  States  and  the  reimbursement  process  is  often  slower  since
reimbursement decisions are made on a country-by-country basis. Prices for drugs in Europe are generally lower than in the
United States and tend to decrease over time.

The United States and several other jurisdictions are considering, or have already enacted, a number of legislative and
regulatory proposals to change their healthcare systems in ways that could affect our ability to sell our products profitably.
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  to
healthcare.  In  the  United  States,  the  pharmaceutical  industry  has  been  a  particular  focus  of  these  efforts  and  has  been
significantly affected by major legislative initiatives. We expect to experience pricing pressures in connection with the sale of
Ocaliva and our other future approved products, if any, due to the trend toward managed healthcare, the increasing influence
of  health  maintenance  organizations  and  additional  legislative  proposals.  Pricing  pressures  recently  experienced  by  the
pharmaceutical  industry  may  be  further  exacerbated  by  legislative  and  policy  changes  considered  by  the  Trump
administration  and  the  United  States  Congress.  There  have  also  been  recent  state  legislative  efforts  to  address  drug  costs,
which have generally focused on increasing transparency around drug costs or limiting drug prices. We cannot predict the
success or impact of any such current or future federal or state legislative efforts.

54

Table of Contents

Ocaliva  and  our  other  future  approved  products,  if  any,  may  not  achieve  broad  market  acceptance  among  physicians,
patients and healthcare payors, and revenues generated from their sales may be limited as a result.

The  commercial  success  of  Ocaliva  for  PBC,  OCA  for  liver  fibrosis  due  to  NASH,  if  approved,  and  our  other  future
approved products, if any, will depend upon their acceptance among the medical community, including physicians, healthcare
payors and patients. In order for Ocaliva to be commercially successful for PBC, we need to demonstrate its utility as a cost-
effective  treatment  for  PBC  patients  who  have  an  inadequate  response  to  UDCA  or  who  are  unable  to  tolerate  UDCA.
Ocaliva also must be shown to be a safe and tolerable treatment in a commercial use setting as it is intended to be a lifetime
therapy for patients eligible for treatment. We cannot be certain that Ocaliva for PBC, OCA for liver fibrosis due to NASH, if
approved,  or  our  other  future  approved  products,  if  any,  will  achieve  an  adequate  level  of  acceptance  among  the  medical
community, including physicians, healthcare payors and patients.

The degree of market acceptance of our approved products depends on a number of factors, including:

● limitations,  warnings,  precautions,  boxed  warnings,  contraindications,  restrictions  or  other  statements

contained in the product label approved by the FDA, EMA or other relevant regulatory authorities;

● changes in the standard of care or availability of alternative therapies at similar or lower costs for the targeted

indications for any of our products, such as UDCA for the treatment of PBC;

● limitations in the approved indications for our products;

● demonstrated and perceived clinical safety and efficacy compared to competitive products;

● a lack of adverse side effects, including deaths and other serious adverse events;

● sales, marketing and distribution support;

● the availability of reimbursement from managed care plans and other third-party payors;

● the timing of the market introduction of competitive products;

● the degree of cost-effectiveness;

● availability of alternative therapies at similar or lower cost, including generic and over-the-counter products;

● the  extent  to  which  our  products  are  approved  for  inclusion  on  formularies  of  hospitals  and  managed  care

organizations;

● whether  and  to  what  extent  our  products  are  recommended  under  physician  treatment  guidelines  for  the

treatment of the indications for which we have received regulatory approval;

● adverse publicity concerning our products or favorable publicity concerning competitive products;

● the convenience and ease of administration of our products; and

● potential product liability claims.

In addition, the potential market opportunity for Ocaliva for PBC, OCA for liver fibrosis due to NASH, if approved, and
our  other  future  approved  products,  if  any,  is  difficult  to  precisely  estimate.  For  example,  our  estimates  of  the  potential
market opportunity for Ocaliva for PBC include a number of key assumptions related to prevalence rates, patients’ access to
healthcare,  diagnosis  rates  and  patients’  response  to  or  tolerance  of  Ocaliva,  which  are  based  on  available  literature  and
epidemiology research in PBC, our industry knowledge gained through market research and other methods, industry

55

Table of Contents

publications, third-party research reports and other surveys. While we believe that our internal assumptions are reasonable,
no  independent  source  has  verified  such  assumptions.  If  any  of  these  assumptions  prove  to  be  inaccurate,  then  the  actual
market  for  Ocaliva  for  PBC  could  be  smaller  than  our  estimates  of  our  potential  market  opportunity.  If  the  actual  market
opportunity for Ocaliva for PBC, OCA for liver fibrosis due to NASH, if approved, or our other future approved products, if
any, is smaller than we expect, our product revenue may be limited and our financial condition and results of operations may
be materially and adversely affected.

If Ocaliva for PBC, OCA for liver fibrosis due to NASH, if approved, or our other future approved products, if any, do
not  achieve  an  adequate  level  of  acceptance  among  the  medical  community,  including  physicians,  healthcare  payors  and
patients,  sufficient  revenue  may  not  be  generated  from  these  products  and  we  may  not  become  or  remain  profitable.  In
addition, our efforts to educate the medical community and third-party payors on the benefits of Ocaliva for PBC, OCA for
liver fibrosis due to NASH, if approved, and our other future approved products, if any, may require significant resources and
may never be successful.

We  have  limited  sales,  marketing  and  distribution  experience  and  we  will  need  to  continue  to  invest  in  significant
additional resources to develop those capabilities or enter into acceptable third-party sales and marketing arrangements.

We have limited sales, marketing and distribution experience as a commercial organization. Ocaliva is our first approved
product and the commercial launch of Ocaliva for PBC is our first product launch. We are commercializing Ocaliva for PBC
using  a  combination  of  our  internal  commercial  organization,  a  contract  sales  organization  and  third-party  distributors
depending on the jurisdiction. We are developing our commercialization strategy for OCA for liver fibrosis due to NASH, if
approved, and have not yet decided on our commercialization strategy for OCA for other indications or for our other product
candidates, in each case, if approved. To develop internal sales, distribution and marketing capabilities, we have invested and
expect to continue to invest significant additional amounts of financial and management resources.

Recruiting and training a commercial organization is expensive, time-consuming and could delay any product launch. If
the commercial launch of an approved product for which we recruit a sales force and establish marketing and distribution
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 could be lost if we cannot retain or reposition our sales
and marketing personnel.

For approved products where we decide to perform sales, marketing and distribution functions ourselves or through third

parties, we could face a number of additional risks, including:

● we or our third-party sales collaborators may not be able to attract and build, or retain, an effective marketing

or sales force;

● the  cost  of  securing  or  establishing  a  marketing  or  sales  force  may  exceed  the  revenues  generated  by  our

products; and

● our sales and marketing efforts may not be successful.

We may utilize the services of third-party collaborators in certain jurisdictions. We may have limited or no control over
the sales, marketing and distribution activities of these third parties, and our future revenues may depend heavily on their
success.

We  could  incur  significant  liability  if  it  is  determined  that  we  have  improperly  promoted  or  are  improperly  promoting
Ocaliva for PBC or any of our product candidates prior to their approval.

Physicians  are  permitted  to  prescribe  drug  products  for  uses  that  are  not  described  in  the  product’s  labeling  and  that
differ from those approved by the FDA or other applicable regulatory agencies. Off-label uses are common across medical
specialties. Although the FDA and other regulatory agencies do not regulate a physician’s choice of treatments, the FDA

56

Table of Contents

and  other  regulatory  agencies  do  restrict  communications  on  the  subject  of  off-label  use.  Companies  are  not  permitted  to
promote  drugs  in  a  manner  inconsistent  with  applicable  regulatory  guidance.  The  FDA,  the  U.S.  Department  of  Justice
(“DOJ”)  and  other  regulatory  and  enforcement  authorities  actively  enforce  laws  and  regulations  prohibiting  the  improper
promotion of approved products, as well as the promotion of products for which marketing approval has not been obtained.
A company that is found to have improperly promoted off-label uses will be subject to significant liability, including civil
and administrative remedies as well as criminal sanctions. A significant number of pharmaceutical companies have received
inquiries  or  been  the  subject  of  investigations  by  various  governmental  authorities  in  the  United  States  and  abroad.  Both
federal  and  state  governments  have  levied  large  civil  and  criminal  fines  against  companies  for  alleged  improper  off-label
promotion, as well as promotion that is determined to be false or misleading, even if related to approved indications.

While we have implemented a corporate compliance program based on what we believe are current best practices, we
cannot  provide  any  assurance  that  governmental  authorities,  including  the  DOJ,  SEC  or  FDA,  will  find  that  our  business
practices  comply  with  all  current  or  future  administrative  or  judicial  interpretations  of  potentially  applicable  laws  and
regulations.  In  addition,  government  and  regulatory  agencies  may  hold  us  responsible  for  any  actions  by  our  sales
representatives or sales organizations, including our contract sales organization, to the extent that they do not comply with
applicable  laws  and  regulations.  If  we  or  our  contract  sales  organization  fail  to  comply  with  any  of  these  laws  and
regulations,  we  could  be  subject  to  a  range  of  penalties,  including  the  issuance  of  an  untitled  letter,  a  warning  letter,
injunction, seizure, criminal and significant civil penalties, fines, damages, disgorgement, curtailment or restructuring of our
operations, exclusion, disqualification or debarment from participation in federally- or state-funded healthcare programs or
other  sanctions  or  litigation,  any  of  which  could  have  a  material  adverse  impact  on  our  business,  financial  condition  and
results of operations.

If  we  market  products  in  a  manner  that  violates  healthcare  fraud  and  abuse  laws,  or  if  we  violate  government  price
reporting or physician payment disclosure laws, we may be subject to civil or criminal penalties.

In  addition  to  FDA  restrictions  on  the  marketing  of  pharmaceutical  products,  several  other  types  of  state  and  federal
healthcare  laws,  commonly  referred  to  as  “fraud  and  abuse”  laws,  have  been  applied  in  recent  years  to  restrict  certain
marketing practices in the pharmaceutical industry. Other jurisdictions including Europe have similar laws and are enacting
more  stringent  regulations.  These  laws  include  false  claims  and  anti-kickback  statutes.  If  we  market  our  products  and  our
products  are  paid  for  by  governmental  programs,  it  is  possible  that  some  of  our  business  activities  could  be  subject  to
challenge under one or more of these laws.

Federal  false  claims  laws  generally  prohibit  anyone  from  knowingly  and  willingly  presenting,  or  causing  to  be
presented, any claims for the payment for goods (including drugs) or services to third-party payers (including Medicare and
Medicaid) that are false or fraudulent. The federal civil monetary penalties statute, likewise, 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.

The  federal  healthcare  program  anti-kickback  statute  prohibits,  among  other  things,  knowingly  and  willfully  offering,
paying,  soliciting  or  receiving  remuneration  to  generate  business,  including  the  purchase  or  prescription  of  a  particular
product covered by Medicare, Medicaid or other federally financed healthcare programs. This statute has been interpreted to
apply  to  arrangements  between  pharmaceutical  manufacturers  on  the  one  hand  and  prescribers,  purchasers  or  formulary
managers  on  the  other.  Although  there  are  several  statutory  exemptions  and  regulatory  safe  harbors  protecting  certain
common  activities  from  prosecution,  the  exemptions  and  safe  harbors  are  drawn  narrowly,  and  practices  that  involve
remuneration intended to induce prescribing, purchasing or recommending may be subject to scrutiny if they do not qualify
for an exemption or safe harbor. In addition, such exemptions and safe harbors are subject to change from time to time.

The Health Insurance Portability and Accountability Act of 1996 (as amended by the Health Information Technology for
Economic and Clinical Health Act, “HIPAA”) created additional federal criminal statutes that prohibit, among other things,
knowingly and willfully executing, or attempting to execute, a scheme to defraud any healthcare benefit program, or obtain,
by  means  of  false  or  fraudulent  pretenses,  or  promises,  any  of  the  money  or  property  owned  by,  or  under  the  custody  or
control  of,  any  healthcare  benefit  program,  regardless  of  the  payor  (e.g.,  public  or  private)  and  knowingly  and  willfully
falsifying, concealing or covering up by any trick or device a material fact or making any materially false

57

Table of Contents

statement,  in  connection  with  the  delivery  of,  or  payment  for,  healthcare  benefits,  items  or  services.  HIPAA  also  imposes
significant requirements on the receipt and transfer of protected health information.

In  addition,  the  federal  transparency  requirements  under  the  Physician  Payments  Sunshine  Act  require  certain
manufacturers of drugs, including us, for which payment is available under certain federal healthcare programs annually to
report  information  related  to  payments  and  other  transfers  of  value  to  physicians  and  teaching  hospitals,  and  physician
ownership and investment interests.

Finally, we must offer discounted pricing or rebates on Ocaliva and our future approved products, if any, under various
federal  and  state  healthcare  programs,  and  report  specific  prices  to  government  agencies  under  healthcare  programs.  The
calculations necessary to determine the prices reported are complex and the failure to report prices accurately may expose us
to significant penalties.

There  are  foreign  and  state  law  equivalents  of  these  laws  and  regulations,  such  as  anti-kickback,  false  claims,
transparency and data privacy and security laws, to which we are currently and/or may in the future be subject. We may also
be subject to foreign and state laws that require manufacturers to report information related to payments and other transfers
of value to physicians and other healthcare providers or marketing expenditures. Many of these laws differ from each other in
significant ways, thus increasing the cost and complexity of our compliance efforts.

A  number  of  pharmaceutical  and  other  healthcare  companies  have  been  prosecuted  under  these  laws  for  a  variety  of
promotional and marketing activities, including providing free trips, free goods, sham consulting fees and grants and other
monetary benefits to prescribers; reporting inflated average wholesale prices that were then used by federal programs to set
reimbursement  rates;  engaging  in  improper  promotional  activities;  and  submitting  inflated  best  price  information  to  the
Medicaid Rebate Program to reduce liability for Medicaid rebates.

If  we  or  our  operations  are  found  to  be  in  violation  of  any  of  the  laws  described  above  or  any  other  governmental
regulations that apply to us, we may be subject to penalties, including criminal and significant civil penalties, damages, fines,
imprisonment, exclusion of products from reimbursement under United States federal or state healthcare programs, and the
curtailment or restructuring of our operations. Any penalties, damages, fines, curtailment or restructuring of our operations
could  materially  and  adversely  affect  our  ability  to  operate  our  business  and  our  financial  results.  Although  compliance
programs  can  mitigate  the  risk  of  investigation  and  prosecution  for  violations  of  these  laws,  the  risks  cannot  be  entirely
eliminated.  Any  action  against  us  for  violation  of  these  laws,  even  if  we  successfully  defend  against  it,  could  cause  us  to
incur  significant  legal  expenses  and  divert  our  management’s  attention  from  the  operation  of  our  business.  Moreover,
achieving and sustaining compliance with these laws may prove costly.

We  may  not  be  successful  in  establishing,  implementing  and  maintaining  development  and  commercialization
collaborations,  which  could  adversely  affect  our  ability  to  develop  certain  of  our  product  candidates  and  our  financial
condition  and  operating  results.  If  any  strategic  collaborator  fails  to  perform  its  obligations  under,  or  terminates,  its
agreement with us, our business could be substantially harmed.

Developing pharmaceutical products, conducting clinical trials, obtaining regulatory approval, expanding manufacturing
capabilities  and  marketing  approved  products  are  expensive,  complex  and  time-consuming  undertakings.  As  a  result,  we
have in the past entered into, and may in the future seek to enter into, collaborations with third parties upon whom we may
rely for financial resources and for development, regulatory and commercialization expertise for selected products or product
candidates  and  in  selected  jurisdictions.  We  may  establish  collaborations  with  respect  to  the  development  and
commercialization  of  OCA  in  various  jurisdictions  and  for  our  other  product  candidates.  Additionally,  we  may  enter  into
sales and marketing arrangements with third parties with respect to our approved products in all or certain jurisdictions.

Our collaborators may fail to develop our product candidates or effectively commercialize our products for a variety of
reasons, including a lack of sufficient resources, a decision not to devote the necessary resources due to internal constraints,
such as limited cash or human resources, a change in strategic focus or a failure to obtain the necessary regulatory approvals.

58

Table of Contents

If we are unable to enter into new arrangements or maintain such arrangements on acceptable terms, or at all, we may be
unable to effectively market and sell our products in certain of our target markets. We expect to face competition in seeking
appropriate collaborators. Moreover, collaboration and similar arrangements are complex and time consuming to negotiate,
document and implement and they may require substantial resources to maintain. We may not be successful in our efforts to
establish  and  implement  collaborations  or  other  alternative  arrangements  for  the  development  of  our  product  candidates.
When we collaborate with a third party for development and commercialization of a product candidate or approved product,
we expect to relinquish some or all of the control over the future success of that product candidate or approved product to the
third  party.  Our  collaboration  partner  may  not  devote  sufficient  resources  to  development  or  commercialization  or  may
otherwise  fail  in  their  development  or  commercialization.  The  terms  of  any  collaboration  or  other  arrangement  that  we
establish may not be favorable to us. In addition, any collaboration that we enter into may be unsuccessful. In some cases, we
may be responsible for continuing preclinical and initial clinical development of a partnered product candidate or research
program,  and  the  payment  we  receive  from  our  collaboration  partner  may  be  insufficient  to  cover  the  cost  of  this
development. If we are unable to reach agreements with suitable collaborators, we may incur increased costs and we may be
forced to limit the number of products or product candidates we can commercially develop or the territories in which we can
commercialize them. If we fail to achieve successful collaborations, our operating results and financial condition could be
materially and adversely affected.

If we fail to develop OCA for additional indications such as NASH, our commercial opportunity will be limited.

To date, we have focused the majority of our development efforts on the development of OCA. One of our strategies is
to pursue clinical development of OCA for liver fibrosis due to NASH and other progressive non-viral liver diseases, to the
extent that we have sufficient funding to do so.

PBC is an orphan disease and the potential market size for Ocaliva for PBC is relatively limited. Furthermore, because a
significant proportion of PBC patients do not exhibit any symptoms at the time of diagnosis, PBC may be left undiagnosed
for a significant period of time. Due to these factors, our ability to grow revenues will be dependent on our ability to increase
market share and successfully develop and commercialize OCA for the treatment of additional indications. In particular, we
believe  that  our  future  success  will  depend  in  large  part  on  the  results  of  our  development  of  OCA  for  the  treatment  of
NASH. Although NASH is believed to be one of the most prevalent chronic liver diseases worldwide, NASH may be left
undiagnosed  in  patients  for  a  long  period  of  time  and  a  definitive  diagnosis  of  NASH  is  often  based  on  a  histological
assessment of a liver biopsy, which impacts the ability to easily identify patients. Furthermore, even if we are successful in
developing and obtaining marketing approval of OCA for the treatment of NASH, we may not be commercially successful.

The completion of development, securing of approval and commercialization of OCA for additional indications such as
liver  fibrosis  due  to  NASH  will  require  substantial  additional  funding,  is  subject  to  numerous  risks  and  we  may  not  be
successful.  We  cannot  provide  you  any  assurance  that  we  will  be  able  to  successfully  advance  any  of  these  indications
through the development process. Even if we receive regulatory approval to market OCA for the treatment of liver fibrosis
due  to  NASH  or  any  other  additional  indications,  we  cannot  assure  you  that  any  such  additional  indications  will  be
successfully  commercialized,  widely  accepted  in  the  marketplace  or  more  effective  than  other  commercially  available
alternatives.  If  we  are  unable  to  successfully  develop  and  commercialize  OCA  for  liver  fibrosis  due  to  NASH  or  other
additional indications, our commercial opportunity will be limited and our business prospects will suffer.

Risks Related to Our Business and Strategy

We depend on third-party contractors for a substantial portion of our operations and may not be able to control their work
as effectively as if we performed these functions ourselves.

We outsource and plan to continue to outsource substantial portions of our operations to third-party service providers,
including CROs for certain of our clinical trial and product development activities, contract manufacturers for the production
of API and finished drug product for our commercial sales and for our clinical trials and preclinical studies and a contract
sales organization for the commercialization of Ocaliva in certain jurisdictions. We will likely also use the services of third-
party vendors in connection with our future commercialization activities, including product sales, marketing and distribution.
Our agreements with third-party service providers are typically on a study-by-study and/or

59

Table of Contents

project-by-project  basis.  Typically,  we  may  terminate  these  agreements  with  notice  and  are  responsible  for  the  supplier’s
previously incurred costs. In addition, a number of third-party service providers that we retain will be subject to the FDA’s
and  EMA’s  regulatory  requirements  and  similar  standards  outside  of  the  United  States  and  Europe  and  we  do  not  have
control over compliance with these regulations by these providers. If these providers do not adhere to applicable governing
practices and standards, the commercialization of Ocaliva and our other approved products, if any, and the development of
OCA and our other product candidates could be delayed or stopped, which could severely harm our business and financial
condition.

Because we have relied on third parties, our internal capacity to perform these functions is limited. Outsourcing these
functions involves the risk that third parties may not perform to our standards, may not produce results in a timely manner or
may  fail  to  perform  at  all.  In  addition,  the  use  of  third-party  service  providers  requires  us  to  disclose  our  proprietary
information to these parties, which could increase the risk that this information will be misappropriated. There are a limited
number  of  third-party  service  providers  that  have  the  specialized  expertise  required  to  achieve  our  business  objectives.
Identifying, qualifying and managing the performance of third-party service providers can be difficult, time-consuming and
cause delays in our development programs. Despite our growth, we have limited internal resources available to identify and
monitor  third-party  service  providers.  To  the  extent  we  are  unable  to  identify,  retain  and  successfully  manage  the
performance  of  third-party  service  providers,  our  business  may  be  materially  and  adversely  affected.  We  may  further  be
subject to the imposition of civil or criminal penalties if their conduct violates applicable law.

Our third-party service providers generally are not prohibited from providing their services to other biopharmaceutical
companies, including companies that currently or may in the future compete with us. For example, certain of our third-party
service  providers  and  consultants  may  be  able  to  develop  intellectual  property  to  which  we  do  not  have  rights  under  our
agreements  and  that  may  eventually  be  used  to  develop  products  that  compete  with  our  products.  Although  we  generally
have confidentiality and non-disclosure agreements in place with our third-party service providers and consultants, such third
parties  may  be  able  to  provide  services  to  other  companies  without  violating  the  terms  of  our  agreements.  In  addition,
although we may seek to enter into non-compete arrangements with our key third-party service providers, such arrangements
are difficult to negotiate and we may be unable to successfully enter into or enforce such arrangements.

We  face  rapid  technological  change  and  competition  from  other  biotechnology  and  pharmaceutical  companies.  Our
operating results will suffer if we fail to compete effectively.

The  biotechnology  and  pharmaceutical  industries  are  intensely  competitive  and  subject  to  rapid  and  significant
technological  change.  We  have  competitors  in  the  United  States,  Europe  and  other  jurisdictions,  including  major
multinational  pharmaceutical  companies,  established  biotechnology  companies,  specialty  pharmaceutical  and  generic  drug
companies  and  universities  and  other  research  institutions.  Many  of  our  competitors  have  financial,  sales  and  marketing,
manufacturing and distribution, legal, regulatory and product development resources substantially greater than ours. Large
pharmaceutical  companies,  in  particular,  have  extensive  experience  in  research,  clinical  testing,  obtaining  regulatory
approvals, recruiting patients and manufacturing pharmaceutical products. These companies also have significantly greater
sales and marketing capabilities and often have collaborative arrangements in our target markets. Established pharmaceutical
companies  may  also  invest  heavily  to  accelerate  discovery  and  development  of  novel  compounds  or  to  in-license  novel
compounds that could make our products or product candidates obsolete. As a result of all of these factors, our competitors
may succeed in obtaining patent protection and/or FDA, EMA or other regulatory approval or discovering, developing and
commercializing drugs for the diseases that we are targeting before we do. Smaller or early-stage companies may also prove
to be significant competitors, particularly through collaborative arrangements with large, established companies.

Some  of  the  pharmaceutical  and  biotechnology  companies  that  we  may  compete  with  include  3-V  Biosciences,  Inc.,
89bio, Inc., Allergan plc, Acorda Therapeutics, Inc., Affimune Limited, Akcea Therapeutics, Inc., Akero Therapeutics, Inc.,
Arrowhead Pharmaceuticals, Inc., AstraZeneca plc, Boehringer Ingelheim GmbH, Bristol-Myers Squibb Company, Can-Fite
BioPharma  Ltd.,  Celgene  Corporation,  Cirius  Therapeutics,  Inc.,  Corcept  Therapeutics  Incorporated,  Dr.  Falk  Pharma
GmbH,  Durect  Corporation,  Eli  Lilly  and  Company,  Enanta  Pharmaceuticals,  Inc.,  Forma  Therapeutics,  Inc.  Galectin
Therapeutics  Inc.,  Galecto  Biotech  AB,  Galmed  Pharmaceuticals  Ltd.,  Genfit  SA,  Genkyotex,  Gilead  Sciences,  Inc.,
GlaxoSmithKline plc, GRI Bio, Inc., Hanmi Pharmaceutical Co., Ltd., HighTide Therapeutics Inc., Immuron Limited,

60

Table of Contents

Inventiva,  Ionis  Pharmaceuticals,  Inc.,  Kowa  Company,  Ltd.,  Lipocine  Inc.,  Madrigal  Pharmaceuticals,  Inc.,  MediciNova,
Inc.,  Metacrine,  Inc.,  Mitsubishi  Tanabe  Pharma  Corporation,  Nash  Pharmaceuticals  Inc.,  NGM  Biopharmaceuticals,  Inc.,
Novartis  AG,  Novo  Nordisk  A/S,  NuSirt  Biopharma,  Inc.,  Oramed  Pharmaceuticals  Inc.,  Pfizer  Inc.,  Poxel  SA,  Second
Genome,  Inc.,  Sinew  Pharma  Inc.,  Theratechnologies,  Inc.,  Viking  Therapeutics,  Inc.,  Yagrit  International  Ltd  and  Zydus
Pharmaceuticals (USA) Inc. Ocaliva competes with UDCA (or ursodiol), a first-line therapy approved for the treatment of
PBC  that  is  available  generically  at  a  significantly  lower  cost  than  Ocaliva.  Although  we  have  a  license  to  develop  and
commercialize  bezafibrate  in  the  United  States,  bezafibrate  has  been  studied  in  multiple  clinical  trials  for  the  treatment  of
liver  diseases  including  PBC  and  NASH  outside  of  the  United  States.  Genfit  SA  has  an  ongoing  Phase  3  clinical  trial  of
elafibranor, a dual PPAR alpha/delta agonist, in NASH. Genfit is also studying elafibranor for the treatment of PBC. Gilead
Sciences,  Inc.  is  studying  firsocostat,  a  small  molecule  allosteric  inhibitor  that  acts  at  the  protein-protein  homodimer
interface of acetyl-CoA carboxylases and cilofexor, an FXR agonist, in NASH patients. Gilead Sciences, Inc. is also studying
a  number  of  compounds  in  other  liver  diseases  including  PBC.  Allergan  plc  has  an  ongoing  Phase  3  clinical  trial  of
cenicriviroc, a dual CCR2 and CCR5 inhibitor, for the treatment of NASH.

In addition, many universities and private and public research institutions may become active in our target disease areas.
The  results  from  our  clinical  trials  and  the  approval  of  Ocaliva  for  PBC  have  brought  more  attention  to  our  targeted
indications and bile acid chemistry. As a result, we believe that additional companies and organizations may seek to compete
with us in the future. Our competitors may succeed in developing, acquiring or licensing on an exclusive basis, technologies
and  drug  products  that  are  more  effective  or  less  costly  than  OCA  or  any  other  product  candidates  that  we  are  currently
developing or that we may develop, which could render our products or product candidates obsolete and noncompetitive. Our
ability to compete may also be affected because, in many cases, insurers or other third-party payors seek to encourage the use
of generic products.

Off-label uses of other potential treatments may limit the commercial potential of our products and product candidates,
especially given the pricing of Ocaliva and the anticipated pricing for our product candidates. For example, while fibrates are
not approved for use in PBC, off-label use of fibrate drugs has been reported. In NASH, a number of treatments, including
vitamin E (an antioxidant), insulin sensitizers (e.g., metformin, pioglitazone), antihyperlipidemic agents (e.g., gemfibrozil),
pentoxifylline and UDCA, are used off-label. Although none of these treatments have been clearly shown in clinical trials to
alter  the  course  of  the  disease,  in  a  previous  study  conducted  by  the  NASH  Clinical  Research  Network,  improvements  in
certain histological measures of NASH were reported with vitamin E and pioglitazone.

We believe that our ability to successfully compete will depend on, among other things:

● the results of our and our strategic collaborators’ clinical trials and preclinical studies;

● our ability to recruit, enroll and retain patients for our clinical trials;

● the efficacy, safety and tolerability of Ocaliva, OCA for liver fibrosis due to NASH, if approved, and our other

future approved products, if any;

● the speed at which we develop our product candidates;

● our ability to design and successfully execute appropriate clinical trials;

● our ability to maintain productive relationships with regulatory authorities;

● the timing and scope of regulatory approvals, if any;

● our ability to commercialize and market Ocaliva, OCA for liver fibrosis due to NASH, if approved, and our

other future approved products, if any;

● the price of our products;

61

Table of Contents

● our ability to obtain adequate levels of reimbursement under private and governmental health insurance plans,

including Medicare;

● our ability to protect our intellectual property rights related to our products;

● our ability to manufacture and sell commercial quantities of Ocaliva, OCA for liver fibrosis due to NASH, if

approved, and our other future approved products, if any, to the market; and

● the acceptance of our products by physicians and other healthcare providers.

If our competitors market products that are more effective or safe or less expensive than our products or that reach the
market  sooner  than  our  products,  we  may  not  achieve  commercial  success.  In  addition,  the  biopharmaceutical  industry  is
characterized by rapid technological change. Because our research approach integrates many technologies, it may be difficult
for us to stay abreast of the rapid changes in other technologies. If we fail to stay at the forefront of technological change, we
may  be  unable  to  compete  effectively.  Technological  advances  or  products  developed  by  our  competitors  may  render  our
technologies, products or product candidates obsolete, less competitive or not economical.

A  variety  of  risks  associated  with  our  international  business  operations  and  our  planned  international  business
relationships could materially and adversely affect our business.

We  have  formed  a  number  of  subsidiaries  in  jurisdictions  outside  of  the  United  States  in  connection  with  or  in
anticipation of our commercial or other business activities in those jurisdictions. We are commercializing Ocaliva for PBC
using  a  combination  of  our  internal  commercial  organization,  a  contract  sales  organization  and  third-party  distributors
depending on the jurisdiction. Our international operations and business relationships subject us to additional risks that may
materially and adversely affect our business and ability to attain or sustain profitability, including:

● the far-reaching anti-bribery and anti-corruption legislation in the United Kingdom, including the U.K. Bribery

Act, and elsewhere and escalation of investigations and prosecutions pursuant to such laws;

● compliance with complex import and export control laws;

● restrictions on direct investments by foreign entities and trade restrictions;

● differing  regulatory  requirements  for  drug  approvals  internationally  and  the  inability  to  obtain  necessary

foreign regulatory, pricing or reimbursement approvals for our products in a timely manner, or at all;

● uncertainty regarding the collectability of accounts receivable;

● difficulties in staffing and managing international operations;

● potentially reduced protection for our intellectual property rights;

● potential third-party patent rights in countries outside of the United States;

● the potential for so-called “parallel importing,” which is what occurs when a local seller opts to import goods

from another jurisdiction with relatively low prices, rather than buying them locally;

● unexpected changes in tariffs, trade barriers and regulatory requirements and the imposition of governmental

controls;

● economic  weakness,  including  inflation,  or  political  instability,  particularly  in  non-U.S.  economies  and

markets, including countries in Europe;

62

Table of Contents

● compliance  with  tax,  employment,  immigration  and  labor  laws  applicable  to  our  employees  working  or

traveling abroad;

● taxes in other countries;

● foreign  currency  fluctuations,  which  could  result  in  increased  operating  expenses  and  reduced  revenue,  and

other transactional risks incident to doing business in foreign countries;

● workforce uncertainty in countries where labor unrest is more common than in the United States;

● production shortages resulting from events affecting raw material supply or manufacturing capabilities abroad;

● business  interruptions  resulting  from  geo-political  actions,  including  war  and  terrorism,  global  health
emergencies,  such  as  the  recent  coronavirus  outbreak,  or  natural  disasters,  including  earthquakes,  volcanoes,
typhoons, floods, hurricanes and fires; and

● increasingly complex standards for complying with foreign laws and regulations that may differ substantially

from country to country and may conflict with corresponding U.S. laws and regulations.

In June 2016, eligible members of the electorate in the United Kingdom decided by referendum to leave the European
Union,  in  what  is  often  referred  to  as  Brexit.  Negotiations  for  Brexit  have  caused  political  and  economic  uncertainty,
including in the regulatory framework applicable to the operations of biotechnology and pharmaceutical companies, and this
uncertainty  may  persist  for  years.  Brexit  could,  among  other  outcomes,  disrupt  the  free  movement  of  goods,  services  and
people between the United Kingdom and the European Union, result in changes to, and uncertainty regarding the application
and interpretation of, national and international laws and regulations and introduce other legal and regulatory complexities.
For example, because a significant proportion of the regulatory framework in the United Kingdom is derived from European
Union  directives  and  regulations,  Brexit  could  materially  change  the  regulatory  regime  applicable  to  our  operations,
including  with  respect  to  Ocaliva  for  PBC  and,  if  approved,  OCA  for  liver  fibrosis  due  to  NASH  and  our  other  product
candidates.  Such  outcomes  could  make  it  more  difficult  and  expensive  for  us  to  do  business  in  Europe,  complicate  our
clinical, manufacturing and regulatory strategies and impair our ability to obtain and maintain regulatory approval for, and, if
approved, commercialize, our products and product candidates in Europe. In addition, our ability to continue to conduct our
international operations out of the United Kingdom, where the headquarters for our international operations is located, may
be materially and adversely affected. While we have undertaken a number of Brexit-related contingency planning initiatives,
the  full  potential  financial,  legal,  regulatory  and  other  implications  of  Brexit  are  uncertain  and  we  cannot  make  any
assurances regarding the extent to which our business may be adversely affected thereby.

In  addition,  we  are  subject  to  the  anti-bribery  and  anticorruption  laws  of  the  United  States,  as  well  as  of  foreign
jurisdictions where we operate, including the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act. Generally, these
laws prohibit paying or offering anything of value to a foreign government official for the purpose of obtaining or retaining
business.  U.S.  and  foreign  regulators  have  increased  their  enforcement  of  anti-bribery  and  anticorruption  laws  in  recent
years, and failure to comply with these laws could result in various adverse consequences, including:

● the possible delay in approval or refusal to approve our product candidates;

● recalls, seizures or withdrawal from the market of an approved product;

● disruption in the supply or availability of our products or suspension of export or import privileges;

● the imposition of civil or criminal sanctions;

● the prosecution of executives overseeing our international operations; and

63

Table of Contents

● damage to our reputation.

Any significant impairment of our ability to develop our product candidates or sell our approved products outside of the

United States could adversely impact our business and financial results.

Our business and operations would suffer in the event of system failures, data breaches or violations of data protection
laws.

We are increasingly dependent on information technology systems and infrastructure, including mobile technologies, to
operate  our  business.  In  the  ordinary  course  of  our  business,  we  collect,  process,  store  and  transmit  large  amounts  of
confidential  information,  including  intellectual  property,  proprietary  business  information  and  personally  identifiable
information. It is critical that we do so in a secure manner to maintain the confidentiality and integrity of such confidential
information. The size and complexity of our information technology systems, and those of third-party vendors with whom
we contract, and the volume of data we retain, make such systems potentially vulnerable to breakdown, malicious intrusion,
security breaches and other cyber-attacks. Information security risks have significantly increased in recent years in part due
to the proliferation of new technologies and the increased sophistication and activities of organized crime, hackers, terrorists
and  other  external  parties,  including  foreign  state  actors.  Our  information  security  systems  and  those  of  our  third  party
vendors  are  subject  to  laws  and  regulations,  or  may  become  subject  to  new  laws  and  regulations,  requiring  that  we  enact
certain  measures  to  protect  the  privacy  and  security  of  certain  information  we  collect  or  use  in  our  business.  A  security
breach  or  privacy  violation  that  leads  to  disclosure  or  modification  of,  or  prevents  access  to,  personally  identifiable
information or other protected information, whether caused by internal or external parties, could harm our reputation, compel
us  to  comply  with  federal  and/or  state  breach  notification  laws  and  foreign  law  equivalents,  subject  us  to  notification
requirements under certain agreements with third parties, subject us to mandatory corrective action, require us to verify the
correctness  of  database  contents  and  otherwise  subject  us  to  liability  under  laws  and  regulations  that  protect  personal
information,  resulting  in  increased  costs  or  loss  of  revenue.  Similarly,  the  loss  of  clinical  trial  data  from  completed  or
ongoing  or  planned  clinical  trials  could  prevent  us  from  obtaining  regulatory  approval  or  delay  our  regulatory  approval
efforts  and  significantly  increase  our  costs  to  recover  or  reproduce  the  data.  If  we  are  unable  to  prevent  such  security
breaches or privacy violations or implement satisfactory remedial measures, our operations could be disrupted, and we may
suffer loss of reputation, financial loss and be subject to regulatory fines and penalties. In addition, these breaches and other
inappropriate  access  can  be  difficult  to  detect,  and  any  delay  in  identifying  them  may  lead  to  increased  harm  of  the  type
described above. Moreover, the prevalent use of mobile devices that access confidential information increases the risk of data
security  breaches,  which  could  lead  to  the  loss  of  confidential  information,  trade  secrets  or  other  intellectual  property.  As
cyber  threats  continue  to  evolve,  we  may  be  required  to  expend  significant  additional  resources  to  continue  to  modify  or
enhance  our  protective  measures  or  to  investigate  and  remediate  any  information  security  vulnerabilities.  While  we  have
implemented  security  measures  to  protect  our  data  security  and  information  technology  systems,  such  measures  may  not
prevent such events. Significant disruptions of our information technology systems or breaches of data security could have a
material adverse effect on our business, financial condition and results of operations.

In  the  United  States,  numerous  federal  and  state  laws,  including,  without  limitation,  HIPAA  state  security  breach
notification laws, state health information privacy laws and federal and state consumer protection laws, govern the collection,
use, disclosure and storage of personal information as well as consumer rights with regard to such information. For example,
California  recently  passed  the  California  Consumer  Privacy  Act  of  2018,  which  became  effective  on  January  1,  2020.
Various  foreign  countries  where  we  may  process  personal  information  also  have,  or  are  developing,  privacy  and  data
protection  laws.  Various  foreign  countries  where  we  may  process  personal  information  also  have,  or  are  developing,  laws
governing the collection, use, disclosure and storage of personal information.

In  July  2016,  U.S.  and  European  Commission  officials  adopted  a  new  framework  called  the  European  Union-U.S.
Privacy Shield to govern cross-border flows of personal information. We adopted the European Union-U.S. Privacy Shield
and  have  certified  to  its  requirements  since  October  2016.  In  May  2018,  the  General  Data  Protection  Regulation  (the
“GDPR”) took effect in the European Union. The GDPR imposes more stringent data protection requirements, and provides
for greater penalties for noncompliance, than previous European Union data protection legislation. The GDPR implemented
a number of changes, including more onerous requirements on companies that process personal data of European Economic
Area  individuals.  In  addition,  we  do  not  know  the  extent  of  the  impact  that  Brexit  may  have  on  our  ability  to  transfer
personal information between European Union member states and the United Kingdom and we may

64

Table of Contents

need to develop new mechanisms to permit for the transfer of this data. Implementation of the GDPR and other changes in
privacy and data protection laws or regulations could require changes to certain of our business practices, thereby increasing
our costs. While we are actively employing the European Union-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield as a
means to legitimize the transfer of personal information from the European Union and Switzerland to the United States, and
are engaging in activities to comply with the GDPR requirements, we may be unsuccessful in these efforts. In addition, if
currently available mechanisms utilized for the transfer of personal information, such as the European Union-U.S. Privacy
Shield and the Swiss-U.S. Privacy Shield, are invalidated in litigation or otherwise, we may not be able to employ suitable
mechanisms to continue such transfers and our ability to conduct our business may be materially impacted.

The  legislative  and  regulatory  landscape  for  privacy  and  data  protection  continues  to  evolve,  and  there  has  been  an
increasing  amount  of  focus  on  privacy  and  data  protection  issues  that  may  affect  our  business.  -There  is  a  degree  of
uncertainty associated with the legal and regulatory environment around privacy and data protection laws, which continue to
develop in ways we cannot predict, including with respect to evolving technologies, such as cloud computing. Privacy and
data  protection  laws  may  be  interpreted  and  applied  inconsistently  from  country  to  country  and  impose  inconsistent  or
conflicting requirements. As a result, our practices may not comply in the future with all such privacy and data protection
laws. Varying jurisdictional requirements could increase the costs and complexity of compliance or require us to change our
business practices in a manner adverse to our business. A determination that we have violated any privacy or data protection
laws  could  result  in  significant  damage  awards,  fines  and  other  penalties  that  could,  individually  or  in  the  aggregate,
materially harm our business and reputation. For example, administrative fines of up to the greater of €20 million and 4% of
our  global  turnover  may  be  imposed  for  breaches  of  the  GDPR;  we  may  also  be  liable  should  any  individual  who  has
suffered  financial  or  non-financial  damage  arising  our  from  our  infringement  of  the  GDPR  exercise  their  right  to  receive
compensation against us.

In  addition,  our  marketing  activities  and  the  marketing  activities  of  any  third  parties  on  which  we  rely  are  subject  to
various regulations, including privacy and data protection laws, consumer protection laws and competition laws. Such laws
may impair our ability, or the ability of third parties on which we rely, to collect information. Such regulations may have a
negative effect on businesses and may increase the potential civil liability and cost of operating our business.

We  have  significantly  expanded  our  operations  and  plan  to  continue  our  expansion  to  support  our  future  development
strategy  for  OCA  for  indications  other  than  PBC,  including  NASH.  We  may  experience  difficulties  in  managing  our
significant growth.

We have significantly expanded our operations, including the size of our employee base, and expect to continue to grow
as  we  pursue  our  future  development  and  commercialization  strategy.  As  we  advance  our  preclinical  and  clinical
development  programs  for  OCA  and  our  other  product  candidates,  seek  regulatory  approval  in  the  United  States  and
elsewhere  and  pursue  our  commercialization  strategy,  we  may  need  to  increase  our  product  development,  scientific,
commercial  and  administrative  headcount.  Such  an  evolution  may  impact  our  strategic  focus  and  our  deployment  and
allocation of resources. Our management, personnel and systems may experience difficulty in adjusting to our growth and
strategic focus.

In addition, in order to continue to meet our obligations as a public company and to support our anticipated longer-term
growth,  we  will  need  to  increase  our  general  and  administrative  capabilities.  We  have  also  expanded  our  operations
geographically and formed a number of subsidiaries outside of the United States. In addition to our U.S. offices, we have an
office in London, which serves as the headquarters for our international operations, and regional offices in a number of other
countries,  and  we  may  further  expand  our  geographical  footprint.  Our  management,  personnel  and  systems  may  not  be
adequate to support this future growth. Furthermore, we may face a number of complexities, such as being subject to national
collective bargaining agreements for employees, in some of the countries in which we operate.

Our need to effectively manage our operations, growth and various projects requires that we:

● successfully attract and recruit new employees or consultants with the expertise and experience we require in

the United States, Europe and other jurisdictions;

65

Table of Contents

● develop and expand our commercial infrastructure;

● manage our clinical programs effectively, which are often conducted at numerous domestic and international

clinical sites, and advance our other development efforts; and

● continue to improve our operational, financial and management controls, reporting systems and procedures.

If we are unable to successfully manage our growth and the increased complexity of our operations, our business may be

materially and adversely affected.

We  may  not  be  able  to  manage  our  business  effectively  if  we  are  unable  to  attract  and  retain  key  personnel  and
consultants.

We  may  not  be  able  to  attract  or  retain  qualified  personnel  and  consultants  due  to  the  intense  competition  for  such
individuals  among  biotechnology,  pharmaceutical  and  other  businesses.  If  we  are  not  able  to  attract  and  retain  necessary
personnel  and  consultants  to  accomplish  our  business  objectives,  we  may  experience  constraints  that  will  significantly
impede the achievement of our development and commercial objectives, our ability to raise additional capital and our ability
to implement our business strategy.

Our industry has experienced a high rate of turnover of management personnel in recent years. We are highly dependent
on  the  development,  regulatory,  commercialization  and  business  development  expertise  of  Dr.  Mark  Pruzanski,  our  co-
founder, president and chief executive officer, and the other members of our executive team, as well as other key employees
and  consultants.  If  we  lose  one  or  more  of  our  executive  officers  or  other  key  employees  or  consultants,  our  ability  to
implement  our  business  strategy  successfully  could  be  seriously  harmed.  Any  of  our  executive  officers  or  other  key
employees or consultants may terminate their employment at any time and replacing such individuals may be difficult and
time-consuming  because  of  the  limited  number  of  individuals  in  our  industry  with  the  necessary  breadth  of  skills  and
experience.  Competition  to  hire  and  retain  employees  and  consultants  from  this  limited  pool  is  intense,  and  we  may  be
unable to hire, train, retain or motivate such individuals.

We also have key advisors and consultants who assist us in operating our business. These advisors are not our employees
and may have commitments to, or consulting or advisory contracts with, other entities that may limit their availability to us
and  such  individuals  typically  will  not  enter  into  non-compete  agreements  with  us.  If  a  conflict  of  interest  arises  between
their  work  for  us  and  their  work  for  another  entity,  we  may  lose  their  services.  In  addition,  our  advisors  may  assist  other
companies that compete with us.

Failure  to  establish  and  maintain  adequate  financial  infrastructure  and  accounting  systems  and  controls  could  impair
our ability to comply with the financial reporting and internal controls requirements for publicly traded companies.

As  a  public  company,  we  operate  in  a  demanding  regulatory  environment,  which  requires  us  to  comply  with  the
Sarbanes-Oxley  Act  of  2002  and  related  rules  and  regulations,  expanded  disclosure  requirements,  accelerated  reporting
requirements and complex accounting rules. Responsibilities imposed by the Sarbanes-Oxley Act include establishing and
maintaining  corporate  oversight  and  adequate  internal  control  over  financial  reporting  and  disclosure  controls  and
procedures.  Effective  internal  controls  are  necessary  for  us  to  produce  reliable  financial  reports  and  are  important  to  help
prevent financial fraud.

In particular, our compliance with Section 404 of the Sarbanes-Oxley Act has required and will continue to require that
we incur substantial accounting-related expenses and expend significant management efforts. Our testing, or the testing by
our independent registered public accounting firm, may reveal deficiencies in our internal controls that we would be required
to remediate in a timely manner. If we are not able to comply with the requirements of the Sarbanes-Oxley Act, we could be
subject  to  sanctions  or  investigations  by  the  SEC,  the  Nasdaq  Global  Select  Market  or  other  regulatory  authorities,  which
would require additional financial and management resources and could adversely affect the market price of our securities.
Furthermore, if we cannot provide reliable financial reports or prevent fraud, our business and results of operations would
likely be materially and adversely affected.

66

Table of Contents

Our  employees  may  engage  in  misconduct  or  other  improper  activities,  including  noncompliance  with  regulatory
standards and requirements and insider trading, which could significantly harm our business.

We are exposed to the risk of employee fraud or other misconduct. Misconduct by employees could include intentional
failures  to  comply  with  the  regulations  of  the  FDA,  the  SEC  or  other  domestic  or  foreign  regulators,  provide  accurate
information to the FDA, the SEC or other domestic or foreign regulators, comply with healthcare fraud and abuse laws and
regulations in the United States and abroad, report financial information or data accurately or disclose unauthorized activities
to us. In particular, sales, marketing and business arrangements in the healthcare industry are subject to extensive regulation
in the United States and abroad intended to prevent fraud, misconduct, kickbacks, self-dealing and other abusive practices.
Such  laws  and  regulations  may  restrict  or  prohibit  a  wide  range  of  pricing,  discounting,  marketing  and  promotion,  sales
commission, customer incentive and other business arrangements. Employee misconduct could also involve the improper use
of  information  obtained  in  the  course  of  clinical  trials,  which  could  result  in  regulatory  sanctions  and  serious  harm  to  our
reputation. Misconduct and misappropriation of confidential information by our employees or third parties may also include
improper  trading  in  our  securities,  which  may  harm  our  reputation  and  result  in  enforcement  actions  against  us.  We  have
adopted a global code of business conduct and implemented a corporate compliance program, but it is not always possible to
identify and deter employee 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 inquires, investigations or other
actions or lawsuits stemming from a failure to comply with applicable laws or regulations. The outcome of any such inquiry,
investigation,  action  or  lawsuit  could  have  a  significant  negative  impact  on  our  business,  including  as  a  result  of  the
imposition  of  significant  fines  or  other  sanctions.  In  addition,  the  institution  of  any  such  inquiry,  investigation,  action  or
lawsuit could negatively impact the market price of our securities.

We  face  potential  product  liability  exposure,  and  if  successful  claims  are  brought  against  us,  we  may  incur  substantial
liability for our products or product candidates and may have to limit or suspend their use.

The  use  of  our  product  candidates  in  clinical  trials  and  the  sale  of  any  products  for  which  we  have  obtained  or  may
obtain marketing approval, such as Ocaliva for PBC, expose us to the risk of product liability claims. Product liability claims
may be brought against us or our collaborators by participants enrolled in our clinical trials, patients, healthcare providers or
others. If we cannot successfully defend ourselves against any such claims, we may incur substantial liabilities. Regardless of
their merit or eventual outcome, product liability claims may result in:

● withdrawal of clinical trial participants;

● termination of clinical trial sites or entire clinical trial programs;

● costs of related litigation;

● substantial monetary awards to patients or other claimants;

● decreased demand for our products and loss of revenues;

● impairment of our business reputation;

● diversion of management and scientific resources from our business operations; and

● the  inability  to  develop  and  commercialize  our  products  and  product  candidates  or  the  withdrawal  of  our

products from the market.

We have obtained limited product liability insurance coverage. Our insurance coverage may not reimburse us or may not
be  sufficient  to  reimburse  us  for  any  expenses  or  losses  we  may  suffer.  Moreover,  insurance  coverage  is  becoming
increasingly  expensive,  and,  in  the  future,  we  may  not  be  able  to  maintain  insurance  coverage  at  a  reasonable  cost  or  in
sufficient amounts to protect us against losses due to product liability. Large judgments have been awarded in class action
lawsuits based on the unanticipated side effects of drug products. A successful product liability claim or series of claims

67

Table of Contents

brought against us, particularly if judgments exceed our insurance coverage, could decrease our cash resources and adversely
affect our business.

Our insurance policies are expensive and only protect us from some business risks, which leave us exposed to significant
uninsured liabilities.

We do not carry insurance for all categories of risk that our business may encounter. Some of the policies we currently
maintain  include  general  liability,  employment  practices  liability,  property,  auto,  workers’  compensation,  products  liability
and directors’ and officers’ insurance. We do not know, however, if our current levels of coverage are adequate or if we will
be able to obtain insurance with adequate levels of coverage in the future, if at all. Any significant uninsured liability may
require  us  to  pay  substantial  amounts,  which  could  materially  and  adversely  affect  our  financial  position  and  results  of
operations. Furthermore, any increase in the volatility of our stock price, among other factors, may result in us being required
to  pay  substantially  higher  premiums  for  our  directors’  and  officers’  insurance,  and  may  make  it  difficult  for  us  to  obtain
adequate coverage on reasonable terms, if at all.

If we engage in an in-license transaction, acquisition, reorganization or business combination, we will face a variety of
risks that could adversely affect our business operations and our securityholders.

From  time  to  time,  we  have  considered,  and  we  will  continue  to  consider  in  the  future,  strategic  business  initiatives
intended to further the expansion and development of our business. These initiatives may include in-licensing or acquiring
products,  technologies  or  businesses  or  entering  into  a  business  combination  with  another  company.  If  we  pursue  such  a
strategy, we could, among other things:

● issue equity securities that would dilute our current stockholders’ ownership;

● incur substantial debt that may place strains on our operations;

● be required to dedicate substantial operational, financial and management resources to integrate new products,

technologies or businesses;

● assume substantial actual or contingent liabilities;

● impair  our  ability  to  make  payments  of  interest  and  principal  on  our  outstanding  debt,  including  the

Convertible Notes;

● reprioritize our development programs or cease development and commercialization activities with respect to

certain of our product candidates or approved products; or

● merge  or  otherwise  enter  into  a  business  combination  with  another  company,  which  may  result  in  our
stockholders  receiving  cash  and/or  securities  of  the  other  company  on  terms  that  certain  of  our  stockholders
may not deem desirable.

We  may  use  our  limited  financial  and  human  resources  to  pursue  a  particular  research  program  or  product  candidate
that is ultimately unsuccessful or less successful than other programs or product candidates that we may have forgone or
delayed.

Because we have limited resources, we may forego or delay the development of certain programs or product candidates
that  later  prove  to  have  greater  commercial  potential  than  the  programs  or  product  candidates  that  we  do  pursue.  Our
resource  allocation  decisions  may  cause  us  to  fail  to  capitalize  on  viable  commercial  products  or  profitable  market
opportunities. Our spending on current and future research and development programs for product candidates may not yield
any commercially viable products. If we fail to accurately evaluate the commercial potential or target market for a particular
product candidate, we may relinquish valuable rights to that product candidate through strategic collaboration, licensing or
other arrangements or we may allocate our limited internal resources to that product candidate when it would

68

Table of Contents

have been more advantageous to enter into such an arrangement. Any such failure could have a material adverse effect on our
business, financial condition or results of operations.

Changes in our effective income tax rate could adversely affect our results of operations.

We are subject to income taxes in the United States and various foreign jurisdictions. Various factors may have favorable
or  unfavorable  effects  on  our  effective  income  tax  rate.  These  factors  include,  but  are  not  limited  to,  interpretations  of
existing  tax  laws,  changes  in  tax  laws  and  rates,  the  accounting  for  stock  options  and  other  stock-based  compensation,
changes in accounting standards, future levels of research and development spending, changes in the mix and level of pre-tax
earnings  in  different  jurisdictions,  the  outcome  of  audits  or  other  examinations  by  the  U.S.  Internal  Revenue  Service  (the
“IRS”) and tax regulators in other jurisdictions, the accuracy of our estimates for unrecognized tax benefits, the realization of
deferred tax assets and changes to our ownership or capital structure.

In late 2017, the United States enacted the Tax Cuts and Jobs Act of 2017 (the “TCJA”), which significantly changed
U.S. Federal income tax law, including by implementing a reduction in the Federal corporate income tax rate to 21%, moving
from a worldwide tax system towards a territorial system and imposing additional limitations on the deductibility of interest
expense and executive compensation. The U.S. Treasury Department, the IRS, and other standard-setting bodies have been
interpreting and issuing, and are expected to continue to interpret and issue guidance on how provisions of the TCJA will be
applied or otherwise administered. As additional interpretation and guidance is issued, we may make adjustments to amounts
that we have previously recorded that may materially impact our financial statements in the period in which the adjustments
are made.

The impact on our effective income tax rate resulting from the above-mentioned factors and others may be significant

and could adversely affect our results of operations.

Risks Related to Our Intellectual Property

It is difficult and costly to protect our proprietary rights, and we may not be able to ensure their protection. If our patent
position does not adequately protect our products such as Ocaliva and product candidates such as OCA for liver fibrosis
due to NASH, others may compete against us more directly, which could harm our business, possibly materially.

Our  commercial  success  will  depend  in  part  on  our  ability  to  obtain  and  maintain  patent,  trademark  and  trade  secret
protection covering Ocaliva, OCA for liver fibrosis due to NASH, if approved, and our other product candidates, as well as
our  ability  to  successfully  defend  our  intellectual  property  against  third-party  challenges.  Our  ability  to  stop  third  parties
from  making,  using,  selling,  offering  to  sell  or  importing  our  products  is  dependent  upon  the  extent  to  which  we  have
regulatory  exclusivity  or  intellectual  property-based  exclusivity  rights  under  valid  and  enforceable  patents  or  other
intellectual property that cover our products. If we fail to obtain and maintain adequate intellectual property protection, we
may  not  be  able  to  prevent  third  parties  from  launching  generic  versions  of  our  products,  from  using  our  proprietary
technologies or from marketing products that are very similar or identical to ours.

The  patent  positions  of  pharmaceutical  companies  can  be  highly  uncertain  and  involve  complex  legal  and  factual
questions  for  which  important  legal  principles  remain  unresolved.  No  consistent  policy  regarding  the  breadth  of  claims
allowed in pharmaceutical patents has emerged to date in the United States or in foreign jurisdictions, and the legal standards
relating to the patentability, validity and enforceability of pharmaceutical patents are evolving. Changes in either the patent
laws or in interpretations of patent laws in U.S. and foreign jurisdictions may diminish the value of our intellectual property.
Accordingly, we cannot predict the breadth of claims that may be enforced in the patents that we currently own or that may
issue  from  the  applications  we  have  filed  or  may  file  in  the  future  or  those  that  we  may  license  from  third  parties.
Additionally, our currently pending or future patent applications may not result in issued patents, and any term extensions or
reissues that we seek may not be granted. Further, if any patents we obtain or license are deemed invalid or unenforceable, it
could  impact  our  ability  to  commercialize  or  license  our  technology  or  we  may  not  be  able  to  prevent  third  parties  from
launching generic versions of our products, or from developing or marketing products that are similar or identical to ours.

69

Table of Contents

There have been numerous changes to the patent laws that may have a significant impact on our ability to protect our
technology  and  enforce  our  intellectual  property  rights.  In  September  2011,  the  America  Invents  Act  was  signed  into  law.
The  final  substantive  provisions  of  the  America  Invents  Act  became  effective  in  March  2013.  The  America  Invents  Act
included a number of significant changes to U.S. patent law that affect the way patent applications are filed, prosecuted and
litigated,  including,  among  other  things,  changing  from  a  “first  to  invent”  to  a  “first  inventor  to  file”  system  and  creating
processes, such as Inter Partes Review (“IPR”) and other post-grant review processes, that permit third parties to challenge
the patentability of granted patents before the Patent Trial and Appeal Board of the U.S. Patent and Trademark Office (the
“USPTO”). The IPR process, for example, permits any person to challenge the validity of a patent on the grounds that it was
anticipated or made obvious by prior art. The America Invents 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, financial condition, results of operations and growth prospects.

Others  have  filed,  and  in  the  future,  are  likely  to  file,  patent  applications  covering  products  and  technologies  that  are
similar or competitive to ours, or may be important to our business. We cannot be certain that any patent application owned
by a third party will not have priority over patent applications filed or in-licensed by us, or that we or our licensors will not
be involved in infringement, interference, derivation, opposition, nullity, invalidity or other similar proceedings before U.S.
or non-U.S. patent offices.

The degree of future protection for our proprietary rights is uncertain because legal means afford only limited protection

and may not adequately protect our rights or permit us to gain or keep our competitive advantage. For example:

● others may be able to make compounds that are similar to our products or product candidates but that are not

covered by the claims of our patents;

● we might not have been the first to make the inventions covered by our patents or pending patent applications;

● we might not have been the first to file patent applications for these inventions;

● others  may  independently  develop  similar  or  alternative  technologies,  or  may  duplicate  any  of  our

technologies;

● any patents that we obtain may not provide us with any competitive advantages or exclusivity in a particular

product area or indication or for the length of time we have anticipated;

● we may not develop additional proprietary technologies that are patentable; or

● the patents of others may have an adverse effect on our business.

We  are  the  owner  of  record  of  numerous  issued  U.S.  and  non-U.S.  patents  with  claims  directed  to  pharmaceutical
compounds, pharmaceutical compositions, methods of making these compounds and methods of using these compounds in
various indications. In addition, we are the owner of record of numerous pending U.S. and non-U.S. patent applications, and
regularly pursue additional patent applications in various jurisdictions.

The issued composition of matter patents for OCA are expected to expire in 2022 at the earliest and 2036 at the latest if
the appropriate maintenance, renewal, annuity, or other government fees are paid. Without patent protection, including patent
protection covering the composition of matter of our products and product candidates, our ability to stop others from using or
selling our products and product candidates may be limited.

Due to the patent laws of a country, the decisions of a patent examiner in a country or our own filing strategies, we may
not obtain patent coverage for all of our products and product candidates or methods involving these candidates in the parent
patent application. While we plan to pursue divisional patent applications or continuation patent applications in the United
States and other countries to obtain claim coverage for inventions which were disclosed but not claimed in the

70

Table of Contents

parent patent application, we cannot be certain that such patents will be granted or that the scope of any patent granted will
prevent third parties from selling the same or similar products.

If  we  do  not  obtain  protection  under  the  Hatch-Waxman  Act  and  similar  legislation  outside  of  the  United  States  by
extending the patent terms and obtaining data exclusivity for our products and product candidates, our business may be
materially harmed.

Depending  upon  the  timing,  duration  and  specifics  of  FDA  marketing  approval  of  our  products,  U.S.  patents  may  be
eligible for a limited extension of patent term under the Drug Price Competition and Patent Term Restoration Act of 1984
(the “Hatch-Waxman Act”). The Hatch-Waxman Act permits an extension of patent term of up to five years as compensation
for patent term lost during product development and the FDA regulatory review process. However, an extension may not be
granted because of, for example, failure to apply within applicable deadlines, failure to apply prior to expiration of relevant
patents  or  failure  to  satisfy  applicable  requirements.  Moreover,  the  applicable  time  period  or  scope  of  patent  protection
afforded could be less than what is requested. If we are unable to obtain patent term extension or restoration or the term of
any such extension is less than we request, the period during which we will have the right to exclusively market our product
will  be  shortened,  our  competitors  may  obtain  approval  of  competing  products  following  our  patent  expiration  and  our
revenue could be reduced, possibly materially.

Our primary composition of matter patent for OCA expires in 2022. In light of the U.S. marketing approval of Ocaliva
for PBC in May 2016, we applied for an extension of the patent term for this patent in the United States through 2027. In
addition,  in  connection  with  the  conditional  approval  of  Ocaliva  for  PBC  in  the  European  Union,  we  applied  for
supplementary patent certification (“SPC”) to extend the patent term for this patent in the European Union through 2027. To
date,  we  have  received  grants  of  SPC  in  Austria,  Cyprus,  Denmark,  Finland,  France,  Germany,  Greece,  Ireland,  Italy,
Norway,  Portugal,  Spain  and  Sweden.  We  have  also  taken  similar  actions  in  other  jurisdictions  and  countries  where
regulations  providing  for  patent  term  extension  exist.  The  issued  composition  of  matter  patents  for  OCA  are  expected  to
expire in 2022 at the earliest and 2036 at the latest if the appropriate maintenance, renewal, annuity, or other government fees
are paid.

We  may  incur  substantial  costs  as  a  result  of  litigation  or  other  proceedings  relating  to  patent  and  other  intellectual
property rights, and such litigation may divert the attention of our management and scientific personnel and adversely
affect our development and commercialization efforts.

If we choose to go to court or engage in other adversarial proceedings to stop another party from using the inventions
claimed in any of our current or future patents, that individual or company has the right to ask the court or adjudicating body
to  rule  that  such  patents  are  invalid,  not  infringed  or  should  not  be  enforced  against  that  third  party.  These  lawsuits  and
proceedings  are  expensive  and  would  consume  time  and  resources  and  divert  the  attention  of  management  and  scientific
personnel even if we are successful in defending our rights. In addition, there is a risk that such court or adjudicating body
will decide that such patents are invalid, unenforceable or not infringed, and that we do not have the right to stop the other
party  from  using  the  inventions.  In  addition,  the  U.S.  Supreme  Court  has  modified  some  tests  utilized  by  the  USPTO  in
granting patents over the past 20 years, which may decrease the likelihood that we will be able to obtain patents and increase
the likelihood of challenges to our patents or the patents we license.

We may infringe the intellectual property rights of others, which may prevent or delay our product development efforts
and/or delay, halt or increase the costs of our commercialization efforts.

Our success will depend in part on our ability to operate without infringing the proprietary rights of third parties. We
cannot guarantee that our products, or the manufacture or use of our product candidates, will not infringe third-party patents.
Furthermore,  a  third  party  may  claim  that  we  or  our  manufacturing  or  commercialization  partners  are  using  inventions
covered  by  the  third  party’s  patent  rights  and  may  go  to  court  to  stop  us  from  engaging  in  our  normal  operations  and
activities, including making or selling our products and product candidates. The defense of these lawsuits is often costly and
could affect our results of operations and divert the attention of our management and scientific personnel. There is also a risk
that a court could decide that we or our manufacturing or commercialization partners are infringing the third party’s patents
and order us or our partners to stop the activities covered by the patents. In that event, we or our partners may be required to
halt or delay commercialization or development of the relevant product or product candidate. In

71

Table of Contents

addition, there is a risk that a court could order us or our partners to pay the other party damages for having violated the other
party’s  patents,  and  we  may  be  subject  to  indemnification  obligations  with  respect  to  any  such  payments  made  by  our
partners. The pharmaceutical and biotechnology industries have produced a proliferation of patents, and it is not always clear
to industry participants, including us, which patents cover various types of products, product candidates or methods of use.
The coverage of patents is subject to interpretation by the courts, and such interpretation is not always uniform.

If we are sued for patent infringement, we would need to demonstrate that our products, product candidates or methods
either do not infringe the patent claims of the relevant patent or that the patent claims are invalid, and we may not be able to
do this. Proving invalidity is difficult. For example, in the United States, proving invalidity requires a showing of clear and
convincing evidence to overcome the presumption of validity enjoyed by issued patents. Even if we are successful in such
proceedings, we may incur substantial costs and divert our management’s time and attention, which could have a material
adverse effect on our business. If we are unable to avoid infringing the patent rights of others, we may be required to seek a
license, which may not be available, defend an infringement action or challenge the validity of the patents in court. Patent
litigation  is  costly  and  time  consuming.  We  may  not  have  sufficient  resources  to  bring  these  actions  to  a  successful
conclusion. In addition, if we fail to obtain a license, develop or obtain non-infringing technology, defend an infringement
action  successfully  or  have  infringed  patents  declared  invalid,  we  may  incur  substantial  monetary  damages,  encounter
significant delays in the commercialization of our products and product candidates and be precluded from manufacturing or
selling our products and product candidates.

We cannot be certain that others have not filed patent applications for technology covered by our pending applications,

or that we were the first to invent or file with respect to a technology, because:

● some patent applications in the United States may be unpublished or otherwise maintained in secrecy until the

patents are issued;

● patent applications in the United States are typically not published until 18 months after the priority date; and

● publications in the scientific literature often lag behind actual discoveries.

Our competitors may have filed, and may in the future file, patent applications covering technology similar to ours. Any
such  patent  application  may  have  priority  over  our  patent  applications,  which  could  further  require  us  to  obtain  rights  to
issued patents covering such technologies. If another party has filed a U.S. patent application on inventions similar to ours,
we may have to participate in an interference, derivation or other similar proceeding declared by the USPTO to determine
priority  of  invention  in  the  United  States.  The  costs  of  these  proceedings  could  be  substantial,  and  it  is  possible  that  such
efforts would be unsuccessful, resulting in a loss of our U.S. patent position with respect to such inventions. Other countries
have similar laws that permit secrecy of patent applications, and such patent applications may be entitled to priority over our
applications in such jurisdictions.

Some  of  our  competitors  may  be  able  to  sustain  the  costs  of  complex  patent  litigation  more  effectively  than  we  can
because they have substantially greater financial and other resources. In addition, uncertainties resulting from the initiation
and  continuation  of  any  such  litigation  could  have  a  material  adverse  effect  on  the  market  price  of  our  securities  and  our
ability to raise the funds necessary to continue our operations.

Obtaining and maintaining our patent protection depends on compliance with various procedural, document submission,
fee  payment  and  other  requirements  imposed  by  governmental  patent  agencies,  and  our  patent  protection  could  be
reduced or eliminated as a result of non-compliance with these requirements.

Periodic  maintenance  fees,  renewal  fees,  annuity  fees  and  various  other  governmental  fees  on  our  patents  and  patent
applications  are  required  to  be  paid  to  the  USPTO  and  foreign  patent  offices  in  several  stages  over  the  lifetime  of  such
patents  and  patent  applications.  In  addition,  the  USPTO  and  foreign  patent  agencies  require  compliance  with  a  number  of
procedural,  documentary,  fee  payment  and  other  similar  provisions  during  the  patent  application  process.  We  have
implemented  systems  and  engaged  reputable  third-party  service  providers  to  help  ensure  that  we  comply  with  such
requirements on a timely basis, but inadvertent lapses may occur and there are situations in which noncompliance can

72

Table of Contents

result  in  abandonment  or  lapse  of  the  relevant  patent  or  patent  application,  resulting  in  partial  or  complete  loss  of  patent
rights in the relevant jurisdiction. Any such event may impair our competitive position in the relevant jurisdiction and have a
material adverse effect on our financial condition or results of operations.

We may be subject to claims that our employees have wrongfully used or disclosed alleged trade secrets of their former
employers.  If  we  are  not  able  to  adequately  prevent  disclosure  of  trade  secrets  and  other  proprietary  information,  the
value of our technology, products and product candidates could be significantly diminished.

As  is  common  in  the  biotechnology  and  pharmaceutical  industries,  we  employ  individuals  who  were  previously
employed at other biotechnology or pharmaceutical companies, including our competitors or potential competitors. We may
be  subject  to  claims  that  these  employees,  or  we,  have  inadvertently  or  otherwise  used  or  disclosed  trade  secrets  or  other
proprietary information of their former employers. Litigation may be necessary to defend against these claims, which could
result in substantial costs and be a distraction to our management even if we are successful.

We may rely on trade secrets to protect our proprietary technologies, especially where we do not believe patent protection
is appropriate or obtainable. However, trade secrets are difficult to protect, and may not prevent others from independently
and  lawfully  developing  similar  or  identical  products  that  circumvent  our  intellectual  property.  We  rely  in  part  on
confidentiality agreements with our employees, consultants, outside scientific collaborators, sponsored researchers and other
advisors  to  protect  our  trade  secrets  and  other  proprietary  information.  These  agreements  may  not  effectively  prevent
disclosure of confidential information and may not provide an adequate remedy in the event of unauthorized disclosure of
confidential information.

Third  parties,  including  competitors  of  ours,  may  also  independently  discover  our  trade  secrets  or  other  proprietary
information. In addition, we may be required under U.S. or foreign transparency initiatives or other regulations to publicly
disclose or otherwise make available certain information that we consider to be proprietary, including pre-clinical and clinical
research data. Enforcing a claim that a third party illegally obtained and is using any of our trade secrets or other proprietary
information  is  expensive  and  time  consuming,  and  the  outcome  is  unpredictable.  In  addition,  courts  outside  of  the  United
States are sometimes reluctant to protect trade secrets. Costly and time-consuming litigation could be necessary to enforce
and determine the scope of our proprietary rights, and failure to obtain or maintain protection of our trade secrets and other
proprietary information could adversely affect our competitive business position.

We  have  not  yet  registered  all  of  our  trademarks  and  failure  to  secure  such  registrations  could  adversely  affect  our
business.

We have numerous trademark and service mark registrations and pending trademark and service mark applications in the

United States and abroad.

Our trademark applications may not be allowed for registration and our registered trademarks may not be maintained or
enforced. During prosecution of applications for trademark registration, we may receive rejections or refusals. Although we
are given an opportunity to respond, we may be unable to overcome such rejections. In addition, the USPTO and comparable
agencies in many other jurisdictions provide third parties with an opportunity to oppose pending trademark applications and
to seek to cancel registered trademarks. Opposition or cancellation proceedings have been filed and may in the future be filed
against certain of our trademarks, and our trademarks may not survive such proceedings. If we do not secure registrations for
our trademarks, we may encounter more difficulty in enforcing them against third parties than we otherwise would.

Trademark protection varies in accordance with local laws. Trademarks remain in force in some countries as long as the
trademark  is  used  and  in  other  countries  as  long  as  the  trademark  is  registered.  Trademark  registrations  generally  are  for
fixed  but  renewable  terms.  We  cannot  provide  any  assurances  that  any  trademarks  or  service  marks  will  be  sufficient  to
prevent competitors from adopting similar names. The adoption of similar names by competitors could impede our ability to
build brand identity and may lead to customer confusion, which could adversely affect our sales or profitability.

73

Table of Contents

Risks Related to Our Indebtedness

Servicing our debt will require significant amounts of cash, and we may not have sufficient cash flow from our business
to pay our debt.

Our  ability  to  make  scheduled  payments  of  the  principal  of,  to  pay  interest  on  or  to  refinance  the  $460.0  million
aggregate  principal  amount  of  2023  Convertible  Notes  that  we  issued  in  July  2016  and/or  the  $230.0  million  aggregate
principal amount of 2026 Convertible Notes that we issued in May 2019 or any other indebtedness we or our subsidiaries
may incur in the future depends on our future performance, which is subject to economic, financial, competitive and other
factors beyond our control. Our business may not generate cash flow from operations in the future sufficient to service our
debt,  including  the  Convertible  Notes.  If  we  are  unable  to  generate  cash  flow,  we  may  be  required  to  adopt  one  or  more
alternatives, such as selling assets, restructuring debt or obtaining additional equity capital on terms that may be unfavorable
to  us  or  highly  dilutive.  Our  ability  to  refinance  our  indebtedness  will  depend  on  the  capital  markets  and  our  financial
condition  at  the  time  we  seek  to  refinance  such  indebtedness.  We  may  not  be  able  to  engage  in  any  of  these  activities  or
engage in these activities on desirable terms, which could result in a default on our debt obligations.

We  may  incur  substantially  more  debt  or  take  other  actions  that  would  affect  our  ability  to  pay  the  principal  of  and
interest on our debt.

We and our subsidiaries may be able to incur substantial additional debt in the future, some of which may be secured
debt.  We  and  our  subsidiaries  are  not  restricted  under  the  terms  of  the  indentures  governing  the  Convertible  Notes  or
otherwise from incurring additional debt, securing existing or future debt, recapitalizing our debt or taking other actions that
could have the effect of diminishing our ability to service our debt when due.

The accounting method for convertible debt securities that may be settled in cash, such as the Convertible Notes, could
have a material effect on our reported financial results.

Under  Accounting  Standards  Codification  Subtopic  470-20,  “Debt  with  Conversion  and  Other  Options”  (“ASC  470-
20”), an entity must separately account for the liability and equity components of convertible debt instruments (such as the
Convertible  Notes)  that  may  be  settled  entirely  or  partially  in  cash  upon  conversion  in  a  manner  that  reflects  the  issuer’s
economic interest cost. The effect of ASC 470-20 on the accounting for the Convertible Notes is that the equity component is
required to be included in the additional paid-in capital section of stockholders’ equity on our consolidated balance sheets,
and the value of the equity component is treated as original issue discount for purposes of accounting for the debt component
of  the  Convertible  Notes.  As  a  result,  we  are  required  to  record  a  greater  amount  of  non-cash  interest  expense  in  current
periods  presented  as  a  result  of  the  amortization  of  the  discounted  carrying  value  of  the  Convertible  Notes  to  their  face
amount over the term of the Convertible Notes. Because ASC 470-20 requires interest to include both the current period’s
amortization of the debt discount and the instrument’s coupon interest, we report lower net income in our financial results,
which could adversely affect the market price of our common stock and the market price of the Convertible Notes.

In  addition,  under  certain  circumstances,  convertible  debt  instruments  (such  as  the  Convertible  Notes)  that  may  be
settled entirely or partly in cash are currently accounted for utilizing the treasury stock method, the effect of which is that the
shares issuable upon conversion of the Convertible Notes will not be included in the calculation of diluted earnings per share
except to the extent that the conversion value of the notes exceeds their principal amount. Under the treasury stock method,
for  diluted  earnings  per  share  purposes,  the  transaction  is  accounted  for  as  if  the  number  of  shares  of  common  stock  that
would be necessary to settle such excess, if we elected to settle such excess in shares, are issued. We cannot be sure that the
accounting standards in the future will continue to permit the use of the treasury stock method. If we are unable to use the
treasury  stock  method  in  accounting  for  the  shares  issuable  upon  conversion  of  the  Convertible  Notes,  then  our  diluted
earnings per share would be adversely affected.

74

Table of Contents

Risks Related to Ownership of Our Common Stock

Ownership in our common stock is highly concentrated and your ability to influence corporate matters may be limited as
a result.

Our executive officers, directors and stockholders who own more than 5% of our outstanding common stock together
beneficially own a significant percentage of our common stock based on reports filed with the SEC. If these stockholders
were  to  choose  to  act  together,  they  would  be  able  to  significantly  influence  matters  submitted  to  our  stockholders  for
approval, including the election of directors and approval of any merger, consolidation, sale of all or substantially all of our
assets or other business combination or reorganization, as well as our management and affairs. This concentration of voting
power could delay or prevent an acquisition of us on terms that other securityholders may desire. The interests of this group
of stockholders may not always coincide with your interests or the interests of other securityholders and they may act in a
manner  that  advances  their  best  interests  and  not  necessarily  those  of  other  securityholders,  including  seeking  a  premium
value for their common stock, and might affect the market price of our common stock and the Convertible Notes.

We have a significant stockholder, which will limit your ability to influence corporate matters, may give rise to conflicts of
interest and could result in future substantial sales of shares of our common stock into the market.

Genextra S.p.A. (“Genextra”) is our largest stockholder and owns a significant minority percentage of our outstanding
common stock. Accordingly, Genextra exerts and will continue to exert significant influence over us and any action requiring
the approval of the holders of our common stock, including the election of directors and amendments to our organizational
documents, such as increases in our authorized shares of common stock and approval of significant corporate transactions.
This concentration of voting power makes it less likely that any other holder of common stock will be able to affect the way
we are managed and could delay or prevent an acquisition of us on terms that other securityholders may desire.

Furthermore, the interests of Genextra may not always coincide with the interests of other securityholders, and Genextra
may act in a manner that advances its best interests and not necessarily those of other securityholders, including seeking a
premium value for its common stock, and might affect the market price of our common stock and the Convertible Notes. Our
board of directors, which consists of ten directors, including one associated with Genextra, has the power to set the number
of directors on our board from time to time.

Genextra also may sell shares of our common stock into the market from time to time, and we cannot predict the effect,
if  any,  that  future  sales  by  Genextra  may  have  on  the  market  price  of  our  common  stock  or  the  Convertible  Notes.  In
addition, Genextra has informed us that it has pledged shares of our common stock that it holds as collateral in connection
with a margin loan. Enforcement against such collateral could materially and adversely affect the price of our common stock
or the Convertible Notes.

An active trading market in our common stock may not be maintained.

The trading market in our common stock has been extremely volatile. The quotation of our common stock on the Nasdaq
Global Select Market does not assure that a meaningful, consistent and liquid trading market will exist. We cannot predict
whether  an  active  market  for  our  common  stock  will  be  maintained  in  the  future.  An  absence  of  an  active  trading  market
could adversely affect your ability to sell our common stock at current market prices in short time periods, or possibly at all.
Additionally, market visibility for our common stock may be limited and such lack of visibility may have a depressive effect
on the market price for our common stock.

We have previously been, and are currently, subject to securities class action litigation and may be subject to similar or
other litigation in the future. Such matters can be expensive, time-consuming and have a material adverse effect on our
business, results of operations and financial condition.

We  have  previously  been  subject  to  securities  class  action  lawsuits.  In  February  2014,  two  purported  securities  class

actions were filed against us and certain of our officers, which were eventually consolidated. In May 2016, the defendants

75

Table of Contents

reached an agreement with the lead plaintiff to seek court approval of a proposed resolution and the settlement was ultimately
granted final approval by the court in September 2016. While the final judgment and order of the court included a dismissal
of the action with prejudice against all defendants and the defendants did not admit any liability as part of the settlement, the
total payment aggregated to $55.0 million, of which $10.0 million was paid by our insurers.

In September 2017, a lawsuit and, in January 2018, a follow-on lawsuit were filed alleging that we and certain of our
officers  made  material  misrepresentations  and/or  omissions  of  material  fact  regarding  Ocaliva  dosing,  use  and
pharmacovigilance-related  matters,  as  well  as  our  operations,  financial  performance  and  prospects.  The  plaintiffs  seek
unspecified monetary damages on behalf of the putative class, an award of costs and expenses, including attorney’s fees, and
rescissory damages. While we believe that we have a number of valid defenses to the claims described above and intend to
vigorously defend ourselves, the matters are in the early stages of litigation and no assessment can be made as to the likely
outcome of the matters or whether they will be material to us.

We  may  be  subject  to  additional  suits  or  proceedings  brought  in  the  future  and,  as  has  been  the  case  with  many
companies in our industry, we may from time to time receive inquiries and subpoenas and other types of information requests
from  government  authorities  and  others.  While  the  ultimate  outcome  of  any  such  investigations,  inquiries,  information
requests and legal proceedings is difficult to predict, adverse resolutions or settlements of those matters may result in, among
other things, modification of our business practices, product recalls, significant costs, payments, damages or fines or other
administrative, civil or criminal remedies, liabilities or penalties, which may have a material adverse effect on our business,
results  of  operations  and  financial  condition.  In  addition,  monitoring  and  defending  against  legal  actions,  whether  or  not
meritorious,  and  responding  to  investigations,  inquiries  and  information  requests  is  expensive,  time-consuming  for  our
management  and  detracts  from  our  ability  to  fully  focus  our  internal  resources  on  our  business  activities,  and  we  cannot
predict how long it may take to resolve such matters. Although we may receive insurance coverage for certain adversarial
proceedings, coverage could be denied or prove to be insufficient. It is possible that we could, in the future, incur a judgment
or enter into settlement of claims for monetary damages. A decision adverse to our interests could result in the payment of
substantial damages and could have a material adverse effect on our business, results of operations and financial condition.

Our  stock  price  has  been  and  may  in  the  future  be  volatile,  which  could  cause  holders  of  our  common  stock  to  incur
substantial losses.

The market price of our common stock has been, and is likely to continue to be, highly volatile and could be subject to
wide fluctuations in response to various factors, some of which are beyond our control. Since our initial public offering in
October  2012,  the  price  of  our  common  stock  on  the  Nasdaq  Global  Select  Market  has  ranged  from  $17.96  per  share  to
$497.00  per  share.  In  addition  to  the  other  factors  discussed  in  this  “Risk  Factors”  section  and  elsewhere  in  this  Annual
Report on Form 10-K, the factors that may result in wide fluctuations in the price of our common stock include any:

● receipt of additional marketing authorizations for Ocaliva in our target markets or for our product candidates,

including OCA for liver fibrosis due to NASH;

● failure  to  successfully  commercialize  Ocaliva  for  PBC  or  our  other  approved  products  in  the  United  States,
Europe and our other target markets in which we have or may receive marketing authorization or our inability
to maintain regulatory approval for Ocaliva or our other approved products in such markets;

● issues, delays or failures in identifying patients, enrolling patients, treating patients, retaining patients, meeting
specific endpoints in the jurisdictions in which we intend to seek approval or completing and timely reporting
the results of our NASH or PBC clinical trials;

● inability to obtain additional funding;

● delay in filing an investigational new drug application, NDA, MAA or comparable submission for any of our
product  candidates,  and  any  adverse  development  or  perceived  adverse  development  with  respect  to  the
regulatory review of any such submission;

76

Table of Contents

● failure  to  successfully  develop,  obtain  regulatory  approval  of  and,  if  approved,  commercialize  OCA  for

indications other than PBC, such as liver fibrosis due to NASH, or any of our other product candidates;

● potential  side  effects  associated  with  Ocaliva  for  PBC,  OCA  for  liver  fibrosis  due  to  NASH  or  our  other

product candidates;

● inability to obtain adequate product supply of Ocaliva, OCA for liver fibrosis due to NASH or any of our other

product candidates or the inability to do so at acceptable prices;

● results of clinical trials of our competitors’ products and product candidates;

● regulatory actions with respect to our products or product candidates or our competitors’ products or product

candidates;

● changes in laws or regulations applicable to our products or product candidates;

● failure to meet or exceed financial projections or guidance we may provide to the public;

● failure to meet or exceed the estimates and projections of the investment community;

● actual or anticipated fluctuations in our financial condition and operating results;

● actual or anticipated changes in our growth rate relative to our competitors;

● actual or anticipated fluctuations in our competitors’ operating results or changes in their growth rate;

● competition from existing products or new products that may emerge;

● announcements by us, our collaborators or our competitors of significant acquisitions, strategic collaborations,

joint ventures, collaborations or capital commitments;

● issuance of new or updated research or reports by securities analysts;

● fluctuations in the valuation of companies perceived by investors to be comparable to us;

● share price and volume fluctuations attributable to inconsistent trading volume levels of our shares;

● additions or departures of key management or scientific personnel;

● disputes or other developments related to proprietary rights, including patents, litigation matters and our ability

to obtain patent protection for our technologies;

● announcement or expectation of additional financing efforts;

● disputes,  governmental  inquiries  or  investigations,  legal  proceedings  or  litigation,  including  any  securities,

intellectual property, employment, product liability or other litigation;

● sales of our common stock by us, our insiders or our other stockholders;

● failure  to  adopt  appropriate  information  security  systems,  including  any  systems  that  may  be  required  to
support  our  growing  and  changing  business  requirements,  or  prevent  system  failures,  data  breaches  or
violations of data protection laws;

● market conditions for biopharmaceutical stocks in general; and

● general economic, industry and market conditions.

Any of these factors could also affect the trading price of the Convertible Notes.

77

Table of Contents

Furthermore,  stock  markets  in  general  and  the  market  for  biotechnology  companies  in  particular  have  experienced
extreme  price  and  volume  fluctuations  that  have  affected  and  continue  to  affect  the  market  prices  of  securities  of  many
companies.  These  fluctuations  often  have  been  unrelated  or  disproportionate  to  the  operating  performance  of  those
companies. These broad market and industry fluctuations, as well as general economic, political and market conditions such
as  recessions,  interest  rate  changes  or  international  currency  fluctuations  may  negatively  impact  the  market  price  of  our
securities,  regardless  of  our  actual  operating  performance.  In  the  past,  companies  that  have  experienced  volatility  in  the
market price of their stock have been subject to securities class action litigation. We have been in the past, and are currently
subject  to  this  type  of  litigation,  which  could  result  in  substantial  costs  and  divert  our  management’s  attention  from  other
business concerns, which could seriously harm our business. As a result of this volatility, you could incur substantial losses.

If  our  stockholders  sell  substantial  amounts  of  our  common  stock,  the  market  price  of  our  common  stock  or  the
Convertible Notes may decline even if our business is doing well.

A significant number of shares of our common stock are held by a small number of stockholders, including Genextra.
Sales  of  a  significant  number  of  shares  of  our  common  stock,  or  the  expectation  that  such  sales  may  occur,  could
significantly reduce the market price of our common stock or the Convertible Notes. These sales, or the possibility that these
sales may occur, also might make it more difficult for us to sell equity securities in the future at a time and price that we
deem appropriate. We have also registered the offer and sale of the shares of common stock that we may issue under our
equity  compensation  plans,  including  upon  the  exercise  of  stock  options.  These  shares  may  be  freely  sold  in  the  public
market upon issuance.

Additionally, sales of our common stock by our executive officers or directors, even when done during an open trading
window  under  our  policies  with  respect  to  insider  sales  or  done  under  a  trading  plan  adopted  in  accordance  with  the
guidelines set forth by Rule 10b5-1, may adversely impact the market price of our common stock or the Convertible Notes.
Although we do not expect that the relatively small volume of such sales would itself significantly impact the market price of
our  common  stock  or  the  Convertible  Notes,  the  market  could  react  negatively  to  the  announcement  of  such  sales,  which
could in turn affect the market price of our common stock and the Convertible Notes. Furthermore, Genextra has informed us
that  it  has  pledged  shares  of  our  common  stock  that  it  holds  as  collateral  in  connection  with  a  margin  loan.  Enforcement
against such collateral could materially and adversely affect the price of our common stock and the Convertible Notes.

Our disclosure controls and procedures may not prevent or detect all errors or acts of fraud.

We are subject to the periodic reporting requirements of the Exchange Act. Our disclosure controls and procedures are
designed to reasonably assure that information required to be disclosed by us in reports we file or submit under the Exchange
Act  is  accumulated  and  communicated  to  management,  recorded,  processed,  summarized  and  reported  within  the  time
periods  specified  in  the  rules  and  forms  of  the  SEC.  We  believe  that  any  disclosure  controls  and  procedures  or  internal
controls and procedures, no matter how well conceived and operated, can provide only reasonable, not absolute, assurance
that the objectives of the control system are met.

These inherent limitations include the realities that judgments in decision-making can be faulty and that breakdowns can
occur because of simple error or mistake. Additionally, controls can be circumvented by the individual acts of some persons,
by  collusion  of  two  or  more  people  or  by  an  unauthorized  override  of  the  controls.  Accordingly,  because  of  the  inherent
limitations  in  our  control  system,  misstatements  or  insufficient  disclosure  due  to  error  or  fraud  may  occur  and  not  be
detected.

You may experience future dilution as a result of future equity offerings or strategic transactions.

We may raise additional funds through the issuance and sale of additional shares of our common stock or other securities
convertible  into  or  exchangeable  for  our  common  stock.  For  example,  in  May  2019,  we  issued  and  sold  an  aggregate  of
2,879,760  shares  of  common  stock  and  $230.0  million  aggregate  principal  amount  of  the  2026  Convertible  Notes,  in
April  2018,  we  issued  and  sold  an  aggregate  of  4,257,813  shares  of  common  stock  and  in  July  2016,  we  issued  and  sold
$460.0 million aggregate principal amount of the 2023 Convertible Notes. Conversions of the Convertible Notes will dilute
the ownership interests of existing shareholders to the extent that we elect to deliver shares of our common

78

Table of Contents

stock (or a combination of cash and shares of our common stock) in connection therewith. In addition, the existence of the
Convertible Notes may encourage short selling by market participants because the conversion of the Convertible Notes could
depress the price of our common stock. We may also issue shares of common stock, stock options, restricted stock, restricted
stock  units  or  other  stock-based  awards  under  our  existing  or  future  equity  incentive  plans  or  other  employee  or  director
compensation  plans.  The  issuance  of  additional  shares  of  common  stock  (including  pursuant  to  conversions  of  the
Convertible Notes) or other securities convertible into or exchangeable for our common stock, or the perception that such
issuances may occur, may materially and adversely affect the price of our common stock and the Convertible Notes.

If  securities  or  industry  analysts  cease  publishing  research  or  reports  about  us,  our  business  or  our  market,  or  if  they
publish inaccurate or unfavorable reports about us or our securities, the price of our securities and trading volume in our
securities could decline.

The market for our common stock and the Convertible Notes depends in part on the research and reports that securities
or  industry  analysts  publish  about  our  company.  We  do  not  have  any  control  over  these  analysts,  and  there  can  be  no
assurance that analysts will continue to cover us or provide favorable coverage. If one or more of the analysts who cover us
downgrade our common stock or publish inaccurate or unfavorable research about our business, our stock price and the price
of  the  Convertible  Notes  may  decline.  If  one  or  more  of  the  analysts  covering  us  fail  to  regularly  publish  reports  on  us,
demand for our common stock and the Convertible Notes may decline, which could cause our stock price and the price of the
Convertible Notes and trading volume to decline.

Anti-takeover  provisions  in  our  restated  certificate  of  incorporation  and  our  restated  bylaws,  as  well  as  provisions  of
Delaware law and certain provisions of the Convertible Notes, might discourage, delay or prevent a change in control of
our  company  or  changes  in  our  management  and,  therefore,  depress  the  market  price  of  our  common  stock  or  the
Convertible Notes.

Provisions in our restated certificate of incorporation and restated bylaws, as well as provisions of Delaware law, may
discourage,  delay  or  prevent  a  merger,  acquisition  or  other  change  in  control  that  our  securityholders  consider  favorable,
including transactions in which securityholders might otherwise receive a premium for their securities. These provisions may
also  prevent  or  frustrate  attempts  by  our  stockholders  to  replace  or  remove  our  management.  Our  corporate  governance
documents include provisions:

● authorizing the issuance of “blank check” convertible preferred stock, the terms of which may be established

and shares of which may be issued without stockholder approval;

● prohibiting  stockholder  action  by  written  consent,  thereby  requiring  all  stockholder  actions  to  be  taken  at  a
meeting of our stockholders, to the extent that no stockholder, together with its affiliates, holds more than 50%
of our voting stock;

● eliminating the ability of stockholders to call a special meeting of stockholders;

● permitting  our  board  of  directors  to  accelerate  the  vesting  of  outstanding  equity  awards  upon  certain

transactions that result in a change of control; and

● establishing advance notice requirements for nominations for election to the board of directors or for proposing

matters that can be acted upon at stockholder meetings.

In  addition,  as  a  Delaware  corporation,  we  are  subject  to  provisions  of  Delaware  law,  including  Section  203  of  the
Delaware  General  Corporation  Law  (the  “DGCL”),  which  prevents  some  stockholders  holding  more  than  15%  of  our
outstanding common stock from engaging in certain business combinations without approval of the holders of substantially
all  of  our  outstanding  common  stock.  Any  provision  of  our  restated  certificate  of  incorporation  or  restated  bylaws  or
Delaware  law  that  has  the  effect  of  delaying  or  deterring  a  change  in  control  could  limit  the  opportunity  for  our
securityholders to receive a premium for their securities, and could also affect the price that some investors are willing to pay
for our common stock or the Convertible Notes.

79

Table of Contents

Certain  provisions  of  the  Convertible  Notes  could  also  make  it  more  difficult  or  more  expensive  for  a  third  party  to
acquire us. For example, if an acquisition event constitutes a “fundamental change” under the terms of the Convertible Notes,
holders of the Convertible Notes will have the right to require us to purchase their Convertible Notes for cash. Similarly, if an
acquisition  event  constitutes  a  “make-whole  fundamental  change”  under  the  terms  of  the  Convertible  Notes,  we  may  be
required to increase the conversion rate for holders who convert their Convertible Notes in connection with such make-whole
fundamental change.

The existence of the foregoing provisions and anti-takeover measures may also frustrate or prevent any attempts by our
stockholders to replace or remove our current management or members of our board of directors and could limit the price
that investors might be willing to pay in the future for shares of our common stock or the Convertible Notes. They could also
deter potential acquirers of our company, thereby reducing the likelihood that our securityholders could receive a premium
for their securities in an acquisition.

Claims for indemnification by our directors and officers may reduce our available funds to satisfy successful stockholder
claims against us and may reduce the amount of money available to us.

As  permitted  by  Section  102(b)(7)  of  the  DGCL,  our  restated  certificate  of  incorporation  limits  the  liability  of  our
directors to the fullest extent permitted by law. In addition, as permitted by Section 145 of the DGCL, our restated certificate
of  incorporation  and  restated  bylaws  provide  that  we  shall  indemnify,  to  the  fullest  extent  authorized  by  the  DGCL,  each
person  who  is  involved  in  any  litigation  or  other  proceeding  because  such  person  is  or  was  a  director  or  officer  of  our
company, or is or was serving as an officer or director of another entity at our request, against all expense, loss or liability
reasonably incurred or suffered in connection therewith. Our restated certificate of incorporation provides that the right to
indemnification  includes  the  right  to  be  paid  expenses  incurred  in  defending  any  proceeding  in  advance  of  its  final
disposition,  subject  to  certain  conditions.  The  rights  conferred  in  the  restated  certificate  of  incorporation  and  the  restated
bylaws  are  not  exclusive,  and  we  are  authorized  to  enter  into  indemnification  agreements  with  our  directors,  officers,
employees and agents and to obtain insurance to indemnify such persons.

The  above  limitations  on  liability  and  our  indemnification  obligations  limit  the  personal  liability  of  our  directors  and
officers for monetary damages for breach of their fiduciary duty by shifting the burden of such losses and expenses to us.
Although we carry directors’ and officers’ liability insurance, certain liabilities or expenses covered by our indemnification
obligations may not be covered by such insurance or the coverage limitation amounts may be exceeded. As a result, we may
need  to  use  a  significant  amount  of  our  funds  to  satisfy  our  indemnification  obligations,  which  could  severely  harm  our
business and financial condition and limit the funds available to securityholders who may choose to bring a claim against our
company.

We do not intend to pay dividends in the foreseeable future.

We  do  not  anticipate  paying  cash  dividends  in  the  future.  As  a  result,  only  appreciation  of  the  price  of  shares  of  our
common stock will provide a return to stockholders, which may not occur. Investors seeking cash dividends should not invest
in our common stock. You may not realize any return on your investment in our common stock and may lose some or all of
your investment.

Our ability to use our net operating loss carryforwards and certain other tax attributes may be limited.

We have significant net operating loss carryforwards (“NOLs”) for U.S. Federal, state and foreign income tax purposes.
The enactment of the TCJA modified the ability of companies to utilize U.S. Federal NOLs arising in tax years beginning on
or after January 1, 2018, by providing that such NOLs may be carried-forward indefinitely and used to offset up to 80 percent
of taxable income in any given future year. Existing NOLs that arose in tax years beginning prior to January 1, 2018, were
not affected by the TCJA and are generally eligible to be carried-forward for up to 20 years and used to fully offset taxable
income in future years. If not utilized, our pre-2018 NOLs will expire for U.S. Federal income tax purposes between 2024
and 2037. We also have certain state and foreign NOLs in varying amounts depending on the different state and foreign tax
laws.

80

Table of Contents

In addition, our ability to utilize our NOLs may be limited under Section 382 of the Internal Revenue Code or applicable
state  and  foreign  tax  law.  The  Section  382  limitations  apply  if  an  “ownership  change”  occurs.  Generally,  an  ownership
change occurs when certain shareholders increase their aggregate ownership by more than 50 percentage points over their
lowest ownership percentage in a testing period (typically three years). We have evaluated whether one or more ownership
changes  under  Section  382  have  occurred  since  our  inception  and  have  determined  that  there  have  been  at  least  two  such
changes. Although we believe that these ownership changes have not resulted in material limitations on our ability to use
these  NOLs,  our  ability  to  utilize  these  NOLs  may  be  limited  due  to  future  ownership  changes  or  for  other  reasons.  As  a
result, we may not be able to take full advantage of our NOL carryforwards for U.S. Federal, state, and foreign income tax
purposes.

Item 1B.  Unresolved Staff Comments

None.

Item 2.   Properties

Our  corporate  headquarters  are  located  at  10  Hudson  Yards  in  New  York,  New  York,  where  we  lease  and  occupy  an
aggregate  of  approximately  45,600  square  feet  of  office  space.  The  lease  covering  this  property  is  currently  scheduled  to
expire in March 2022.

Our research and development operations are based in San Diego, California, where we lease and occupy an aggregate
of approximately 47,000 square feet of space. The lease covering this property is currently scheduled to expire in July 2020.
We  will  lease  and  occupy  approximately  34,000  square  feet  of  office  space  in  San  Diego  under  a  separate  lease  that  is
expected to commence in August 2020 and scheduled to expire 60 months from the commencement date.

We also lease and occupy approximately 8,600 square feet of office space in London, United Kingdom, which serves as
the headquarters for our international operations. The lease covering this property is currently scheduled to expire in May
2024.

We  believe  that  our  existing  facilities  are  adequate  for  our  immediate  needs  and  that,  should  it  be  needed,  additional

space can be leased to accommodate any future growth.

Item 3.   Legal Proceedings

For  a  description  of  our  significant  legal  proceedings,  see  Note  16  to  our  audited  consolidated  financial  statements

included elsewhere in this Annual Report on Form 10-K and incorporated by reference herein.

Item 4.   Mine Safety Disclosures

Not applicable.

81

Table of Contents

PART II

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

Market Information and Stockholders

Our common stock trades on the Nasdaq Global Select Market under the symbol “ICPT”. As of December 31, 2019,
there were 32,853,066 shares of our common stock issued and outstanding and approximately 256 stockholders of record. A
significantly  larger  number  of  stockholders  may  hold  their  shares  in  “street  name”  through  banks,  brokers  and  other
nominees. The number of stockholders of record does not include stockholders who hold their shares in “street name.”

Stock Price Performance Graph

The  following  graph  compares  the  cumulative  total  stockholder  return  for  our  common  stock  to  the  cumulative  total
stockholder return for the Nasdaq Composite Index and the Nasdaq Biotechnology Index, in each case, for the period from
December 31, 2014 through December 31, 2019. The graph assumes an initial investment of $100 in our common stock at
the closing price of $156.00 on December 31, 2014 and in the Nasdaq Composite Index and the Nasdaq Biotechnology Index
on December 31, 2014 and the reinvestment of dividends. The stock performance shown below is not intended to forecast or
be indicative of the possible future performance of our common stock, and we do not make or endorse any predications as to
future  stockholder  returns.  The  following  stock  performance  information  shall  not  be  deemed  to  be  “soliciting  material,”
“filed” with the U.S. Securities and Exchange Commission (the “SEC”), incorporated by reference into any filing under the
Securities  Act  of  1933,  as  amended  (the  “Securities  Act”),  or  the  Securities  Exchange  Act  of  1934,  as  amended  (the
“Exchange  Act”),  or  subject  to  the  liabilities  of  Section  18  of  the  Exchange  Act,  except  to  the  extent  that  we  specifically
incorporate it by reference into a document filed under the Securities Act or the Exchange Act.

Among Intercept Pharmaceuticals, Inc., the Nasdaq Composite Index and

Comparison of Cumulative Total Return

the Nasdaq Biotechnology Index

82

Table of Contents

$100 investment in stock or index
Intercept Pharmaceuticals, Inc.
Nasdaq Composite Index
Nasdaq Biotechnology Index

Dividend Policy

2014

2015

2016

2017

2018

2019

December 31,

$  100.00
$  100.00
$  100.00

$  95.74
$  106.96
$  111.77

$  69.65
$  116.45
$  87.91

$  37.45
$  150.96
$  106.92

$  64.61
$  146.67
$  97.45

$  79.44
$  200.49
$  121.91

We  have  never  declared  or  paid  any  cash  dividends  on  our  common  stock,  and  we  do  not  anticipate  paying  any  cash

dividends in the foreseeable future.

Recent Sales of Unregistered Securities

Not applicable.

Issuer Purchases of Equity Securities

The following table provides certain information with respect to purchases of our common stock during the three months

ended December 31, 2019.

Period

Total Number
of Shares
Purchased (1)

Total Number of
Shares Purchased as
Part of Publicly

Average
Price Paid Announced Plans or
per Share

Programs

     Maximum Number (or

Approximate Dollar
Value) of Shares that
May Yet Be Purchased
Under the Plans or
Programs

October 1, 2019 through October 31, 2019
November 1, 2019 through November 30, 2019
December 1, 2019 through December 31, 2019

Total

 2,689
 1,656
 80
 4,425

$  65.87  
$  90.65  
$  114.16  
$  76.02  

 —  
 —  
 —  
 —  

 —
 —
 —
 —

(1) Represents shares of common stock withheld to satisfy taxes associated with the vesting of restricted stock awards.

Item 6.   Selected Financial Data

The  selected  consolidated  financial  data  set  forth  below  should  be  read  together  with  “Management’s  Discussion  and
Analysis  of  Financial  Condition  and  Results  of  Operations”  and  our  audited  consolidated  financial  statements  and
accompanying notes included elsewhere in this Annual Report on Form 10-K. The selected consolidated financial data in this
section  are  not  intended  to  replace  our  audited  consolidated  financial  statements  and  accompanying  notes.  Our  historical
results are not necessarily indicative of our future results.

The selected consolidated statements of operations data for the years ended December 31, 2019, 2018 and 2017 and the
selected consolidated balance sheet data as of December 31, 2019 and 2018 have been derived from our audited consolidated
financial  statements  and  accompanying  notes  included  elsewhere  in  this  Annual  Report  on  Form  10-K.  The  selected
consolidated statements of operations data for the years ended December 31, 2016 and 2015 and the selected

83

    
    
    
    
    
    
 
    
    
    
    
    
  
    
    
    
 
 
 
 
Table of Contents

consolidated balance sheet data as of December 31, 2017, 2016 and 2015 have been derived from our audited consolidated
financial statements and accompanying notes that are not included in this Annual Report on Form 10-K.

2019

2018

Years Ended December 31, 
2017
(in thousands, except per share data)

2016

2015

Consolidated Statement of Operations Data:
Revenue:

Product revenue, net
Licensing revenue
Total revenues
Operating expenses:

Cost of sales
Selling, general and administrative
Research and development
Total operating expenses
Operating loss

Total other income (expense), net
Net loss
Net loss per common and potential common share,
basic and diluted
Weighted average common and potential common
shares outstanding, basic and diluted

$  249,570
 2,432
 252,002

$  177,782
 2,022
 179,804

$  129,175
 1,781
 130,956

$

 18,169
 6,782
 24,951

$

 —
 2,782
 2,782

 —  

 4,212
 317,418
 242,799
 564,429
   (312,427)
 (32,254)

 —
 1,371
 119,242
 273,698
 112,696
 191,499
 231,938
 466,568
 (229,156)
   (335,612)
 2,727
 (24,755)
$  (344,681) $  (309,242) $  (360,367) $  (412,830) $  (226,429)

 2,519
 255,474
 207,301
 465,294
   (285,490)
 (23,752)

 273,596
 153,893
 427,489
   (402,538)
 (10,292)

$

 (10.89) $

 (10.86) $

 (14.38) $

 (16.74) $

 (9.56)

 31,654

 28,464

 25,054

 24,663

 23,694

2019

2018

December 31, 
2017
(in thousands)

2016

2015

Consolidated Balance Sheet Data:
Cash, cash equivalents, restricted cash and
investment debt securities
Total assets
Accounts payable, accrued expenses and other
liabilities
Long-term debt (1)
Accumulated deficit
Total stockholders’ equity

$

 657,347
 754,886

$

 436,160
 509,167

$

 414,917
 484,347

$

 689,385
 739,253

$  628,055
 655,758

 153,968
 532,078
   (2,123,466)
 51,556

 105,109
 371,250
   (1,778,785)
 19,130

 94,777
 355,677
   (1,469,543)
 16,386

 65,551
 341,356
   (1,108,460)
 314,932

 45,591
 —
 (695,630)
 602,149

(1) Reflects  $690.0  million  aggregate  principal  amount  of  Convertible  Notes,  less  unamortized  debt  discounts  and
unamortized  debt  issuance  costs  as  of  December  31,  2019  and  $460.0  million  aggregate  principal  amount  of  2023
Convertible Notes as of December 31, 2018, 2017 and 2016. See Note 9 to our audited consolidated financial statements
included elsewhere in this Annual Report on Form 10-K for further information regarding the Convertible Notes.

84

    
    
    
    
    
 
    
    
    
    
  
 
  
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
 
    
    
    
    
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 together with our audited consolidated financial statements and
accompanying notes included elsewhere in this Annual Report on Form 10-K. This discussion and analysis contains forward-
looking  statements,  which  involve  risks  and  uncertainties.  As  a  result  of  many  factors,  such  as  those  described  under
“Cautionary Note Regarding Forward-Looking Statements,” “Risk Factors” and elsewhere in this Annual Report on Form
10-K, our actual results may differ materially from those anticipated in these forward-looking statements.

Overview

We are a biopharmaceutical company focused on the development and commercialization of novel therapeutics to treat
progressive  non-viral  liver  diseases  with  high  unmet  medical  need  utilizing  our  proprietary  bile  acid  chemistry.  Our  first
marketed product, Ocaliva® (obeticholic acid or “OCA”), is a farnesoid X receptor (“FXR”) agonist approved in the United
States,  the  European  Union  and  several  other  jurisdictions  for  the  treatment  of  primary  biliary  cholangitis  (“PBC”)  in
combination  with  ursodeoxycholic  acid  (“UDCA”)  in  adults  with  an  inadequate  response  to  UDCA  or  as  monotherapy  in
adults  unable  to  tolerate  UDCA.  In  addition  to  commercializing  OCA  for  PBC  under  the  Ocaliva  brand  name,  we  are
currently  developing  OCA  for  additional  indications,  including  nonalcoholic  steatohepatitis  (“NASH”).  We  are  also
developing several other product candidates in various stages of clinical and preclinical development. We believe that OCA
and our other product candidates have the potential to treat orphan and other more prevalent liver diseases such as NASH for
which there are currently limited therapeutic options.

Ocaliva was approved for PBC by the U.S. Food and Drug Administration (“FDA”) in May 2016 under the accelerated
approval pathway. We commenced sales and marketing of Ocaliva in the United States shortly after receiving approval, and
Ocaliva is now available to U.S. patients primarily through a network of specialty pharmacy distributors. Ocaliva received
conditional  approval  for  PBC  from  the  European  Commission  in  December  2016  and  we  commenced  our  European
commercial  launch  in  January  2017.  We  have  submitted  dossiers  and  obtained,  or  are  otherwise  pursuing,  reimbursement
from  a  number  of  national  authorities  in  Europe.  Since  January  2017,  Ocaliva  has  also  received  regulatory  approval  in
several  of  our  target  markets  outside  the  United  States  and  Europe,  including  Canada,  Israel  and  Australia,  and  we  are
pursuing  marketing  approval  of  Ocaliva  for  PBC  in  our  other  international  target  markets.  Ocaliva  received  orphan  drug
designation in both the United States and the European Union for the treatment of PBC.

Our lead product candidate is OCA for the potential treatment of NASH. In February 2019, we announced topline results
from the planned 18-month interim analysis of our pivotal Phase 3 clinical trial of OCA in patients with liver fibrosis due to
NASH,  known  as  the  REGENERATE  trial.  In  the  primary  efficacy  analysis,  once-daily  OCA  25  mg  met  the  primary
endpoint agreed with the FDA of fibrosis improvement by at least one stage with no worsening of NASH at the planned 18-
month interim analysis and adverse events were generally mild to moderate in severity and the most common were consistent
with the known profile of OCA. Interim analysis results at 18 months were based on surrogate endpoints and the impact on
clinical outcomes has not been confirmed. The REGENERATE trial is ongoing and will continue through clinical outcomes
for  verification  and  description  of  the  clinical  benefit  of  OCA.  OCA  also  achieved  the  primary  endpoint  in  a  Phase  2b
clinical trial for the treatment of NASH completed in late July 2014, known as the FLINT trial, which was sponsored by the
U.S. National Institute of Diabetes and Digestive and Kidney Diseases, a part of the National Institutes of Health. OCA has
received  breakthrough  therapy  designation  from  the  FDA  for  the  treatment  of  NASH  patients  with  liver  fibrosis.  In
September 2019, we submitted a New Drug Application (“NDA”) to the FDA seeking accelerated approval of OCA for liver
fibrosis due to NASH. In November 2019, the FDA accepted our NDA for filing and granted a priority review designation of
OCA for liver fibrosis due to NASH. Under the Prescription Drug User Fee Act (“PDUFA”), the FDA has set a target action
date of June 26, 2020 for the completion of its review of our NDA, after giving effect to a 90 day extension of its initial
target action date. The FDA has also notified us that it has tentatively scheduled an advisory committee meeting relating to
our  NDA  for  April  22,  2020.  In  December  2019,  we  submitted  a  Marketing  Authorization  Application  (“MAA”)  to  the
European  Medicines  Agency  (“EMA”)  seeking  conditional  approval  of  OCA  for  liver  fibrosis  due  to  NASH.  In  January
2020,  the  EMA  validated  our  MAA  and  thereby  confirmed  that  our  MAA  was  sufficiently  complete  to  begin  the  formal
review  process.  In  addition,  we  are  conducting  a  number  of  other  trials  and  studies  in  connection  with  our  NASH
development  program,  including  our  ongoing  Phase  3  trial  in  NASH  patients  with  compensated  cirrhosis,  known  as  the
REVERSE trial. In January 2020, we announced that we completed enrollment of the REVERSE trial with over 900 patients
randomized.

85

Table of Contents

As  part  of  our  product  development  activities,  we  expect  to  continue  to  invest  in  evaluating  the  potential  of  OCA  in
other  progressive  non-viral  liver  diseases.  We  are  studying  OCA  in  combination  with  bezafibrate,  a  pan-peroxisome
proliferator-activated receptor (“PPAR”) agonist, in patients with PBC and potentially may study such combination in other
liver diseases. In addition, we have other compounds in early stages of research and development in our pipeline.

Capital Markets Activities During the Periods Under Review

In  May  2019,  we  issued  and  sold  (i)  2,760,000  shares  of  common  stock  in  a  registered  public  offering
(including 360,000 shares issued and sold upon the exercise in full of the underwriters’ option to purchase additional shares),
at a price to the public of $83.50 per share (the “2019 Public Offering”) and (ii) 119,760 shares of common stock (the “2019
Private Placement Shares”) in a concurrent private placement of common stock (the “2019 Concurrent Private Placement”)
exempt from the registration requirements of the Securities Act of 1933, as amended (the “Securities Act”), at a purchase
price  per  share  equivalent  to  the  price  to  the  public  set  in  the  2019  Public  Offering  and  pursuant  to  a  securities  purchase
agreement  (the  “2019  Securities  Purchase  Agreement”)  that  the  Company  entered  into  with  Samsara  BioCapital,  L.P.
(“Samsara”), one of our existing stockholders. Pursuant to the 2019 Securities Purchase Agreement, we granted to Samsara
certain  registration  rights  requiring  us,  upon  request  of  Samsara  on  or  after  July  9,  2019  and  subject  to  certain  terms  and
conditions, to register the resale by Samsara of its 2019 Private Placement Shares. Such registration rights expire upon the
earlier  of  (i)  May  8,  2020  and  (ii)  the  date  that  all  of  the  2019  Private  Placement  Shares  have  been  sold  or  can  be  sold
publicly under Rule 144 of the Securities Act on a single day. We received net proceeds from the 2019 Public Offering and
the  2019  Concurrent  Private  Placement  of  approximately  $227.3  million,  after  deducting  underwriting  discounts,
commissions and estimated offering expenses of approximately $13.9 million.

In May 2019, we also issued and sold $230.0 million aggregate principal amount of 2.00% Convertible Senior Notes due
2026  (the  “2026  Convertible  Notes”).  We  received  net  proceeds  from  the  sale  of  the  2026  Convertible  Notes  of  $223.4
million, after deducting underwriting discounts, commissions and estimated offering expenses of approximately $6.6 million.

In  April  2018,  we  issued  and  sold  (i)  2,695,313  shares  of  common  stock  in  a  registered  public  offering  (including
351,563 shares issued and sold upon the exercise in full of the underwriters’ option to purchase additional shares), at a price
to the public of $64.00 per share (the “2018 Public Offering”) and (ii) 1,562,500 shares of common stock (the “2018 Private
Placement  Shares”)  in  a  concurrent  private  placement  (the  “2018  Concurrent  Private  Placement”)  exempt  from  the
registration requirements of the Securities Act, at a purchase price per share equivalent to the price to the public set in the
2018 Public Offering and pursuant to a securities purchase agreement (the “2018 Securities Purchase Agreement”) that we
entered  into  with  the  purchasers  in  the  2018  Concurrent  Private  Placement  (the  “2018  Private  Placement  Purchasers”).
Pursuant  to  the  2018  Securities  Purchase  Agreement,  we  granted  to  the  2018  Private  Placement  Purchasers  certain
registration rights which expired on April 4, 2019. We received net proceeds from the 2018 Public Offering and the 2018
Concurrent  Private  Placement  of  approximately  $261.4  million,  after  deducting  underwriting  discounts,  commissions  and
estimated offering expenses of approximately $11.1 million.

Financial Overview

Revenue

We  commenced  our  commercial  launch  of  Ocaliva  for  the  treatment  of  PBC  in  the  United  States  in  June  2016.  In
December  2016,  the  European  Commission  granted  conditional  approval  for  Ocaliva  for  the  treatment  of  PBC  and  we
commenced  our  European  commercial  launch  in  January  2017.  Since  January  2017,  Ocaliva  has  also  received  regulatory
approval in several of our target markets outside the United States and Europe, including Canada, Israel and Australia. We
sell  Ocaliva  to  a  limited  number  of  specialty  pharmacies  which  dispense  the  product  directly  to  patients.  The  specialty
pharmacies are referred to as our customers.

Effective January 1, 2018, we began recognizing revenue under Accounting Standards Codification (“ASC”) Topic 606,
Revenue from Contracts with Customers (“ASC 606”). The core principle of this revenue standard is that a company should
recognize revenue to depict the transfer of promised goods or services to customers in an amount that reflects the

86

Table of Contents

consideration to which the company expects to be entitled in exchange for those goods or services. The following five steps
are applied to achieve that core principle:

● Step 1: Identify the contract with the customer
● Step 2: Identify the performance obligations in the contract
● Step 3: Determine the transaction price
● Step 4: Allocate the transaction price to the performance obligations in the contract
● Step 5: Recognize revenue when the company satisfies a performance obligation

Product Revenue, Net

We provide the right of return to our customers for unopened product for a limited time before and after its expiration
date.  Prior  to  July  2017,  given  our  limited  sales  history  for  Ocaliva  and  the  inherent  uncertainties  in  estimating  product
returns, we determined that the shipments of Ocaliva made to our customers did not meet the criteria for revenue recognition
at the time of shipment. Accordingly, we recognized revenue when the product was sold through by our customers, provided
all other revenue recognition criteria were met. We invoiced our customers upon shipment of Ocaliva to them and recorded
accounts receivable, with a corresponding liability for deferred revenue equal to the gross invoice price. We then recognized
revenue  when  Ocaliva  was  sold  through  as  specialty  pharmacies  dispensed  product  directly  to  the  patients  (sell-through
basis).  We  re-evaluated  our  revenue  recognition  policy  in  the  third  quarter  of  2017,  which  included  the  accumulation  and
review of customer-related transactions since our commercial launch in the second quarter of 2016. We concluded we had
accumulated sufficient data to reasonably estimate product returns and, therefore, began to recognize revenue at the time of
shipment to our customers (sell-in basis).

Under ASC 606, we have written contracts with each of our customers that have a single performance obligation — to
deliver  products  upon  receipt  of  a  customer  order  —  and  these  obligations  are  satisfied  when  delivery  occurs  and  the
customer  receives  Ocaliva.  We  evaluate  the  creditworthiness  of  each  of  our  customers  to  determine  whether  collection  is
reasonably assured. We estimate variable revenue by calculating gross product revenues based on the wholesale acquisition
cost  that  we  charge  our  customers  for  Ocaliva,  and  then  estimating  our  net  product  revenues  by  deducting  (i)  trade
allowances,  such  as  invoice  discounts  for  prompt  payment  and  customer  fees,  (ii)  estimated  government  rebates  and
discounts related to Medicare, Medicaid and other government programs, and (iii) estimated costs of incentives offered to
certain indirect customers including patients.

We  recognized  net  sales  of  Ocaliva  of  $249.6  million,  $177.8  and  $129.2  million  for  the  years  ended  December  31,

2019, 2018 and 2017, respectively.

Licensing Revenue

In March 2011, we entered into an exclusive license agreement (the “Original Sumitomo Agreement”) with Sumitomo
Dainippon Pharma Co., Ltd. (“Sumitomo Dainippon”), pursuant to which we granted to Sumitomo Dainippon an exclusive
license to research, develop and commercialize OCA for the treatment of PBC and NASH in Japan and China (excluding
Taiwan)  and  an  option  to  research,  develop  and  commercialize  OCA  in  certain  countries  outside  of  such  territories  (the
“Country  Option”).  We  received  an  upfront  payment  from  Sumitomo  Dainippon  of  $15.0  million  under  the  terms  of  the
Original Sumitomo Agreement. In May 2014, Sumitomo Dainippon exercised the Country Option in part to add Korea as
part  of  its  licensed  territories  and  paid  us  a  $1.0  million  upfront  fee  in  connection  therewith.  In  February  2018,  we  and
Sumitomo Dainippon entered into Amendment No. 3 (the “Sumitomo Amendment”) to the Original Sumitomo Agreement
(as amended, the “Sumitomo Agreement”), pursuant to which (i) Sumitomo Dainippon agreed to return the rights to develop
and commercialize OCA in Japan and Korea and waived its rights to the Country Option, (ii) we agreed to forego any further
milestone  or  royalty  payments  relating  to  the  development  and  commercialization  of  OCA  in  Japan  and  Korea  and  (iii)
certain  milestone  payment  obligations  with  respect  to  the  development  and  commercialization  of  OCA  were  adjusted.  In
October 2019, we and Sumitomo Dainippon mutually agreed to terminate with immediate effect the Sumitomo Agreement.
In connection with the termination of the Sumitomo Agreement, Sumitomo Dainippon agreed to return to us the rights to
develop and commercialize OCA in China and we agreed to forego any further milestone or royalty payments relating to the
development and commercialization of OCA in China. No payment is due from us to Sumitomo Dainippon as a result of the
termination of the Sumitomo Agreement.

87

Table of Contents

As of December 31, 2019, we had achieved $6.0 million of development milestones under the Sumitomo Agreement.

For  accounting  purposes,  the  upfront  payments  were  recorded  as  deferred  revenue  and  amortized  over  time  and
milestone  payments  are  recognized  once  earned.  For  the  years  ended  December  31,  2019,  2018  and  2017,  we  recognized
$2.4  million,  $2.0  million  and  $1.8  million,  respectively,  in  licensing  revenue  related  to  the  amortization  of  the  upfront
payments  under  the  Sumitomo  Agreement.  Included  in  licensing  revenue  for  the  year  ended  December  31,  2019  is  $1.2
million  related  to  the  accelerated  recognition  of  deferred  revenue  as  a  result  of  the  agreement  termination.  Included  in
licensing revenue for the year ended December 31, 2018 is $0.4 million related to the accelerated recognition, as a result of
the Sumitomo Amendment, of the remaining portion of deferred revenue associated with the $1.0 million upfront payment
that we received under the Original Sumitomo Agreement in connection with Sumitomo Dainippon’s exercise of the Country
Option with respect to Korea.

Selling, General and Administrative Expenses

We have incurred and expect to continue to incur significant selling, general and administrative expenses as a result of,
among  other  initiatives,  the  launch  and  commercialization  of  Ocaliva  for  PBC  in  the  United  States,  Europe  and  our  other
target markets, the preparation for the potential commercialization of OCA for liver fibrosis due to NASH, if approved, and
our other future approved products, if any, and the build-out of our general and administrative infrastructure in the United
States and abroad.

Research and Development Expenses

Since  our  inception,  we  have  focused  significant  resources  on  our  research  and  development  activities,  including
conducting preclinical studies and clinical trials, pursuing regulatory approvals and engaging in other product development
activities. We recognize research and development expenses as they are incurred.

We have incurred and expect to continue to incur significant research and development expenses as a result of, among
other initiatives, our clinical development programs for OCA for PBC and NASH, our other earlier stage research programs
and our regulatory approval efforts.

Results of Operations

Comparison of the Years Ended December 31, 2019 and 2018

The following table summarizes our results of operations for the years ended December 31, 2019 and 2018:

Revenue:

Product revenue, net
Licensing revenue
Total revenue

Operating expenses:

Cost of sales
Selling, general and administrative
Research and development
Total operating expenses

Other income (expense):

Interest expense
Other income, net

Net loss

88

Years Ended December 31, 

2019

2018

(in thousands)

$  249,570
 2,432
 252,002

$  177,782
 2,022
 179,804

 4,212
 317,418
 242,799
 564,429

 2,519
 255,474
 207,301
 465,294

 (41,144)
 8,890
 (32,254)
$  (344,681)

 (30,523)
 6,771
 (23,752)
$  (309,242)

    
    
    
 
    
    
 
 
 
 
 
  
 
  
 
 
 
 
 
 
 
 
 
  
 
  
 
 
 
 
 
 
Table of Contents

Revenues

Product  revenue,  net  was  $249.6  million  and  $177.8  million  for  the  years  ended  December  31,  2019  and  2018,
respectively. For the years ended December 31, 2019 and 2018, product revenue, net was comprised of U.S. Ocaliva net sales
of  $187.5  million  and  $140.8  million,  respectively,  and  ex-U.S.  Ocaliva  net  sales  of  $62.1  million  and  $37.0  million,
respectively. We commenced our commercial launch of Ocaliva for the treatment of PBC in the United States and certain
European countries in June 2016 and January 2017, respectively. Since January 2017, Ocaliva has also received regulatory
approval in several of our target markets outside the United States and Europe, including Canada, Israel and Australia. For
the  years  ended  December  31,  2019  and  2018,  licensing  revenue  was  $2.4  million  and  $2.0  million,  respectively,  in  each
case, related to the amortization of upfront payments under the Sumitomo Agreement.

Cost of sales

Cost of sales was $4.2 million and $2.5 million for the years ended December 31, 2019 and 2018, respectively. Our cost
of sales for the years ended December 31, 2019 and 2018 consisted primarily of packaging, labeling, materials and related
expenses.

Selling, general and administrative expenses

Selling, general and administrative expenses were $317.4 million and $255.5 million for the years ended December 31,
2019 and 2018, respectively. The $61.9 million net increase between periods was primarily driven by increases in expenses
relating to our launch preparation activities associated with the potential approval and commercialization of OCA for liver
fibrosis due to NASH.

Research and development expenses

Research  and  development  expenses  were  $242.8  million  and  $207.3  million  for  the  years  ended  December  31,  2019
and 2018, respectively. The $35.5 million net increase between periods was primarily driven by increases in OCA for liver
fibrosis  due  to  NASH  development  program  expenses  and  costs  associated  with  the  preparation  of  the  NASH  NDA
submission.

Interest expense

Interest expense was $41.1 million and $30.5 million for the years ended December 31, 2019 and 2018, respectively. For
the year ended December 31, 2019, interest expense related to the 2026 Convertible Notes that we issued in May 2019 and
the $460.0 million aggregate principal amount of 3.25% Convertible Senior Notes due 2023 (the “2023 Convertible Notes”
and  together  with  the  2026  Convertible  Notes,  the  “Convertible  Notes”)  that  we  issued  in  July  2016.  For  the  year  ended
December 31, 2018, interest expense related only to the 2023 Convertible Notes.

Other income, net

Other  income,  net  was  $8.9  million  and  $6.8  million  for  the  years  ended  December  31,  2019  and  2018,  respectively.

Such income is primarily attributable to interest income earned on cash, cash equivalents and investment debt securities.

Income taxes

For the years ended December 31, 2019 and 2018, no income tax expense or benefit was recognized. Our deferred tax
assets are comprised primarily of net operating loss carryforwards. We maintain a full valuation allowance on our deferred
tax assets since we have not yet achieved sustained profitable operations. As a result, we have not recorded any income tax
benefit since our inception.

89

Table of Contents

Comparison of the Years Ended December 31, 2018 and 2017

The following table summarizes our results of operations for the years ended December 31, 2018 and 2017:

Revenue:

Product revenue, net
Licensing revenue
Total revenue

Operating expenses:

Cost of sales
Selling, general and administrative
Research and development
Total operating expenses

Other income (expense):

Interest expense
Other income, net

Net loss

Revenues

Years Ended December 31, 

2018

2017

(in thousands)

  $  177,782   $  129,175  
 1,781  
 130,956  

 2,022  
 179,804  

 2,519
 255,474  
 207,301  
 465,294  

 1,371
 273,698  
 191,499  
 466,568  

 (30,523) 
 6,771  
 (23,752) 
$  (309,242)

 (29,271) 
 4,516  
 (24,755) 
$  (360,367)

Product  revenue,  net  was  $177.8  million  and  $129.2  million  for  the  years  ended  December  31,  2018  and  2017,
respectively. For the years ended December 31, 2018 and 2017, product revenue, net was comprised of U.S. Ocaliva net sales
of  $140.8  million  and  $115.8  million,  respectively,  and  ex-U.S.  Ocaliva  net  sales  of  $37.0  million  and  $13.4  million,
respectively. We commenced our commercial launch of Ocaliva for the treatment of PBC in the United States and certain
European countries in June 2016 and January 2017, respectively. Since January 2017, Ocaliva has also received regulatory
approval  in  several  of  our  target  markets  outside  the  United  States  and  Europe,  including  Canada,  Israel  and  Australia.
Included  in  product  revenue,  net  for  the  year  ended  December  31,  2017  is  $4.1  million  of  previously  deferred  revenue
recognized in connection with our adoption of a sell-in basis revenue recognition policy in the third quarter of 2017. For the
years ended December 31, 2018 and 2017, licensing revenue was $2.0 million and $1.8 million, respectively, in each case,
related to the amortization of upfront payments under the Sumitomo Agreement.

Cost of sales

Cost of sales was $2.5 million and $1.4 million for the years ended December 31, 2018 and 2017, respectively. Prior to
the  FDA’s  approval  of  Ocaliva  in  May  2016,  we  expensed  costs  related  to  the  manufacturing  and  buildup  of  our  Ocaliva
commercial  launch  supplies  as  research  and  development  expenses.  As  a  result,  our  cost  of  sales  for  the  years  ended
December 31, 2018 and 2017 consisted primarily of packaging and labeling expenses.

Selling, general and administrative expenses

Selling, general and administrative expenses were $255.5 million and $273.7 million for the years ended December 31,
2018  and  2017,  respectively.  The  $18.2  million  net  decrease  between  periods  primarily  reflects  the  inclusion  in  selling,
general  and  administrative  expenses  for  the  year  ended  December  31,  2017  of  $9.8  million  of  expenses  incurred  in
connection with our termination in December 2017 of a lease agreement relating to office space at 55 Hudson Yards and $3.9
million of restructuring related charges.

90

    
    
         
 
    
    
 
 
 
 
 
 
 
    
    
 
 
 
 
 
 
 
 
    
    
 
 
 
 
 
 
 
Table of Contents

Research and development expenses

Research  and  development  expenses  were  $207.3  million  and  $191.5  million  for  the  years  ended  December  31,  2018
and 2017, respectively, representing a net increase of $15.8 million. The net increase in research and development expenses
primarily  reflects  $9.0  million  that  we  paid  to  Aralez  in  December  2018  pursuant  to  the  Aralez  Agreement,  as  well  as  an
increase  in  OCA  research  and  development  activities  of  approximately  $16.8  million,  partially  offset  by  a  decrease  of
approximately  $12.1  million  in  compensation-related  costs,  which  includes  $1.3  million  of  restructuring-related  charges
incurred in the year ended December 31, 2017.

Interest expense

Interest expense was $30.5 million and $29.3 million for the years ended December 31, 2018 and 2017, respectively, in

each case, related to the 2023 Convertible Notes issued in July 2016.

Other income, net

Other  income,  net  was  $6.8  million  and  $4.5  million  for  the  years  ended  December  31,  2018  and  2017,  respectively.

Such income is primarily attributable to interest income earned on cash, cash equivalents and investment debt securities.

Income Taxes

For the years ended December 31, 2018 and 2017, no income tax expense or benefit was recognized. Our deferred tax
assets are comprised primarily of net operating loss carryforwards. We maintain a full valuation allowance on our deferred
tax assets since we have not yet achieved sustained profitable operations. As a result, we have not recorded any income tax
benefit since our inception.

Liquidity and Capital Resources

Cash Flows

The following table sets forth the significant sources and uses of cash for the periods indicated:

2019

Years Ended December 31, 
2018
(in thousands)

2017

Net cash provided by (used in):

Operating activities
Investing activities
Financing activities
Effect of exchange rate changes
Net increase/(decrease) in cash, cash equivalents and restricted cash

$  (236,613) $  (240,714) $  (265,402)
 287,775
   (188,988)
 2,838
 457,519
 1,127
 (386)
 26,338
 31,532

 (48,070)
 263,545
 (1,526)
$  (26,765) $

$

Operating Activities. Net cash used in operating activities of $236.6 million during the year ended December 31, 2019
was primarily a result of our $344.7 million net loss and a gain on lease termination of $2.0 million, partially offset by $56.0
million  in  stock-based  compensation,  a  net  increase  in  operating  assets  and  liabilities  of  $19.3  million,  $15.3  million  for
accretion of the discount on the 2023 Convertible Notes, $5.9 million for accretion of the discount on the 2026 Convertible
Notes, $5.4 million for non-cash operating lease costs, $3.7 million of depreciation and $2.7 million for loss on the disposal
of fixed assets.

Net cash used in operating activities of $240.7 million during the year ended December 31, 2018 was primarily a result
of our $309.2 million net loss and a net decrease in operating assets and liabilities of $2.8 million, partially offset by $49.9
million in stock-based compensation, $14.0 million for accretion of the discount on the 2023 Convertible Notes, and $4.6
million of depreciation.

91

    
    
    
 
    
    
  
 
 
 
 
 
 
 
 
Table of Contents

Net cash used in operating activities of $265.4 million during the year ended December 31, 2017 was primarily a result
of  our  $360.4  million  net  loss,  partially  offset  by  a  net  increase  in  operating  assets  and  liabilities  of  $14.6  million,  $57.0
million in stock-based compensation, $12.9 million for accretion of the discount on the 2023 Convertible Notes, $4.6 million
of depreciation and $3.4 million for amortization of investment premium.

Investing Activities. For the year ended December 31, 2019, net cash used in investing activities primarily reflects the
purchases of investment debt securities of $603.0 million, partially offset by the sales of investment debt securities of $415.2
million.

For the year ended December 31, 2018, net cash used in investing activities primarily reflects the purchase of investment

debt securities of $436.1 million, partially offset by the sale of investment debt securities of $388.2 million.

For the year ended December 31, 2017, net cash provided by investing activities primarily reflects the sale of investment
debt securities of $529.3 million, partially offset by the purchase of investment debt securities of $231.1 million and $10.4
million of capital expenditures primarily related to our offices.

Financing Activities. Net cash provided by financing activities in the year ended December 31, 2019 consisted primarily
of  net  proceeds  received  from  the  2019  Public  Offering  and  2019  Concurrent  Private  Placement  in  May  2019  of  $227.3
million and net proceeds from the issuance of the 2026 Convertible Notes of $223.4 million.

Net cash provided by financing activities in the year ended December 31, 2018 consisted primarily of net proceeds of
approximately $261.4 million from the 2018 Public Offering and 2018 Concurrent Private Placement in April 2018 and $2.2
million from the exercise of options to purchase common stock net of payments of employee withholding taxes related to
stock-based awards.

Net cash provided by financing activities in the year ended December 31, 2017 consisted primarily of $2.8 million from

the exercise of options to purchase common stock.

2019 Public Offerings and 2019 Concurrent Private Placement

In May 2019, we issued and sold an aggregate of 2,879,760 shares of common stock in the 2019 Public Offering and
2019  Concurrent  Private  Placement.  We  received  net  proceeds  from  the  2019  Public  Offering  and  the  2019  Concurrent
Private  Placement  of  approximately  $227.3  million,  after  deducting  underwriting  discounts,  commissions  and  estimated
offering expenses of approximately $13.9 million.

2026 Convertible Notes

In  May  2019,  we  issued  and  sold  $230.0  million  aggregate  principal  amount  of  2.00%  Convertible  Senior  Notes  due
2026  (the  “2026  Convertible  Notes”).  We  received  net  proceeds  from  the  sale  of  the  2026  Convertible  Notes  of  $223.4
million, after deducting underwriter discounts, commissions, and estimated offering expenses of approximately $6.6 million.

The 2026 Convertible Notes were issued pursuant to a Second Supplemental Indenture, dated as of May 14, 2019 (the
“Second  Supplemental  Indenture”),  which  supplements  the  Indenture  (the  “Base  Indenture”),  as  supplemented  by  a  First
Supplemental  Indenture  (the  “First  Supplemental  Indenture”  and  collectively  with  the  Base  Indenture  and  the  Second
Supplemental  Indenture,  the  “Indenture”),  each  dated  as  of  July  6,  2016,  by  and  between  us  and  U.S.  Bank  National
Association,  as  trustee.  The  2026  Convertible  Notes  are  senior  unsecured  obligations  of  ours,  bear  interest  at  a  fixed  rate
of 2.00% per annum (payable semi-annually on May 15 and November 15 of each year, beginning on November 15, 2019)
and  will  mature  on  May  15,  2026,  unless  earlier  repurchased,  redeemed  or  converted.  The  2026  Convertible  Notes  are
convertible at the option of holders, under certain circumstances and during certain periods, into cash, shares of our common
stock  or  a  combination  of  cash  and  shares  of  our  common  stock,  at  our  election.  The  initial  conversion  rate  of  the  2026
Convertible Notes is 9.2123 shares of our common stock per $1,000 principal amount of 2026 Convertible Notes, which is
equivalent to an initial conversion price of approximately $108.55 per share of our common stock. The conversion rate is
subject to adjustment in some events but will not be adjusted for any accrued and unpaid interest. In addition,

92

Table of Contents

following certain corporate events that occur prior to the maturity date, we will increase the conversion rate for a holder who
elects  to  convert  its  2026  Convertible  Notes  in  connection  with  such  a  corporate  event  in  certain  circumstances.  If  we
undergo a fundamental change (as defined in the Indenture), holders may require us to repurchase for cash all or any portion
of their 2026 Convertible Notes at a fundamental change repurchase price equal to 100% of the principal amount of the 2026
Convertible Notes to be repurchased, plus accrued and unpaid interest to, but excluding, the fundamental change repurchase
date.  In  addition,  if  certain  make-whole  fundamental  changes  occur,  we  will,  in  certain  circumstances,  increase  the
conversion  rate  for  any  2026  Convertible  Notes  converted  in  connection  with  such  make-whole  fundamental  change.  We
may not redeem the 2026 Convertible Notes prior to May 20, 2023. We may redeem for cash all or any portion of the 2026
Convertible Notes, at our option, on or after May 20, 2023, under certain circumstances at a redemption price equal to 100%
or the principal amount of the 2026 Convertible Notes to be redeemed, plus accrued and unpaid interest to, but excluding, the
redemption date. The Indenture provides for customary events of default.

2018 Public Offering and 2018 Concurrent Private Placement

In April 2018, we issued and sold an aggregate of 4,257,813 shares of common stock in the 2018 Public Offering and
2018  Concurrent  Private  Placement.  We  received  net  proceeds  from  the  2018  Public  Offering  and  the  2018  Concurrent
Private  Placement  of  approximately  $261.4  million,  after  deducting  underwriting  discounts,  commissions  and  estimated
offering expenses of approximately $11.1 million.

Future Funding Requirements

As  of  December  31,  2019,  we  had  $657.4  million  in  cash,  cash  equivalents,  restricted  cash  and  investment  debt
securities.  We  currently  expect  to  continue  to  incur  significant  operating  expenses  in  the  fiscal  year  ending  December  31,
2020. These expenses are planned to support, among other initiatives, the continued commercialization of Ocaliva for PBC in
the  United  States  and  our  other  markets,  launch  preparation  activities  associated  with  the  potential  approval  and
commercialization  of  OCA  for  liver  fibrosis  due  to  NASH,  our  clinical  development  and  pipeline  programs  and  our  other
operating activities. Although we believe that our existing capital resources, together with our net sales will be sufficient to
fund our anticipated operating requirements for the next twelve months and the initial phase of the anticipated U.S. launch of
OCA for liver fibrosis due to NASH, we may need to raise additional capital to fund our operating requirements beyond that
period.  Furthermore,  in  light  of  the  numerous  risks  and  uncertainties  associated  with  pharmaceutical  product  development
and  commercialization,  any  delays  in,  or  unanticipated  costs  associated  with,  our  development,  regulatory  or
commercialization  efforts  could  significantly  increase  the  amount  of  capital  required  by  us  to  fund  our  operating
requirements. Accordingly, we may seek to access the public or private capital markets whenever conditions are favorable,
even  if  we  do  not  have  an  immediate  need  for  additional  capital  at  that  time.  Our  forecast  regarding  the  period  of  time
through which our financial resources will be adequate to support our operations is a forward-looking statement that involves
risks  and  uncertainties,  and  actual  results,  including  the  costs  to  maintain  our  currently  planned  operations,  could  vary
materially.

Our  forecasts  regarding  the  period  of  time  that  our  existing  capital  resources  will  be  sufficient  to  meet  our  operating
requirements and the timing of our future funding requirements, both near and long-term, will depend on a variety of factors,
many of which are outside of our control. Such factors include, but are not limited to:

● our ability to successfully commercialize Ocaliva for PBC;

● our  ability  to  maintain  our  regulatory  approval  of  Ocaliva  for  PBC  in  the  United  States,  Europe,  Canada,  Israel,

Australia and other jurisdictions in which we have or may receive marketing authorization;

● the  initiation,  timing,  cost,  conduct,  progress  and  results  of  our  research  and  development  activities,  preclinical
studies and clinical trials, including any issues, delays or failures in identifying patients, enrolling patients, treating
patients, retaining patients, meeting specific endpoints in the jurisdictions in which we intend to seek approval or
completing and timely reporting the results of our NASH or PBC clinical trials;

● our ability to timely and cost-effectively file for and obtain regulatory approval of our product candidates, including

the regulatory approval of our NDA for NASH; any advisory committee recommendation that our

93

Table of Contents

product candidates, including OCA for liver fibrosis due to NASH, should not be approved or approved only under
certain conditions; or any determination that the regulatory applications and subsequent information we submit for
our product candidates, including OCA for liver fibrosis due to NASH, do not contain adequate clinical or other
data or meet applicable regulatory requirements for approval;

● conditions that may be imposed by regulatory authorities on our marketing approvals for our products and product
candidates, such as the need for clinical outcomes data (and not just results based on achievement of a surrogate
endpoint), and any related restrictions, limitations and/or warnings contained in the label of any of our products or
product candidates;

● any  potential  side  effects  associated  with  Ocaliva  for  PBC,  OCA  for  liver  fibrosis  due  to  NASH  or  our  other
product candidates that could delay or prevent approval, require that an approved product be taken off the market,
require  the  inclusion  of  safety  warnings  or  precautions  or  otherwise  limit  the  sale  of  such  product  or  product
candidate;

● our ability to establish and maintain relationships with, and the performance of, third-party manufacturers, contract
research organizations and other vendors upon whom we are substantially dependent for, among other things, the
manufacture and supply of our products, including Ocaliva for PBC and, if approved, OCA for liver fibrosis due to
NASH, and our clinical trial activities;

● our ability to identify, develop and successfully commercialize our products and product candidates, including our

ability to timely and successfully launch OCA for liver fibrosis due to NASH, if approved;

● our ability to obtain and maintain intellectual property protection for our products and product candidates, including
our  ability  to  cost-effectively  file,  prosecute,  defend  and  enforce  any  patent  claims  or  other  intellectual  property
rights;

● the size and growth of the markets for our products and product candidates and our ability to serve those markets;

● the degree of market acceptance of Ocaliva for PBC and, if approved, OCA for liver fibrosis due to NASH or our

other product candidates among physicians, patients and healthcare payors;

● the availability of adequate coverage and reimbursement from governmental and private healthcare payors for our
products,  including  Ocaliva  for  PBC  and,  if  approved,  OCA  for  liver  fibrosis  due  to  NASH,  and  our  ability  to
obtain adequate pricing for such products;

● our  ability  to  establish  and  maintain  effective  sales,  marketing  and  distribution  capabilities,  either  directly  or

through collaborations with third parties;

● competition from existing drugs or new drugs that become available;

● our ability to prevent system failures, data breaches or violations of data protection laws;

● costs  and  outcomes  relating  to  any  disputes,  governmental  inquiries  or  investigations,  legal  proceedings  or

litigation, including any securities, intellectual property, employment, product liability or other litigation;

● our collaborators’ election to pursue research, development and commercialization activities;

● our  ability  to  establish  and  maintain  relationships  with  collaborators  with  development,  regulatory  and

commercialization expertise;

● our need for and ability to generate or obtain additional financing;

94

Table of Contents

● our estimates regarding future expenses, revenues and capital requirements and the accuracy thereof;

● our use of cash and short-term investments;

● our ability to acquire, license and invest in businesses, technologies, product candidates and products;

● our ability to attract and retain key personnel to manage our business effectively;

● our ability to manage the growth of our operations, infrastructure, personnel, systems and controls;

● our ability to obtain and maintain adequate insurance coverage;

● the impact of general U.S. and foreign economic, industry, market, regulatory or political conditions, including the

potential impact of Brexit; and

● the  other  risks  and  uncertainties  identified  under  the  captions  “Risk  Factors”,  “Business”  and  “Management’s
Discussion and Analysis of Financial Condition and Results of Operations” and elsewhere in this Annual Report on
Form 10-K and in our other periodic filings filed with the SEC.

We have no committed external sources of funding and additional funds may not be available when we need them on
terms that are acceptable to us, or at all. In addition, our restated certificate of incorporation authorizes us to issue 45 million
shares of common stock. Following the 2019 Public Offering and the 2019 Concurrent Private Placement, and after taking
into  account  shares  of  common  stock  reserved  for  issuance  upon  the  exercise  of  outstanding  stock  options,  the  vesting  of
outstanding restricted stock units (including performance restricted stock units) and the conversion of the Convertible Notes,
together with shares of common stock available for future grants under our equity incentive plan, we have a limited number
of remaining unreserved and authorized shares available for issuance, which could impact our ability to raise additional funds
in the future. If adequate funds are not available to us, we may not be able to make scheduled debt payments on a timely
basis, or at all, and may be required to delay, limit, reduce or cease our operations.

Contractual Obligations

Our  contractual  obligations  as  of  December  31,  2019  consisted  primarily  of  obligations  under  the  Convertible  Notes,
purchase obligations entered into in the normal course of business and lease agreements. The following table summarizes our
material  contractual  obligations  as  of  December  31,  2019  and  the  effect  such  obligations  are  expected  to  have  on  our
liquidity and cash flows in future years:

Contractual Obligations:
Operating leases (1)
Convertible Notes (2)
Purchase obligations (3)
Total

Payments Due By Period

Total

Less than 1 year 1 - 3 years 3 - 5 years

More than 5
years

(in thousands)

$  24,062 $
   786,600  
 —  
$  810,662 $

 8,489 $  11,119 $

 3,731 $
 19,550    39,100    491,625  
 —  

 723
 236,325
 —
 28,039 $  50,219 $  495,356 $  237,048

 —  

 —  

(1) For  a  description  of  our  material  operating  leases,  see  “Properties”  above.  The  obligations  represent  payments  for  all
operating leases, including short-term operating leases exempt under ASC Topic 842, Leases (“ASC 842”) and leases
that have yet to commence. Operating expenses associated with our leased office buildings are not included in the table
above.

(2) Represents  2023  Convertible  Notes  and  2026  Convertible  Notes  (including  future  interest  payments  at  a  fixed  rate  of

3.25% and 2.00% per year, respectively).

(3) We  enter  into  contracts  in  the  normal  course  of  business  with  contract  research  organizations  for  our  clinical  trials,
contract manufacturing organizations for the manufacture and supply of our clinical and commercial product needs and
other vendors for other research and development and commercial activities, as well as services and products for

95

    
 
 
Table of Contents

operating  purposes.  Our  agreements  generally  provide  for  termination  with  notice.  Such  agreements  are  cancelable
contracts and are not included as purchase commitments.

Off-Balance Sheet Arrangements

As of December 31, 2019, we did not have any off-balance sheet arrangements.

Critical Accounting Policies and Estimates

Our management’s discussion and analysis of our financial condition and results of operations is based on our audited
consolidated financial statements, which we have prepared in accordance with accounting principles generally accepted in
the United States of America. The preparation of our audited consolidated financial statements requires us to make estimates
and judgments that affect the reported amounts of assets and liabilities, the disclosure of assets and liabilities at the date of
the financial statements and the reported amounts of revenues and expenses during the reporting period. We evaluate these
estimates and judgments on an ongoing basis. We base our estimates on historical experience and on various other factors
that we believe are reasonable under the circumstances, the results of which form the basis for making judgments about the
carrying value of assets and liabilities that are not readily apparent from other sources. Our actual results could differ from
these estimates.

While  our  significant  accounting  policies  are  more  fully  described  in  Note  2  to  our  audited  consolidated  financial
statements appearing elsewhere in this Annual Report on Form 10-K, we believe that the following accounting policies are
the most critical for fully understanding and evaluating our financial condition and results of operations.

Revenue Recognition

Effective  January  1,  2018,  we  began  recognizing  revenue  under  ASC  606  using  the  modified  retrospective  approach.
The core principle of this revenue standard is that a company should recognize revenue to depict the transfer of promised
goods or services to customers in an amount that reflects the consideration to which the company expects to be entitled in
exchange  for  those  goods  or  services.  The  following  five  steps  are  applied  to  achieve  that  core  principle:  (i)  identify  the
contract with the customer; (ii) identify the performance obligations in the contract; (iii) determine the transaction price; (iv)
allocate  the  transaction  price  to  the  performance  obligations  in  the  contract  and  (v)  recognize  revenue  when  the  company
satisfies a performance obligation.

Product Revenue, Net

Under ASC 606, we have written contracts with each of our customers that have a single performance obligation — to
deliver  products  upon  receipt  of  a  customer  order  —  and  these  obligations  are  satisfied  when  delivery  occurs  and  the
customer  receives  Ocaliva.  We  evaluate  the  creditworthiness  of  each  of  our  customers  to  determine  whether  collection  is
reasonably assured. We estimate variable revenue by calculating gross product revenues based on the wholesale acquisition
cost  that  we  charge  our  customers  for  Ocaliva,  and  then  estimating  our  net  product  revenues  by  deducting  (i)  trade
allowances,  such  as  invoice  discounts  for  prompt  payment  and  customer  fees,  (ii)  estimated  government  rebates  and
discounts related to Medicare, Medicaid and other government programs, and (iii) estimated costs of incentives offered to
certain indirect customers including patients.

Trade Allowances

We  provide  invoice  discounts  on  Ocaliva  sales  to  certain  of  our  customers  for  prompt  payment  and  record  these
discounts  as  a  reduction  to  gross  product  revenues.  These  discounts  are  based  on  contractual  terms.  Reserves  for  prompt
payment  discounts  are  recorded  in  the  same  period  the  related  revenue  is  recognized,  resulting  in  a  reduction  of  product
revenue and accounts receivable.

96

Table of Contents

Rebates and Discounts

We  contract  with  the  Centers  for  Medicare  &  Medicaid  Services  and  other  government  agencies  to  make  Ocaliva
available to eligible patients. As a result, we estimate any rebates and discounts and deduct these estimated amounts from our
gross  product  revenues  at  the  time  the  revenues  are  recognized.  Our  estimates  of  rebates  and  discounts  are  based  on  the
government mandated discounts, which are statutorily-defined and applicable to these government funded programs. These
estimates are recorded in accounts payable, accrued expenses and other liabilities on our consolidated balance sheets.

Other Incentives

Other incentives that we offer to indirect customers include co-pay assistance cards provided by us for PBC patients who
reside  in  states  that  permit  co-pay  assistance  programs.  Our  co-pay  assistance  program  is  intended  to  reduce  each
participating  patient’s  portion  of  the  financial  responsibility  for  Ocaliva  purchase  price  to  a  specified  dollar  amount.  We
estimate the amount of co-pay assistance provided to eligible patients based on the terms of the program when product is
dispensed  by  the  specialty  pharmacies  to  the  patients.  These  estimates  are  based  on  redemption  information  provided  by
third-party claims processing organizations and are recorded in accounts payable, accrued expenses and other liabilities on
our consolidated balance sheets.

Valuation of Stock-Based Compensation

We account for stock-based compensation in accordance with ASC Topic 718, Compensation — Stock Compensation.
We estimate the fair value of stock option awards using the Black-Scholes option pricing model on the date of the grant. The
Black-Scholes option pricing model requires the use of assumptions, including with respect to stock price volatility, assumed
dividend yield, the expected term of options and the risk-free interest rate, as described below:

• The expected volatility is estimated based on actual historical volatility information of our own ordinary shares.

• The assumed dividend yield is based on our expectation of not paying dividends for the foreseeable future.

• The expected term of options granted represents the period of time the options are expected to be outstanding and is
based on the simplified method.

• The risk-free interest rate was based on the rate for U.S. Treasury securities at the date of grant with maturity dates
   approximately equal to the expected term of the award at the grant date.

Restricted  stock  unit  awards  and  restricted  stock  awards  without  a  market  condition  are  valued  based  on  the  closing
price of our common stock on the date of the grant. The fair value of time-based equity awards is recognized and amortized
on a straight-line basis over the requisite service period of the award. We recognize stock-based compensation expense for
options and other stock-based awards with performance conditions ratably over the performance period once the pre-defined
performance-based  criteria  for  vesting  becomes  probable.  At  the  probable  date,  we  record  a  cumulative  expense  catch-up,
with remaining expense amortized over the remaining service period. Throughout the performance period, we re-assess the
estimated  performance  and  update  the  numbers  of  performance-based  awards  that  we  believe  will  ultimately  vest.  The
performance level is measured to determine the ultimate level of shares that will vest upon the conclusion of the performance
period. The fair value of awards with market conditions is estimated using the Monte Carlo simulation method and expense
is recognized on a straight-line basis over the requisite service period of the award. The Company accounts for all forfeitures
when they occur. Ultimately, the actual expense recognized over the vesting period will be for only those shares that vest and
are not forfeited.

We expect to continue to grant stock options and other stock-based awards and the impact of stock-based compensation
may fluctuate in future periods due to changes in the value of our common stock, changes to our headcount and the number
and value of awards granted.

97

Table of Contents

Convertible Senior Notes

The Convertible Notes are accounted for in accordance with ASC Subtopic 470-20, Debt  with  Conversion  and  Other
Options. ASC Subtopic 470-20 requires the issuer of convertible debt that may be settled in shares or cash upon conversion
at  the  issuer’s  option,  such  as  the  Convertible  Notes,  to  account  for  the  liability  (debt)  and  equity  (conversion  option)
components separately. The value assigned to the debt component is the estimated fair value, as of the issuance date, of a
similar debt instrument without the conversion option. The amount of the equity component (and resulting debt discount) is
calculated  by  deducting  the  fair  value  of  the  liability  component  from  the  principal  amount  of  the  convertible  debt
instrument.  The  resulting  debt  discount  is  amortized  as  additional  non-cash  interest  expense  over  the  expected  life  of  the
notes  utilizing  the  effective  interest  method.  For  additional  information,  see  Note  9  to  our  audited  consolidated  financial
statements included elsewhere in this Annual Report on Form 10-K.

Income Taxes

We  utilize  the  asset  and  liability  method  of  accounting  for  income  taxes.  Under  this  method,  deferred  tax  assets  and
liabilities are determined based on the difference between the financial statement carrying amounts and tax bases of assets
and liabilities using enacted tax rates in effect for years in which the temporary differences are expected to reverse.

We determine the need for a valuation allowance by assessing the probability of realizing deferred tax assets, taking into
consideration  all  available  positive  and  negative  evidence,  including  historical  operating  results,  expectations  of  future
taxable  income,  carryforward  periods  available,  various  income  tax  strategies  and  other  relevant  factors.  Significant
judgment is required in making this assessment and to the extent future expectations change, we would have to assess the
recoverability of our deferred assets at that time. At December 31, 2019 and 2018, we maintained a full valuation allowance
on our deferred tax assets. At any one time our tax returns for numerous tax years are subject to examination by U.S. Federal,
state, and foreign taxing jurisdictions. The impact of an uncertain tax position taken or expected to be taken on an income tax
return must be recognized in our financial statements at the largest amount that is more likely than not to be sustained. An
uncertain  income  tax  position  will  not  be  recognized  in  our  financial  statements  unless  it  is  more  likely  than  not  to  be
sustained. At December 31, 2019 and 2018, we had no reserves for unrecognized tax benefits.

Recent Accounting Pronouncements

See Note 2 to our audited consolidated financial statements included elsewhere in this Annual Report on Form 10-K for
a  full  description  of  recent  accounting  pronouncements  including  the  respective  expected  dates  of  adoption  and  expected
effects, if any, on our results of operations and financial condition.

Item 7A.  Quantitative and Qualitative Disclosures about Market Risk

Our primary exposure to market risk is interest income sensitivity, which is affected by changes in the general level of
U.S.  interest  rates.  We  currently  do  not  hedge  interest  rate  exposure.  Because  of  the  short-term  maturities  of  our  cash
equivalents  and  investment  debt  securities,  we  do  not  believe  that  an  increase  in  market  rates  would  have  any  significant
impact on the realized value of our investment debt securities. If a 10% change in interest rates were to have occurred on
December 31, 2019, this change would not have had a material effect on the fair value of our investment portfolio as of that
date.

We  do  not  believe  that  our  cash,  cash  equivalents  and  investment  debt  securities  have  significant  risk  of  default  or
illiquidity.  While  we  believe  our  cash,  cash  equivalents  and  investment  debt  securities  do  not  contain  excessive  risk,  we
cannot provide absolute assurance that, in the future, our investments will not be subject to adverse changes in market value.
In  addition,  we  maintain  significant  amounts  of  cash  and  cash  equivalents  at  one  or  more  financial  institutions  that  are  in
excess of federally insured limits.

We  contract  with  CROs,  investigational  sites,  suppliers,  facilities,  marketing  firms  and  other  vendors  and  suppliers  in
Europe  and  internationally.  We  are  therefore  subject  to  fluctuations  in  foreign  currency  rates  in  connection  with  these
agreements. We do not hedge our foreign currency exchange rate risk.

98

Table of Contents

Inflation generally affects us by increasing our cost of labor and clinical trial costs. We do not believe that inflation has

had a material effect on our results of operations during 2019, 2018 or 2017.

Item 8.   Financial Statements and Supplementary Data

The financial statements required to be filed pursuant to this Item 8 are appended to this Annual Report on Form 10-K
and  incorporated  by  reference  herein.  An  index  of  those  financial  statements  is  set  forth  under  Item  15.  “Exhibits  and
Financial Statement Schedules”.

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

Our  Chief  Executive  Officer  and  Chief  Financial  Officer  evaluated  the  effectiveness  of  our  disclosure  controls  and
procedures as of December 31, 2019. The term “disclosure controls and procedures,” as defined in Rules 13a-15(e) and 15d-
15(e)  under  the  Exchange  Act,  means  controls  and  other  procedures  of  a  company  that  are  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 recorded,
processed, summarized and reported, within the time periods specified in the SEC’s rules and forms. 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, 2019, 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.

Management’s Report on Internal Control Over Financial Reporting

Our  management  is  responsible  for  establishing  and  maintaining  adequate  internal  control  over  financial  reporting.
Internal control over financial reporting is defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act, as a process
designed by, or under the supervision of, the company’s principal executive and principal financial officers and effected by
the company’s board of directors, management and other personnel, 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  and  includes  those  policies  and  procedures  that:  (i)  pertain  to  the  maintenance  of  records  that  in
reasonable  detail  accurately  and  fairly  reflect  the  transactions  and  dispositions  of  the  assets  of  the  company;  (ii)  provide
reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance
with  generally  accepted  accounting  principles,  and  that  receipts  and  expenditures  of  our  company  are  being  made  only  in
accordance  with  authorizations  of  management  and  directors  of  the  company;  and  (iii)  provide  reasonable  assurance
regarding prevention or timely detection of unauthorized acquisition, use, or disposition of our company’s assets that could
have a material effect on the financial statements.

All internal controls, no matter how well designed, have inherent limitations. Therefore, even those systems determined
to  be  effective  can  provide  only  reasonable  assurance  with  respect  to  consolidated  financial  statement  preparation  and
presentation.  Because  of  its  inherent  limitations,  internal  control  over  financial  reporting  may  not  prevent  or  detect
misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may
become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may
deteriorate.

99

Table of Contents

Our  management,  with  the  participation  of  our  Chief  Executive  Officer  and  Chief  Financial  Officer,  assessed  the
effectiveness of our internal control over financial reporting as of December 31, 2019, based on criteria established in the
Internal  Control  —  Integrated  Framework  (2013)  issued  by  the  Committee  of  Sponsoring  Organizations  of  the  Treadway
Commission  (COSO).  Based  on  that  assessment,  management  concluded  that  our  internal  control  over  financial  reporting
was effective as of December 31, 2019.

Attestation Report of Independent Registered Public Accounting Firm

The effectiveness of our internal control over financial reporting as of December 31, 2019 has been audited by KPMG
LLP, an independent registered public accounting firm, as stated in their report included elsewhere in this Annual Report on
Form 10-K.

Changes in Internal Control Over Financial Reporting

There were no changes in our internal control over financial reporting that occurred during the quarter ended December
31,  2019  that  have  materially  affected,  or  are  reasonably  likely  to  materially  affect,  our  internal  control  over  financial
reporting.

Item 9B.  Other Information

Not applicable.

Item 10.  Directors, Executive Officers and Corporate Governance

PART III

We  have  adopted  a  Global  Code  of  Business  Conduct  as  our  “code  of  ethics,”  as  defined  by  regulations  promulgated
under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, which applies to our
directors, officers and employees, including our principal executive officer, principal financial officer, principal accounting
officer  or  controller,  or  persons  performing  similar  functions.  The  Global  Code  of  Business  Conduct  is  available  on  our
website at www.interceptpharma.com in the Investors & Media section under “Corporate Governance.” We intend to satisfy
the disclosure requirement under Item 5.05 of Form 8-K regarding any future amendment to, or waiver from, a provision of
the  Global  Code  of  Business  Conduct  that  applies  to  our  principal  executive  officer,  principal  financial  officer,  principal
accounting  officer  or  controller,  or  persons  performing  similar  functions  by  posting  such  information  on  our  website  at
www.interceptpharma.com  in  the  Investors  &  Media  section  under  “Corporate  Governance.”  The  references  to
www.interceptpharma.com herein are inactive textual references only, and the information found on our internet website is
not incorporated by reference into this Annual Report on Form 10-K or any other report we file with or furnish to the SEC.

The  remainder  of  the  information  required  by  this  item  is  incorporated  by  reference  to  our  definitive  proxy  statement
related to our 2020 Annual Meeting of Stockholders, to be filed pursuant to Regulation 14A not later than 120 days after the
end of the fiscal year covered by this Annual Report on Form 10-K.

Item 11.  Executive Compensation

The information required by this item is incorporated by reference to our definitive proxy statement related to our 2020
Annual Meeting of Stockholders, to be filed pursuant to Regulation 14A not later than 120 days after the end of the fiscal
year covered by this Annual Report on Form 10-K.

Item 12.  Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

The information required by this item is incorporated by reference to our definitive proxy statement related to our 2020
Annual Meeting of Stockholders, to be filed pursuant to Regulation 14A not later than 120 days after the end of the fiscal
year covered by this Annual Report on Form 10-K.

100

Table of Contents

Item 13.  Certain Relationships and Related Transactions, and Director Independence

The information required by this item is incorporated by reference to our definitive proxy statement related to our 2020
Annual Meeting of Stockholders, to be filed pursuant to Regulation 14A not later than 120 days after the end of the fiscal
year covered by this Annual Report on Form 10-K.

Item 14.  Principal Accounting Fees and Services

The information required by this item is incorporated by reference to our definitive proxy statement related to our 2020
Annual Meeting of Stockholders, to be filed pursuant to Regulation 14A not later than 120 days after the end of the fiscal
year covered by this Annual Report on Form 10-K.

101

Table of Contents

PART IV

Item 15.  Exhibits and Financial Statement Schedules

(a) 1. Index to Consolidated Financial Statements

Reports of Independent Registered Public Accounting Firm
Consolidated Balance Sheets
Consolidated Statements of Operations
Consolidated Statements of Comprehensive Loss
Consolidated Statements of Changes in Stockholders’ Equity
Consolidated Statements of Cash Flows
Notes to Consolidated Financial Statements

2. Index to Consolidated Financial Statements

F-2
F-5
F-6
F-7
F-8
F-9
F-10

Financial  statement  schedules  have  been  omitted  from  this  Annual  Report  on  Form  10-K  because  they  are  not
applicable,  not  required  or  the  information  required  is  set  forth  in  the  audited  consolidated  financial  statements  or
accompanying notes.

3. Exhibits

The  exhibits  filed  or  furnished  as  part  of  this  Annual  Report  on  Form  10-K  are  set  forth  in  the  Exhibit  Index  below,

which is incorporated herein by reference.

102

Table of Contents

Exhibit Index

Exhibit
Number     

3.1

3.2

4.1

4.2

4.3

4.4

4.5

4.6

4.7

4.8

4.9

Restated Certificate of Incorporation, as amended

Exhibit Description

Restated Bylaws

Form of Common Stock Certificate

Indenture, dated as of July 6, 2016, between the
Registrant and U.S. Bank National Association, as
trustee

First Supplemental Indenture (including the Form of
Note), dated as of July 6, 2016, between the Registrant
and U.S. Bank National Association, as trustee

Form of Senior Indenture

Form of Subordinated Indenture

Form of Senior Note

Form of Subordinated Note

Securities Purchase Agreement, dated April 4, 2018,
between the Registrant and the purchasers named
therein

Securities Purchase Agreement, dated May 8, 2019,
between the Registrant and the purchasers named
therein

4.10

Second Supplemental Indenture (including the Form of
Note), dated as of May 14, 2019, between the
Registrant and U.S. Bank National Association, as
trustee

4.11*

Description of Securities of the Registrant

Incorporated herein by reference

Form†
Form 10-Q

Form 8-K

Form S-8(1)

Form 8-K

     Exhibit

3.1 

3.1 

4.3 

4.1 

Filing Date
August 9, 2016

February 17, 2016

November 7, 2012

July 6, 2016

Form 8-K

4.2 

July 6, 2016

Form S-3(2)

Form S-3(2)

Form S-3(2)

Form S-3(2)

4.1 

4.2 

4.3 

4.4 

May 10, 2017

May 10, 2017

May 10, 2017

May 10, 2017

Form 8-K

10.1 

April 10, 2018

Form 8-K

10.1 

May 14, 2019

Form 8-K

4.2 

May 14, 2019

10.1#

10.2#

10.3*

10.4#

Intercept Pharmaceuticals, Inc. 2012 Equity Incentive
Plan

Form S-1/A(3)

10.2.1

September 27, 2012

Form of Stock Option Grant Notice and Agreement for
Directors

Form S-1/A(3)

10.2.2

September 27, 2012

Form of Stock Option Grant Notice and Agreement for
Employees and Consultants

Form of Restricted Stock Unit Award Grant Notice and
Agreement for Directors

Form S-1/A(3)

10.2.4

September 27, 2012

103

    
    
 
Table of Contents

10.5*

10.6#

10.7#

10.8*

10.9#

Form of Restricted Stock Unit Award Grant Notice and
Agreement for Employees and Consultants

Form of Restricted Stock Award Grant Notice and
Agreement for Directors

Form of Restricted Stock Award Grant Notice and
Agreement for Employees and Consultants

Form of Performance Stock Unit Grant Notice and
Agreement

Form of Performance Share Grant Notice and
Agreement

10.10#

Amended and Restated Employment Agreement,
effective May 14, 2013, between the Registrant and
Mark Pruzanski

Form 10-Q

10.3 

May 9, 2014

Form 10-Q

10.4 

May 9, 2014

Form 10-Q

10.6 

May 10, 2018

Form 10-Q

10.5 

May 14, 2013

10.11#

Employment Agreement, effective May 3, 2016,
between the Registrant and Sandip S. Kapadia

Form 10-Q

10.1.1

August 9, 2016

10.12#

Employment Agreement, effective February 15, 2017,
between the Registrant and Jerome B. Durso

Form 10-Q

10.1 

May 10, 2017

10.13#

Employment Agreement, effective April 14, 2017,
between the Registrant and David Ford

Form 10-Q

10.1 

August 3, 2017

10.14#

Amended and Restated Employment Agreement,
effective as of November 27, 2017, between the
Registrant and David Shapiro

Form 8-K

10.2 

December 1, 2017

10.15#

Employment Agreement, effective January 22, 2018,
between the Registrant and Ryan Sullivan

Form 10-Q

10.1 

August 8, 2019

10.16#

Employment Agreement, effective February 6, 2018,
between the Registrant and Gail Cawkwell

Form 10-Q

10.2 

August 8, 2019

10.17*

Employment Agreement, effective November 19, 2019,
between the Registrant and Jason Campagna

10.18#

Form of Indemnification Agreement for directors and
executive officers of the Registrant

Form S-1(3)

10.7 

September 4, 2012

10.19

10.20

10.21

Base Call Option Confirmation, dated June 30, 2016,
between the Registrant and Royal Bank of Canada

Form 8-K

10.1 

July 6, 2016

Base Call Option Confirmation, dated June 30, 2016,
between the Registrant and UBS AG, London Branch

Form 8-K

10.3 

July 6, 2016

Base Call Option Confirmation, dated June 30, 2016,
between the Registrant and Credit Suisse Capital LLC

Form 8-K

10.5 

July 6, 2016

104

 
Table of Contents

10.22

10.23

10.24

10.25

10.26

10.27

10.28

10.29

10.30

10.31

10.32

10.33

10.34

Additional Call Option Confirmation, dated July 1,
2016, between the Registrant and Royal Bank of
Canada

Additional Call Option Confirmation, dated July 1,
2016, between the Registrant and UBS AG, London
Branch

Additional Call Option Confirmation, dated July 1,
2016, between the Registrant and Credit Suisse Capital
LLC

Form 8-K

10.2 

July 6, 2016

Form 8-K

10.4 

July 6, 2016

Form 8-K

10.6 

July 6, 2016

Lease Agreement between The Irvine Company LLC
and the Registrant, dated May 1, 2014

Form 8-K

10.1 

May 7, 2014

Second Amendment to Lease, dated as of July 19, 2016,
between the Registrant and Irvine Eastgate Office II
LLC

Third Amendment to Lease, dated as of June 21, 2018,
between the Registrant and Irvine Eastgate Office II
LLC

Fourth Amendment to Lease, dated as of October 30,
2018, between the Registrant and Irvine Eastgate Office
II LLC

Underlease between the Registrant, Intercept Pharma
Europe Ltd. and Performing Right Society, Ltd., dated
January 22, 2016

Form 10-Q

10.7 

November 9, 2016

Form 10-Q

10.1 

August 7, 2018

Form 10-Q

10.1 

November 1, 2018

Form 10-K

10.12 

February 29, 2016

Lease Agreement, dated December 7, 2016, between
the Registrant and Legacy Yards Tenant LP

Form 10-K

10.17 

March 1, 2017

First Amendment to Lease Agreement, dated June 27,
2017, between the Registrant and Legacy Yards Tenant
LP

Form 10-Q

10.1 

November 6, 2017

Second Amendment to Lease, dated June 22, 2018,
between the Registrant and Legacy Yards Tenant LP

Form 10-Q

10.2 

August 7, 2018

Third Amendment to Lease, dated November 1, 2019,
between the Registrant and Legacy Yards Tenant LP

Termination of Lease, dated December 31, 2017,
between the Registrant and One Hudson Yards Owner
LLC

Form 10-Q

10.1

November 5, 2019

Form 10-K

10.21 

February 28, 2018

10.35+

Commercial Manufacturing and Supply Agreement,
dated August 12, 2016, between the Registrant and
PharmaZell GMBH

Form 10-Q

10.8 

November 9, 2016

105

Form 10-K

10.2.1

February 28, 2018

Form S-1/A(3)

10.10 

September 27, 2012

Form 10-Q

10.1 

May 10, 2018

Form 10-Q

10.2 

May 10, 2018

Form 10-Q

10.3 

May 10, 2018

Table of Contents

10.36+

10.37+

10.38

10.39

10.40+

Amendment #1 to Manufacturing and Supply
Agreement, dated December 12, 2017, between the
Registrant and PharmaZell GMBH

Sumitomo Agreement, dated March 29, 2011, between
the Registrant and Sumitomo Dainippon Pharma Co.,
Ltd.

Amendment No. 1, dated June 8, 2011, to that certain
Sumitomo Agreement, dated March 29, 2011, between
the Registrant and Sumitomo Dainippon Pharma Co.,
Ltd.

Amendment No. 2, dated September 16, 2011, to that
certain Sumitomo Agreement, dated March 29, 2011,
between the Registrant and Sumitomo Dainippon
Pharma Co., Ltd.

Amendment No. 3, dated February 13, 2018, to that
certain Sumitomo Agreement, dated March 29, 2011,
between the Registrant and Sumitomo Dainippon
Pharma Co., Ltd.

10.41*

Letter Agreement, dated October 25, 2019, between the
Registrant and Sumitomo Dainippon Pharma Co., Ltd.

21.1*

Subsidiaries of the Registrant

23.1*

24.1*

31.1*

31.2*

32*(4)

Consent of Independent Registered Public Accounting
Firm

Power of Attorney (included in signature page to this
Annual Report on Form 10-K)

Certification of Principal Executive Officer required by
Rule 13a-14(a) or Rule 15d-14(a)

Certification of Principal Financial Officer required by
Rule 13a-14(a) or Rule 15d-14(a)

Certifications required by Rule 13a-14(b) or Rule 15d-
14(b) and Section 1350 of Chapter 63 of Title 18 of the
United States Code (18 U.S.C. 1350)

106

Table of Contents

101*

The following materials from the Registrant’s Annual
Report on Form 10-K for the year ended December 31,
2019, formatted in Inline XBRL (eXtensible Business
Reporting Language): (i) Consolidated Balance Sheets
as of December 31, 2019 and 2018, (ii) Consolidated
Statements of Operations for the Years Ended
December 31, 2019, 2018 and 2017, (iii) Consolidated
Statement of Comprehensive Loss for the Years Ended
December 31, 2019, 2018 and 2017, (iv) Consolidated
Statements of Changes in Stockholders’ Equity for the
Years Ended December 31, 2019, 2018 and 2017, (v)
Consolidated Statements of Cash Flows for the Years
Ended December 31, 2019, 2018 and 2017 and (vi)
Notes to Consolidated Financial Statements

104*

Cover Page Interactive Data File (formatted as Inline
XBRL and contained in Exhibit 101)

*

Filed herewith.

+ Confidential  treatment  has  been  received  with  respect  to  certain  portions  of  this  exhibit.  Omitted  portions  have  been

filed separately with the Securities and Exchange Commission (“SEC”).

#

Indicates a management contract or compensatory plan or arrangement.

† Unless otherwise specified, the File No. is 001-35668.

(1) Registration Statement on Form S-8 filed by the Registrant, Registration No. 333-184810.

(2) Registration Statement on Form S-1 filed by the Registrant, Registration No. 333-217861.

(3) Registration Statement on Form S-1 filed by the Registrant, Registration No. 333-183706.

(4) This certification “accompanies” the Annual Report on Form 10-K to which it relates, is not deemed filed with the SEC
and is not to be incorporated by reference into any filing of Registrant under the Securities Act of 1933, as amended, or
the Securities Exchange Act of 1934, as amended, (whether made before or after the date of the Annual Report on Form
10-K), irrespective of any general incorporation language contained in such filing.

Item 16.  Form 10-K Summary

None.

107

Table of Contents

Pursuant  to  the  requirements  of  Section  13  or  15(d)  of  the  Securities  Exchange  Act  of  1934,  the  registrant  has  duly

caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

SIGNATURES

Date: February 25, 2020

    By:/s/ Mark Pruzanski, M.D.

INTERCEPT PHARMACEUTICALS, INC.

Mark Pruzanski, M.D.
President and Chief Executive Officer
(Principal Executive Officer)

Date: February 25, 2020

By:/s/ Sandip Kapadia
Sandip Kapadia
Chief Financial Officer and Treasurer
(Principal Financial Officer and Principal Accounting Officer)

POWER OF ATTORNEY

KNOW ALL PERSONS BY THESE PRESENTS, that each person whose signature appears below hereby constitutes
and appoints Mark Pruzanski, M.D. and Sandip Kapadia, and each of them, as his or her true and lawful attorneys-in-fact and
agents, with full power of substitution and resubstitution, for him or her, and in his or her name, place and stead, in any and
all capacities, to sign any and all amendments to this Annual Report on Form 10-K, and to file the same, with all exhibits
thereto, and all other documents in connection therewith, with the Securities and Exchange Commission, granting unto each
said attorney-in-fact and agent full power and authority to do and perform each and every act and thing required or necessary
to  be  done  in  and  about  the  premises,  as  fully  and  to  all  intents  and  purposes  as  the  undersigned  could  do  in  person,  and
hereby  ratifying  and  confirming  all  that  said  attorneys-in-fact  and  agents,  or  any  of  them  or  their  or  his  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, this report has been signed below by the following

persons on behalf of the registrant and in the capacities indicated on February 25, 2020.

Signature

/s/ Mark Pruzanski, M.D.
Mark Pruzanski, M.D.

/s/ Sandip Kapadia
Sandip Kapadia

/s/ Paolo Fundarò
Paolo Fundarò

/s/ Srinivas Akkaraju, M.D., Ph.D.
Srinivas Akkaraju, M.D., Ph.D.

/s/ Luca Benatti, Ph.D.
Luca Benatti, Ph.D.

/s/ Daniel Bradbury
Daniel Bradbury

Title

President, Chief Executive Officer and Director
(Principal Executive Officer)

Chief Financial Officer and Treasurer
(Principal Financial Officer and Principal Accounting Officer)

Chairman of the Board of Directors

Director

Director

Director

108

    
Table of Contents

/s/ Keith Gottesdiener, M.D.
Keith Gottesdiener, M.D.

/s/ Nancy Miller-Rich
Nancy Miller-Rich

/s/ Gino Santini
Gino Santini

/s/ Glenn Sblendorio
Glenn Sblendorio

/s/ Daniel Welch
Daniel Welch

Director

Director

Director

Director

Director

109

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

Index to Consolidated Financial Statements

Reports of Independent Registered Public Accounting Firm
Consolidated Financial Statements:
Consolidated Balance Sheets as of December 31, 2019 and 2018
Consolidated Statements of Operations for the Years Ended December 31, 2019, 2018 and 2017
Consolidated Statements of Comprehensive Loss for the Years Ended December 31, 2019, 2018 and 2017
Consolidated Statements of Changes in Stockholders’ Equity for the Years Ended December 31, 2019, 2018 and 2017
Consolidated Statements of Cash Flows for the Years Ended December 31, 2019, 2018 and 2017
Notes to Consolidated Financial Statements

F-2

F-5
F-6
F-7
F-8
F-9
F-10

F-1

Table of Contents

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Stockholders and Board of Directors
Intercept Pharmaceuticals, Inc.:

Opinion on the Consolidated Financial Statements

We  have  audited  the  accompanying  consolidated  balance  sheets  of  Intercept  Pharmaceuticals,  Inc.  and  subsidiaries  (the
Company)  as  of  December  31,  2019  and  2018,  the  related  consolidated  statements  of  operations,  comprehensive  loss,
changes in stockholders’ equity, and cash flows for each of the years in the three year period ended December 31, 2019, and
the  related  notes  (collectively,  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  31,  2019  and  2018,  and  the
results  of  its  operations  and  its  cash  flows  for  each  of  the  years  in  the  three  year  period  ended  December  31,  2019,  in
conformity with U.S. generally accepted accounting principles.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States)
(PCAOB), the Company’s internal control over financial reporting as of December 31, 2019, based on criteria established in
Internal  Control  –Integrated  Framework  (2013)  issued  by  the  Committee  of  Sponsoring  Organizations  of  the  Treadway
Commission, and our report dated February 25, 2020 expressed an unqualified opinion on the effectiveness of the Company’s
internal control over financial reporting.

Basis for Opinion

These consolidated financial statements are the responsibility of the Company’s management. Our responsibility is to express
an opinion on these consolidated financial statements based on our audits. We are a public accounting firm registered with
the 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.

Critical Audit Matter
The critical audit matter communicated below is a matter arising from the current period audit of the consolidated financial
statements that was communicated or required to be communicated to the audit committee and that: (1) relates to accounts or
disclosures that are material to the consolidated financial statements and (2) involved our especially challenging, subjective,
or complex judgment. The communication of a critical audit matter does not alter in any way our opinion on the consolidated
financial statements, taken as a whole, and we are not, by communicating the critical audit matter below, providing a separate
opinion on the critical audit matter or on the accounts or disclosures to which it relates.

Evaluation of certain assumptions impacting rebates and discounts, and other incentives accruals
As  described  in  Notes  2  and  8  to  the  consolidated  financial  statements,  the  Company  records  net  product  revenue  by
deducting  various  rebates  and  discounts,  and  other  incentives.  The  rebates  and  discounts  are  related  to  contracts  with  the
Center for Medicare & Medicaid Services and other government programs, and other incentives are offers to certain indirect
customers that include co-pay assistant cards provided by the Company for patients who reside in states that permit co-pay
assistance  programs.  The  rebates  and  discounts,  and  other  incentives  are  estimated  and  accrued  with  a  corresponding
reduction  of  gross  product  revenues  when  revenue  is  recognized.  As  of  December  31,  2019,  the  Company  had  a  $22.0
million  balance  in  rebates  and  discounts,  and  other  incentives  accruals,  which  are  recorded  in  accounts  payable,  accrued
expenses and other liabilities on the consolidated balance sheet.

We  identified  the  evaluation  of  the  rebates  and  discounts,  and  other  incentives  accruals,  as  a  critical  audit  matter  because
evaluating the Company’s assumptions involved especially challenging auditor judgment. Rebates and discounts are based
on assumptions developed using historical experience including actual payments and redemptions, regulations, specific terms
in  individual  agreements,  product  pricing,  channels,  and  pipeline  units.  For  other  incentives,  a  key  assumption  is  the
estimation of co-pay assistance provided to eligible patients based on redemption information provided by third-party claims
processing organizations.

F-2

Table of Contents

The primary procedures we performed to address this critical audit matter included the following. We tested certain internal
controls over the Company’s rebates and discounts, and other incentives accrual process, including controls related to the key
assumptions  used  in  the  Company’s  estimation  of  its  rebates  and  discounts,  and  other  incentives.  We  evaluated  the
Company’s ability to estimate rebates and discounts, and other incentives by comparing the previously recorded accruals to
the actual amounts that were settled and ultimately paid by the Company. We compared the Company’s key assumptions to
the Company’s internal accruals using historical experience including actual payments and redemptions, regulations, specific
terms  in  individual  agreements,  product  pricing,  channels,  and  pipeline  units.  We  performed  a  sensitivity  analysis  using
independently-developed assumptions utilizing third-party information and the historical trend of actual rebate claims paid
and compared them to the Company’s accruals.

We conducted our audits 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.  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/ KPMG LLP

We have served as the Company’s auditor since 2008.

New York, New York
February 25, 2020

F-3

Table of Contents

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Stockholders and Board of Directors
Intercept Pharmaceuticals, Inc.:

Opinion on Internal Control Over Financial Reporting

We have audited Intercept Pharmaceuticals, Inc.’s and subsidiaries (the Company) internal control over financial reporting as
of  December  31,  2019,  based  on  criteria  established  in  Internal  Control  –Integrated  Framework  (2013)  issued  by  the
Committee  of  Sponsoring  Organizations  of  the  Treadway  Commission.  In  our  opinion,  the  Company  maintained,  in  all
material respects, effective internal control over financial reporting as of December 31, 2019, based on criteria established in
Internal  Control  –Integrated  Framework  (2013)  issued  by  the  Committee  of  Sponsoring  Organizations  of  the  Treadway
Commission.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States)
(PCAOB),  the  consolidated  balance  sheets  of  the  Company  as  of  December  31,  2019  and  2018,  the  related  consolidated
statements of operations, comprehensive loss, changes in stockholders’ equity, and cash flows for each of the years in the
three-year period ended December 31, 2019, and the related notes (collectively, the “consolidated financial statements”), and
our report dated February 25, 2020 expressed an unqualified opinion on those consolidated financial statements.

Basis for Opinion

The  Company’s  management  is  responsible  for  maintaining  effective  internal  control  over  financial  reporting  and  for  its
assessment  of  the  effectiveness  of  internal  control  over  financial  reporting,  included  in  the  accompanying  Management’s
Report on Internal Control Over Financial Reporting. Our responsibility is to express an opinion on the Company’s internal
control  over  financial  reporting  based  on  our  audit.  We  are  a  public  accounting  firm  registered  with  the  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 audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform
the audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in
all  material  respects.  Our  audit  of  internal  control  over  financial  reporting  included  obtaining  an  understanding  of  internal
control over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and
operating  effectiveness  of  internal  control  based  on  the  assessed  risk.  Our  audit  also  included  performing  such  other
procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable basis for our
opinion.

Definition and Limitations of Internal Control Over Financial Reporting

A  company’s  internal  control  over  financial  reporting  is  a  process  designed  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. A company’s internal control over financial reporting includes those policies and procedures
that  (1)  pertain  to  the  maintenance  of  records  that,  in  reasonable  detail,  accurately  and  fairly  reflect  the  transactions  and
dispositions  of  the  assets  of  the  company;  (2)  provide  reasonable  assurance  that  transactions  are  recorded  as  necessary  to
permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and
expenditures  of  the  company  are  being  made  only  in  accordance  with  authorizations  of  management  and  directors  of  the
company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or
disposition of the company’s assets that could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also,
projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate
because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

/s/ KPMG LLP

New York, New York
February 25, 2020

F-4

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

Consolidated Balance Sheets

Assets

Current assets:

Cash and cash equivalents
Restricted cash
Investment debt securities, available-for-sale
Accounts receivable
Prepaid expenses and other current assets

Total current assets

Fixed assets, net
Inventory
Security deposits
Other assets

Total assets

Current liabilities:

Liabilities and Stockholders’ Equity

Accounts payable, accrued expenses and other liabilities
Short-term interest payable
Short-term portion of deferred revenue

Total current liabilities

Long-term liabilities:

Long-term debt
Long-term other liabilities
Long-term portion of deferred revenue

Total liabilities

Commitments and contingencies (Note 16)
Stockholders’ equity:

Common stock par value $0.001 per share; 45,000,000 shares authorized;
32,853,066 and 29,693,876 shares issued and outstanding as of December 31, 2019
and December 31, 2018, respectively
Additional paid-in capital
Accumulated other comprehensive loss, net
Accumulated deficit

Total stockholders’ equity
Total liabilities and stockholders’ equity

December 31, 

2019

2018

     (in thousands, except share and per share data)

$

$

$

$

$

70,055
4,725
582,567
38,044
25,924
721,315
5,202
8,462
6,661
13,246
754,886

153,968
8,037

$

$

$

—  

162,005

532,078
9,247

—  
$

703,330

43,248
—
392,912
25,694
20,571
482,425
10,411
7,108
9,223
—
509,167

105,109
7,475
1,621
114,205

371,250
3,771
811
490,037

33
2,176,133
(1,144)
(2,123,466)
51,556
754,886

$

30
1,800,144
(2,259)
(1,778,785)
19,130
509,167

See accompanying notes to consolidated financial statements.

F-5

 
    
  
 
    
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
  
 
 
 
 
 
 
  
 
  
 
 
 
 
 
 
  
 
  
 
 
 
 
 
 
 
 
 
 
Table of Contents

Revenue:
Product revenue, net
Licensing revenue
Total revenue

Operating expenses:

Cost of sales
Selling, general and administrative
Research and development
Total operating expenses
Operating loss

Other income (expense):

Interest expense
Other income, net

INTERCEPT PHARMACEUTICALS, INC.

Consolidated Statements of Operations

2019

Years Ended December 31, 
2018
(in thousands, except per share data)

2017

$

$

249,570
2,432
252,002

$

177,782
2,022
179,804

129,175
1,781
130,956

4,212
317,418
242,799
564,429
(312,427)

(41,144)
8,890
(32,254)
(344,681)

(10.89)

$

$

2,519
255,474
207,301
465,294
(285,490)

(30,523)
6,771
(23,752)
(309,242)

(10.86)

$

$

1,371
273,698
191,499
466,568
(335,612)

(29,271)
4,516
(24,755)
(360,367)

(14.38)

$

$

Net loss
Net loss per common and potential common share:

Basic and diluted

Weighted average common and potential common shares outstanding:

Basic and diluted

31,654

28,464

25,054

See accompanying notes to consolidated financial statements.

F-6

    
    
    
    
    
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
 
  
 
  
 
 
 
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

Consolidated Statements of Comprehensive Loss

Net loss
Other comprehensive income (loss):
   Net changes related to available-for-sale investment debt securities:
     Unrealized gains on investment debt securities
     Reclassification adjustment for realized gains on investment debt securities   

included in other income, net

   Net unrealized gains on investment debt securities
     Foreign currency translation gains (losses)
Other comprehensive income (loss)
Comprehensive loss

2019

Years Ended December 31, 
2018
(in thousands)
$ (344,681) $ (309,242) $ (360,367)

2017

1,509

88

791

$

$

(8)
1,501
(379)
1,122

—
791
1,225
2,016
$ (343,559) $ (310,715) $ (358,351)

(8)
80
(1,553)
(1,473)

$

See accompanying notes to consolidated financial statements.

F-7

    
    
    
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

Consolidated Statements of Changes in Stockholders’ Equity

For the Years Ended December 31, 2019, 2018 and 2017
(in thousands)

Common Stock

Paid-in

Comprehensive

Accumulated

Stockholders’

Additional

Other

Total

Accumulated

Balance - December 31, 2016
Stock-based compensation
Net proceeds from exercise of stock
options
Other comprehensive income
Net loss
Balance - December 31, 2017
Stock-based compensation
Issuance of common stock from public
and private placement offerings, net of
underwriting fees and issuance costs
Net proceeds from exercise of stock
options
Employee withholding taxes related to
stock-based awards
Other comprehensive loss
Net loss
Balance - December 31, 2018
Stock-based compensation
Recognition of debt discount on 2026
Convertible Notes
Issuance of common stock from public
and private placement offerings, net of
underwriting fees and issuance costs
Net proceeds from exercise of stock
options
Employee withholding taxes related to
stock-based awards
Other comprehensive income
Net loss
Balance - December 31, 2019

Shares      Amount     
$
24,820

25

—   —  

Capital
$ 1,426,168
56,968

$

Loss

Deficit

Equity

(2,801) $ (1,108,460) $ 314,932
56,968

—  

—  

—

353
—   —  
—   —  

2,838
716
—  
$

$ 1,486,690
49,914

—
2,015

—  

—
(716)
(360,367)

(786) $ (1,469,543) $

—

—

—

—

—

—

—
(1,473)
—

—
—
(309,242)

$

(2,259) $ (1,778,785) $

—

—

—

—

—

—

—

—

261,357

4,363

(2,180)
—
—
$ 1,800,144

55,982

85,915

227,257

8,993

(2,158)
—
—
$ 2,176,133

—
1,115
—

—
—
(344,681)

$

(1,144) $ (2,123,466) $

2,838
2,015
(360,367)
16,386
49,914

261,362

4,363

(2,180)
(1,473)
(309,242)
19,130

55,982

85,915

227,260

8,993

(2,158)
1,115
(344,681)
51,556

$

25,173
—

4,258

263

—
—
—
29,694

—

—

2,880

279

—
—
—
32,853

$

$

25
—

5

—

—
—
—
30

—

—

3

—

—
—
—
33

See accompanying notes to consolidated financial statements.

F-8

    
    
    
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

Consolidated Statements of Cash Flows

Cash flows from operating activities:

Net loss
Adjustments to reconcile net loss to net cash used in operating activities:
Stock-based compensation
(Accretion) amortization of (discount) premium on investment debt securities
Amortization of deferred financing costs
Realized loss on investments
Depreciation
Non-cash operating lease cost
Gain on lease termination
Loss on the disposal of fixed assets
Accretion of debt discount
Changes in operating assets:

Accounts receivable
Prepaid expenses and other current assets
Inventory
Security deposits
Other assets

Changes in operating liabilities:

Accounts payable, accrued expenses and other current liabilities
Operating lease liabilities
Interest payable
Deferred revenue
Long-term other liabilities

Net cash used in operating activities

Cash flows from investing activities:

2019

Years Ended December 31, 
2018
(in thousands)

2017

$ (344,681) $ (309,242) $ (360,367)

55,982
(302)
2,130
—
3,663
5,388
(1,995)
2,682
21,189

(12,350)
(5,353)
(1,354)
2,562
(24,665)

49,914
(33)
1,542
8
4,582
—
—
1,331
14,031

(9,193)
(3,682)
(3,628)
7,153
—

56,411
(6,767)
562
(2,432)
12,717
  (236,613)

10,332
—
—
(2,022)
(1,807)
  (240,714)

56,968
3,429
1,417
—
4,601
—
—
1,000
12,904

(7,375)
(7,535)
(1,201)
1,438
—

29,226
—
208
(5,693)
5,578
(265,402)

(231,107)
529,274
(10,392)
287,775

Purchases of investment debt securities
Sales and maturities of investment debt securities
Purchases of equipment, leasehold improvements, and furniture and fixtures
Net cash (used in) provided by investing activities

  (603,014)
415,162
(1,136)
  (188,988)

  (436,071)
388,168
(167)
(48,070)

Cash flows from financing activities:

Proceeds from issuance of 2026 Convertible Notes, net of issuance costs
Proceeds from issuance of common stock, net of issuance costs
Proceeds from exercise of options, net
Payments of employee withholding taxes related to stock-based awards

Net cash provided by financing activities

Effect of exchange rate changes on cash, cash equivalents and restricted cash
Net increase (decrease) in cash, cash equivalents and restricted cash

Cash, cash equivalents and restricted cash at beginning of period
Cash, cash equivalents and restricted cash at end of period

Reconciliation of cash, cash equivalents and restricted cash included in the
consolidated balance sheets:
Cash and cash equivalents
Restricted cash
Total cash, cash equivalents and restricted cash

223,424
227,260
8,993
(2,158)
457,519
(386)
31,532
43,248
74,780

70,055
4,725
74,780

—
261,362
4,363
(2,180)
263,545
(1,526)
(26,765)
70,013
43,248

43,248
—
43,248

$

$

$

$

$

$

$

$

$

—
—
2,838
—
2,838
1,127
26,338
43,675
70,013

70,013
—
70,013

See accompanying notes to consolidated financial statements

F-9

    
    
    
 
    
    
  
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

1. Overview of Business

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

Intercept  Pharmaceuticals,  Inc.  (the  “Company”)  is  a  biopharmaceutical  company  focused  on  the  development  and
commercialization  of  novel  therapeutics  to  treat  progressive  non-viral  liver  diseases,  including  primary  biliary  cholangitis
(“PBC”)  and  nonalcoholic  steatohepatitis  (“NASH”).  The  Company  currently  has  one  marketed  product,  Ocaliva
(obeticholic acid or “OCA”). Founded in 2002 in New York, the Company has operations in the United States, Europe and
Canada.

2. Summary of Significant Accounting Policies

Basis of Presentation and Principles of Consolidation

The Company’s financial statements have been prepared in conformity with accounting principles generally accepted in
the United States of America (“U.S. GAAP”). The consolidated financial statements include the accounts of the Company
and its wholly owned subsidiaries. All intercompany balances and transactions have been eliminated in consolidation. The
Company has no unconsolidated subsidiaries or investments accounted for under the equity method.

Use of Estimates

The preparation of these financial statements in conformity with U.S. GAAP requires management to make estimates
and judgments that affect the reported amounts of assets and liabilities at the date of the consolidated financial statements and
the reported amounts of revenues and expenses during the reporting period. Actual results could differ from these estimates.

Foreign Currency

The Company’s functional and reporting currency is the U.S. dollar. Transactions in foreign currencies are recorded at
the exchange rate prevailing on the date of the transaction. The resulting monetary assets and liabilities are translated into
U.S.  dollars  at  exchange  rates  prevailing  on  the  subsequent  balance  sheet  date.  Revenue  and  expense  components  are
translated to U.S. dollars at weighted-average exchange rates in effect during the period. Foreign currency transaction gains
and  losses  resulting  from  remeasurement  are  recognized  in  Other  income,  net  within  the  consolidated  statements  of
operations.  Gains  and  losses  as  a  result  of  foreign  currency  translation  adjustments  are  recorded  as  a  component  of
Accumulated other comprehensive loss, net in the equity section of our consolidated balance sheets and as Foreign currency
translation gains (losses) within the accompanying consolidated statements of comprehensive loss.

Cash and Cash Equivalents

The  Company  considers  all  highly  liquid  securities  with  an  original  or  remaining  maturity  of  three  months  or  less  at

acquisition to be cash equivalents.

Restricted Cash

Restricted  cash  consists  of  short-term  bank  guarantees  held  by  our  financial  institutions  to  maintain  operations  of  the

Company’s subsidiaries in their respective countries.

Investment Debt Securities, Available-for-Sale

Investment debt securities are considered to be available-for-sale and are carried at fair market value. The estimated fair
value  of  the  available-for-sale  investment  debt  securities  is  determined  based  on  quoted  market  prices  or  rates  for  similar
instruments. Unrealized gains and losses, if any, are reported in accumulated other comprehensive income (loss).

F-10

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

The cost of investment debt securities is adjusted for amortization of premiums and accretion of discounts to maturity. Such
amortization and accretion is included in Other income, net. Realized gains and losses, and declines in value judged to be
other-than-temporary, if any, are also included in Other income, net. Interest and dividends on available-for-sale securities are
included in Other income, net.

Fair Value of Financial Instruments

The  carrying  amounts  of  certain  financial  instruments,  including  cash  and  cash  equivalents,  restricted  cash,  accounts
receivable, prepaid expenses and other current assets, accounts payable, accrued expenses and other liabilities approximate
fair value due to their short-term maturities.

Concentration of Credit Risk

Financial  instruments,  which  potentially  subject  the  Company  to  concentrations  of  credit  risk,  principally  consist  of

cash, cash equivalents, accounts receivables from customers and investment debt securities.

The Company currently invests its excess cash primarily in money market funds, U.S. Treasury notes, and high quality,
marketable debt instruments of corporations, financial institutions and government sponsored enterprises. The Company has
adopted  an  investment  policy  that  includes  guidelines  relative  to  credit  quality,  diversification  and  maturities  to  preserve
principal and liquidity.

On a consolidated basis, for the year ended December 31, 2019, the Company’s three largest customers (as discussed in
more detail below under “Revenue Recognition”) accounted for 32%, 31% and 15%, of the Company’s net product sales,
respectively.  On  a  consolidated  basis,  for  the  year  ended  December  31,  2018,  the  Company’s  three  largest  customers  (as
discussed  in  more  detail  below  under  “Revenue  Recognition”)  accounted  for  38%,  28%  and  16%,  of  the  Company’s  net
product sales, respectively.

On a consolidated basis, the Company’s three largest customers accounted for 27%, 28% and 7% of the December 31,
2019 accounts receivable balance, respectively. On a consolidated basis, the Company’s three largest customers accounted
for  22%,  29%  and  6%  of  the  December  31,  2018  accounts  receivable  balance,  respectively.  We  monitor  our  customers’
financial credit worthiness in order to assess and respond to any changes in their credit profile.

Accounts Receivable

The Company extends credit to customers based on its evaluation of the customer’s financial condition. The Company
records receivables for all billings when amounts are due under standard terms. Accounts receivable are stated at amounts
due net of applicable prompt pay discounts and other contractual adjustments as well as an allowance for doubtful accounts.
The Company assesses the need for an allowance for doubtful accounts by considering a number of factors, including the
length  of  time  trade  accounts  receivable  are  past  due,  the  customer’s  ability  to  pay  its  obligation  and  the  condition  of  the
general  economy  and  the  industry  as  a  whole.  The  Company  will  write  off  accounts  receivable  when  the  Company
determines that they are uncollectible. The Company has recorded $38.0 million and $25.7 million of accounts receivable as
of  December  31,  2019  and  2018,  respectively,  and  has  not  recorded  an  allowance  for  any  doubtful  accounts  as  of
December 31, 2019 and 2018.

Fixed Assets

Fixed assets are stated at cost, and depreciated over the estimated useful life of the assets. Depreciation is recorded using
the  straight-line  method  over  the  estimated  useful  lives  of  the  respective  assets,  generally  three  to  seven  years.  Leasehold
improvements  are  amortized  over  the  shorter  of  the  asset’s  useful  life  or  the  life  of  the  lease  term.  Expenditures  for
maintenance and repairs are charged to expense as incurred. Upon sale or retirement of assets, the cost of the assets

F-11

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

disposed of and the related accumulated depreciation are removed from the balance sheets and any related gains or losses are
reflected in the consolidated statements of operations.

Impairment of Long-Lived Assets

Long-lived  assets  consist  of  fixed  assets  and  right-of-use  assets.  The  Company  evaluates  long-lived  assets  for
impairment when events and circumstances indicate that the carrying amount of an asset or group of assets may not be fully
recoverable. If indicators of impairment exist, the Company assesses the recoverability of the affected long-lived assets by
determining whether the carrying value of such assets can be recovered through undiscounted future operating cash flows. If
the  carrying  amount  is  not  recoverable,  the  Company  measures  the  amount  of  any  impairment  by  comparing  the  carrying
value of the asset to the present value of the expected future cash flows associated with the use of the asset. There have been
no impairments of any long-lived assets in the periods presented.

Inventory

Inventories are stated at the lower of cost or estimated realizable value. The Company determines the cost of inventory
using  the  first-in,  first-out  (or  FIFO)  method.  The  Company  capitalizes  inventory  costs  associated  with  the  Company's
product after regulatory approval when, based on management's judgment, future commercialization is considered probable
and the future economic benefit is expected to be realized; otherwise, such costs are expensed as research and development.
The Company periodically analyzes its inventory levels to identify inventory that may expire prior to expected sale or has a
cost  basis  in  excess  of  its  estimated  realizable  value,  and  writes-down  such  inventories  as  appropriate.  In  addition,  the
Company's  product  is  subject  to  strict  quality  control  and  monitoring  which  the  Company  performs  throughout  the
manufacturing process. If certain batches or units of product no longer meet quality specifications or become obsolete due to
expiration,  the  Company  records  a  charge  to  cost  of  sales  to  write  down  such  unmarketable  inventory  to  zero.  No  such
charges were recorded in the years ended December 31, 2019, 2018 or 2017.

Leases

Upon  adoption  of  Accounting  Standards  Codification  (“ASC”)  Topic  842,  Leases  (“ASC  842”),  the  Company
determines  if  an  arrangement  is  a  lease  at  inception  and  records  right-of-use  (“ROU”)  assets  and  lease  liabilities  on  the
consolidated balance sheets at lease commencement based on the present value of remaining lease payments over the lease
term. The Company only considers payments that are fixed and determinable at the time of commencement. Operating leases
are  included  in  other  assets,  accounts  payable,  accrued  expenses  and  other  liabilities  and  long-term  other  liabilities  on  the
consolidated balance sheets.

Operating lease liabilities are recognized based on the present value of the future minimum lease payments discounted
by  the  Company’s  incremental  borrowing  rate.  The  Company  measures  ROU  assets  based  on  the  corresponding  lease
liability adjusted for (i) payments made to the lessor at or before the commencement date, (ii) initial direct costs incurred and
(iii) tenant incentives under the lease. The Company’s lease terms may include options to extend or terminate the lease when
it  is  reasonably  certain  that  it  will  exercise  that  option.  Lease  expense  for  minimum  lease  payments  is  recognized  on  a
straight-line basis over the lease term.

For  short-term  leases,  the  Company  records  rent  expense  in  its  consolidated  statements  of  operations  on  a  straight-

line basis over the lease term and records variable lease payments as incurred.

Convertible Debt

The Company accounts for convertible debt in accordance with Financial Accounting Standards Board (“FASB”) ASC
Subtopic  470-20.  The  Company  separately  accounts  for  the  liability  (debt)  and  equity  (conversion  option)  components  of
convertible debt instruments by allocating the proceeds from the issuance. The value assigned to the debt

F-12

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

component is the estimated fair value, as of the issuance date, of a similar debt instrument without the conversion option. The
amount  of  the  equity  component  (and  resulting  debt  discount)  is  calculated  by  deducting  the  fair  value  of  the  liability
component  from  the  principal  amount  of  the  convertible  debt  instrument.  The  resulting  debt  discount  is  amortized  as
additional non-cash interest expense over the expected life of the notes utilizing the effective interest method. For additional
information, see Note 9 — Long-Term Debt.

Revenue Recognition

Product Revenue, Net

The Company commenced its commercial launch of Ocaliva for the treatment of PBC in the United States in June 2016.
In  December  2016,  the  European  Commission  granted  conditional  approval  for  Ocaliva  for  the  treatment  of  PBC  and  the
Company  commenced  its  European  commercial  launch  in  January  2017.  Since  January  2017,  Ocaliva  has  also  received
regulatory  approval  in  several  of  the  Company’s  target  markets  outside  the  United  States  and  Europe,  including  Canada,
Israel  and  Australia.  The  Company  sells  Ocaliva  to  a  limited  number  of  specialty  pharmacies  which  dispense  the  product
directly to patients. The specialty pharmacies are referred to as the Company’s customers.

The Company provides the right of return to its customers for unopened product for a limited time before and after its
expiration date. Prior to July 2017, given the Company’s limited sales history for Ocaliva and the inherent uncertainties in
estimating product returns, the Company determined that the shipments of Ocaliva made to its customers did not meet the
criteria for revenue recognition at the time of shipment. Accordingly, the Company recognized revenue when the product was
sold through by its customers, provided all other revenue recognition criteria were met. The Company invoiced its customers
upon  shipment  of  Ocaliva  to  them  and  recorded  accounts  receivable,  with  a  corresponding  liability  for  deferred  revenue
equal  to  the  gross  invoice  price.  The  Company  then  recognized  revenue  when  Ocaliva  was  sold  through  as  specialty
pharmacies dispensed product directly to the patients (sell-through basis).

The Company re-evaluated its revenue recognition policy in the third quarter of 2017, which included the accumulation
and  review  of  customer-related  transactions  since  the  Company’s  commercial  launch  in  the  second  quarter  of  2016.  The
Company  concluded  it  had  accumulated  sufficient  data  to  reasonably  estimate  product  returns  and,  therefore,  began  to
recognize  revenue  at  the  time  of  shipment  to  its  customers  (sell-in  basis).  During  the  third  quarter  of  2017,  the  Company
recorded  an  adjustment  related  to  this  change  in  estimate  to  recognize  previously  deferred  revenue.  The  net  effect  was  an
increase in net sales of Ocaliva of $4.1 million for the year ended December 31, 2017. The Company also established a new
reserve of $0.7 million during 2017 related to future returns from its customers.

Effective January 1, 2018, the Company began recognizing revenue under ASC Topic 606, Revenue from Contracts with
Customers (“ASC 606”). The core principle of this revenue standard is that a company should recognize revenue to depict
the transfer of promised goods or services to customers in an amount that reflects the consideration to which the company
expects  to  be  entitled  in  exchange  for  those  goods  or  services.  The  following  five  steps  are  applied  to  achieve  that  core
principle:

● Step 1: Identify the contract with the customer

● Step 2: Identify the performance obligations in the contract

● Step 3: Determine the transaction price

● Step 4: Allocate the transaction price to the performance obligations in the contract

● Step 5: Recognize revenue when the company satisfies a performance obligation

F-13

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

In  order  to  identify  the  performance  obligations  in  a  contract  with  a  customer,  a  company  must  assess  the  promised
goods or services in the contract and identify each promised good or service that is distinct. A performance obligation meets
ASC 606’s definition of a “distinct” good or service (or bundle of goods or services) if both of the following criteria are met:

● The customer can benefit from the good or service either on its own or together with other resources that are readily

available to the customer (i.e., the good or service is capable of being distinct).

● The entity’s promise to transfer the good or service to the customer is separately identifiable from other promises in

the contract (i.e., the promise to transfer the good or service is distinct within the context of the contract).

If a good or service is not distinct, the good or service is combined with other promised goods or services until a bundle

of goods or services is identified that is distinct.

The transaction price is the amount of consideration to which an entity expects to be entitled in exchange for transferring
promised goods or services to a customer, excluding amounts collected on behalf of third parties (for example, some sales
taxes).  The  consideration  promised  in  a  contract  with  a  customer  may  include  fixed  amounts,  variable  amounts,  or  both.
Variable consideration is included in the transaction price only to the extent that it is probable that a significant reversal in the
amount of cumulative revenue recognized will not occur when the uncertainty associated with the variable consideration is
subsequently resolved.

The  transaction  price  is  allocated  to  each  performance  obligation  on  a  relative  standalone  selling  price  basis.  The
transaction price allocated to each performance obligation is recognized when that performance obligation is satisfied, at a
point in time or over time as appropriate.

Under ASC 606, the Company has written contracts with each of its customers that have a single performance obligation
— to deliver products upon receipt of a customer order — and these obligations are satisfied when delivery occurs and the
customer  receives  Ocaliva.  The  Company  evaluates  the  creditworthiness  of  each  of  its  customers  to  determine  whether
collection is reasonably assured. The Company estimates variable revenue by calculating gross product revenues based on
the  wholesale  acquisition  cost  that  the  Company  charges  its  customers  for  Ocaliva,  and  then  estimating  its  net  product
revenues by deducting (i) trade allowances, such as invoice discounts for prompt payment and customer fees, (ii) estimated
government rebates and discounts related to Medicare, Medicaid and other government programs, and (iii) estimated costs of
incentives offered to certain indirect customers including patients.

Trade Allowances

The Company provides invoice discounts on Ocaliva sales to certain of its customers for prompt payment and records

these discounts as a reduction to gross product revenues. These discounts are based on contractual terms.

Rebates and Discounts

The  Company  contracts  with  the  Centers  for  Medicare  &  Medicaid  Services  and  other  government  agencies  to  make
Ocaliva  available  to  eligible  patients.  As  a  result,  the  Company  estimates  any  rebates  and  discounts  and  deducts  these
estimated  amounts  from  its  gross  product  revenues  at  the  time  the  revenues  are  recognized.  The  Company’s  estimates  of
rebates and discounts are based on the government mandated discounts, which are statutorily-defined and applicable to these
government  funded  programs  and  assumptions  developed  using  historical  experience  along  with  actual  payments  and
redemptions, government regulations, specific terms in individual agreements, product pricing, channels, and pipeline units.
The Company recorded $20.3 million and $10.8 million in such estimates as of December 31, 2019 and December 31, 2018,
respectively, in accounts payable, accrued expenses and other liabilities on the consolidated balance sheets.

F-14

Table of Contents

Other Incentives

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

Other  incentives  that  the  Company  offers  to  indirect  customers  include  co-pay  assistance  cards  provided  by  the
Company for PBC patients who reside in states that permit co-pay assistance programs. The Company’s co-pay assistance
program is intended to reduce each participating patient’s portion of the financial responsibility for Ocaliva purchase price to
a specified dollar amount. The Company estimates the amount of co-pay assistance provided to eligible patients based on the
terms of the program when product is dispensed by the specialty pharmacies to the patients. These estimates are based on
redemption  information  provided  by  third-party  claims  processing  organizations.  The  Company  recorded  $1.2  million  and
$0.9 million in such estimates as of December 31, 2019 and December 31, 2018, respectively, in accounts payable, accrued
expenses and other liabilities on the consolidated balance sheets.

 Because the Company changed its revenue recognition polices to the sell-in basis during the year ended December 31,
2017, the adoption of ASC 606, via a modified retrospective approach applied to all contracts not completed at January 1,
2018,  did  not  result  in  an  adjustment  to  amounts  previously  recognized  as  revenue  under  ASC  Topic  605,  Revenue
Recognition (“ASC 605”).

Licensing Revenue

The  Company  accounts  for  the  development,  regulatory  and  sales  milestones  within  an  arrangement  as  variable
consideration that is included in the transaction price only to the extent that it is probable that a significant reversal in the
amount of cumulative revenue recognized will not occur when the uncertainty associated with the variable consideration is
subsequently resolved. Because the achievement of the milestones triggering these payments is highly susceptible to factors
outside  the  entity’s  influence,  and  the  uncertainty  about  the  amount  of  consideration  for  some  of  the  milestones  is  not
expected  to  be  resolved  for  a  long  period  of  time,  the  Company  does  not  expect  to  record  the  associated  revenue  until
achievement of each milestone is imminent or has already occurred. Adoption of ASC 606 did not result in any adjustment to
licensing revenue previously recognized.

Research and Development Expenses

Research and development costs that do not have alternative future use are charged to expense as incurred. This includes
the cost of conducting clinical trials, compensation and related overhead for employees and consultants involved in research
and  development  and  the  cost  of  the  Company’s  manufacturing  activities  to  supply  ongoing  and  future  clinical  trials  and
preclinical studies as well as preparations for commercialization of OCA. The cost of a compound that is acquired prior to
regulatory approval, does not constitute a business and has no alternative future use is charged to expense as incurred. For
periods prior to commercial launch, all manufacturing costs for OCA were expensed as research and development expenses.
The  Company  will  continue  to  incur  manufacturing  costs  for  OCA  for  other  indications  such  as  NASH  prior  to  their
approval.

Stock-based Compensation

The Company accounts for stock-based compensation to employees, non-employee directors and non-employees granted
share-based payments for services in accordance with ASC Topic 718, Compensation — Stock Compensation (“ASC 718”).
The Company estimates the fair value of stock option awards using the Black-Scholes option pricing model on the date of the
grant. Restricted stock unit awards (“RSUs”) and restricted stock awards (“RSAs”) without a market condition are valued
based  on  the  closing  price  of  the  Company’s  common  stock  on  the  date  of  the  grant.  The  fair  value  of  time-based  equity
awards  is  recognized  and  amortized  on  a  straight-line  basis  over  the  requisite  service  period  of  the  award.  Stock  options
granted to employees generally fully vest over four years and have a term of ten years. The Company recognizes stock-based
compensation expense for options and other stock-based awards with performance conditions ratably over the performance
period once the pre-defined performance-based criteria for vesting becomes probable. The fair value of awards with market
conditions is estimated using the Monte Carlo simulation method and expense is

F-15

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

recognized on a straight-line basis over the requisite service period of the award. The Company accounts for all forfeitures
when they occur.

Net Loss Per Share

Basic loss per share is computed by dividing net loss attributable to common stockholders (numerator) by the weighted
average number of common shares outstanding (denominator) during the period. Potential common shares include the shares
of common stock issuable upon the exercise of outstanding stock options and vesting of restricted stock units. The Company
accounts for the effect of the Convertible Notes on diluted net earnings per share using the if-converted method as they may
be settled in cash or shares at the Company’s option. Diluted net loss per share is the same as basic net loss per share, since
the effects of potentially dilutive securities are antidilutive given our net losses.

Income Taxes

The  Company  utilizes  the  asset  and  liability  method  of  accounting  for  income  taxes.  Under  this  method,  deferred  tax
assets and liabilities are determined based on the difference between the financial statement carrying amounts and tax bases
of assets and liabilities using enacted tax rates in effect for years in which the temporary differences are expected to reverse.
The Company establishes a valuation allowance when it believes it is more likely than not that deferred tax assets will not be
realized.

The Company determines the need for a valuation allowance by assessing the probability of realizing deferred tax assets,
taking into consideration all available positive and negative evidence, including historical operating results, expectations of
future taxable income, carryforward periods available, various income tax strategies and other relevant factors. Significant
judgment is required in making this assessment and to the extent future expectations change, the Company would have to
assess the recoverability of its deferred assets at that time.

At any one time the Company’s tax returns for numerous tax years are subject to examination by U.S. Federal, state, and
foreign taxing jurisdictions. The impact of an uncertain tax position taken or expected to be taken on an income tax return
must be recognized in the financial statements at the largest amount that is more likely than not to be sustained. An uncertain
income tax position will not be recognized in the financial statements unless it is more likely than not to be sustained.

Segments

The Company operates in one segment focused on the development and commercialization of novel therapeutics to treat

progressive non-viral liver diseases.

Recently Adopted Accounting Pronouncements

In  February  2016,  the  FASB  established  ASC  842,  by  issuing  ASU  No.  2016-02,  which  requires  lessees  to  recognize
leases on-balance sheet and disclose key information about leasing arrangements. ASC 842 was subsequently amended by
ASU  No.  2018-01,  “Land  Easement  Practical  Expedient  for  Transition  to  Topic  842”;  ASU  No.  2018-10,  “Codification
Improvements  to  Topic  842,  Leases”;  and  ASU  No.  2018-11,  “Targeted  Improvements”.  The  new  standard  establishes  a
right-of-use model that requires a lessee to recognize a ROU asset and lease liability on the balance sheet for all leases with a
term longer than 12 months. Leases will be classified as finance or operating, with classification affecting the pattern and
classification  of  expense  recognition  in  the  statements  of  operations.  A  modified  retrospective  transition  approach  is
required, applying the new standard to all leases existing at the date of initial application. An entity may choose to use either
(1) its effective date or (2) the beginning of the earliest comparative period presented in the financial statements as its date of
initial application. The Company adopted the new standard on January 1, 2019 using the effective date as the date of initial
application. Consequently, financial information was not updated and the disclosures required under the new

F-16

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

standard was not provided for dates and periods before January 1, 2019. The new standard provides a number of optional
practical expedients in transition. The Company elected the “package of practical expedients”, which permits the Company
to not reassess under the new standard the Company’s prior conclusions about lease identification, lease classification and
initial direct costs. The new standard also provides practical expedients for an entity’s ongoing accounting. The Company
elected the short-term lease recognition exemption for all leases that qualify. This means, for those leases that qualify, the
Company did not recognize ROU assets or lease liabilities, and this includes not recognizing ROU assets or lease liabilities
for existing short-term leases of those assets in transition. The Company also elected the practical expedient to not separate
lease and non-lease components for all of the Company’s leases. Upon adoption at January 1, 2019, the Company recognized
additional operating liabilities of $25.4 million, with corresponding ROU assets of $19.6 million based on the present value
of the remaining minimum rental payments under current leasing standards for existing operating leases.

In June 2016, the FASB issued ASU No. 2016-13, “Financial Instruments-Credit Losses: Measurement of Credit Losses
on Financial Instruments” (“ASU 2016-13”), which replaces the incurred loss impairment methodology under current U.S.
GAAP with a methodology that reflects expected credit losses and requires consideration of a broader range of reasonable
and supportable information to inform credit loss estimates. ASU 2016-13 was subsequently updated by ASU No. 2019-04,
“Codification Improvements to Topic 326, Financial Instruments—Credit Losses, Topic 815, Derivatives and Hedging, and
Topic 825, Financial Instruments”, to clarify that entities should include recoveries when estimating the allowance for credit
losses. The Company will be required to use a forward-looking expected credit loss model for accounts receivables, loans
and other financial instruments. Credit losses relating to available-for-sale investment debt securities will also be recorded
through an allowance for credit losses rather than as a reduction in the amortized cost basis of the securities. This guidance is
effective  for  fiscal  years,  and  interim  periods  within  those  fiscal  years,  beginning  after  December  15,  2019  and  must  be
adopted using a modified retrospective approach, with certain exceptions. The Company adopted ASU 2016-13 on January
1, 2020 and its adoption will not have any material impact on the Company’s consolidated financial statements and related
disclosures.

In  July  2017,  the  FASB  issued  ASU  No.  2017-11,  “Earnings  Per  Share  (Topic  260),  Distinguishing  Liabilities  from
Equity (Topic 480) and Derivatives and Hedging (Topic 815): I. Accounting for Certain Financial Instruments with Down
Round  Features;  II.  Replacement  of  the  Indefinite  Deferral  for  Mandatorily  Redeemable  Financial  Instruments  of  Certain
Nonpublic  Entities  and  Certain  Mandatorily  Redeemable  Noncontrolling  Interests  with  a  Scope  Exception”  (“ASU  2017-
11”). Part I of this update addresses the complexity of accounting for certain financial instruments with down round features.
Down round features are features of certain equity-linked instruments (or embedded features) that result in the strike price
being reduced on the basis of the pricing of future equity offerings. Current accounting guidance creates cost and complexity
for  entities  that  issue  financial  instruments  (such  as  warrants  and  convertible  instruments)  with  down  round  features  that
require fair value measurement of the entire instrument or conversion option. Part II of this update addresses the difficulty of
navigating ASC Topic 480, Distinguishing Liabilities from Equity, because of the existence of extensive pending content in
the  FASB  Accounting  Standards  Codification.  This  pending  content  is  the  result  of  the  indefinite  deferral  of  accounting
requirements  about  mandatorily  redeemable  financial  instruments  of  certain  nonpublic  entities  and  certain  mandatorily
redeemable noncontrolling interests. The amendments in Part II of this update do not have an accounting effect. This ASU is
effective for fiscal years, and interim periods within those years, beginning after December 15, 2018. The Company adopted
ASU  2017-11  on  January  1,  2019  and  its  adoption  did  not  have  any  impact  on  the  Company’s  consolidated  financial
statements and related disclosures.

In June 2018, the FASB issued ASU No. 2018-07, “Improvements to Nonemployee Share-Based Payment Accounting”
(“ASU  2018-07”),  which  simplifies  the  accounting  for  share-based  payments  granted  to  nonemployees  for  goods  and
services. Under this ASU, most of the guidance on such payments to nonemployees would be aligned with the requirements
for share-based payments granted to employees. The changes take effect for public companies for fiscal years starting after
December 15, 2018, including interim periods within that fiscal year. For all other entities, the amendments are effective for
fiscal years beginning after December 15, 2019, and interim periods within fiscal years beginning after December 15, 2020.
Early adoption is permitted, but no earlier than an entity’s adoption date of ASC 606. The Company

F-17

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

adopted ASU 2018-07 on January 1, 2019 and its adoption did not have a material impact on the Company’s consolidated
financial statements and related disclosures.

In August 2018, the FASB issued ASU No. 2018-13, “Fair Value Measurement (Topic 820): Disclosure Framework –
Changes to the Disclosure Requirements for Fair Value Measurement” (“ASU 2018-13”), which makes a number of changes
meant  to  add,  modify  or  remove  certain  disclosure  requirements  associated  with  the  movement  amongst  or  hierarchy
associated with Level 1, Level 2 and Level 3 fair value measurements. This guidance is effective for fiscal years, and interim
periods  within  those  fiscal  years,  beginning  after  December  15,  2019.  Early  adoption  is  permitted  upon  issuance  of  the
update. The Company adopted ASU 2018-13 on January 1, 2020 and its adoption did not have any impact on the Company’s
consolidated financial statements and related disclosures.

Recent Accounting Pronouncements to be Adopted

In  December  2019,  the  FASB  issued  ASU  No.  2019-12,  “Income  Taxes  (Topic  740):  Simplifying  the  Accounting  for
Income Taxes (“ASU 2019-12”), which is intended to simplify various aspects related to accounting for income taxes. ASU
2019-12 removes certain exceptions to the general principles in Topic 740 and also clarifies and amends existing guidance to
improve  consistent  application.  This  guidance  is  effective  for  fiscal  years,  and  interim  periods  within  those  fiscal  years,
beginning after December 15, 2020, with early adoption permitted. The Company is currently evaluating the impact of this
standard on its consolidated financial statements and related disclosures.

3. Significant Agreements

Sumitomo Dainippon Pharma Co., Ltd.

In March 2011, the Company entered into an exclusive license agreement (the “Original Sumitomo Agreement”) with
Sumitomo  Dainippon  Pharma  Co.,  Ltd.  (“Sumitomo  Dainippon”),  pursuant  to  which  the  Company  granted  to  Sumitomo
Dainippon an exclusive license to research, develop and commercialize OCA for the treatment of PBC and NASH in Japan
and  China  (excluding  Taiwan)  and  an  option  to  research,  develop  and  commercialize  OCA  in  certain  countries  outside  of
such  territories  (the  “Country  Option”).  The  Company  received  an  upfront  payment  from  Sumitomo  Dainippon  of  $15.0
million  under  the  terms  of  the  Original  Sumitomo  Agreement.  In  May  2014,  Sumitomo  Dainippon  exercised  the  Country
Option in part to add Korea as part of its licensed territories and paid the Company a $1.0 million upfront fee in connection
therewith.  In  February  2018,  the  Company  and  Sumitomo  Dainippon  entered  into  Amendment  No.  3  (the  “Sumitomo
Amendment”)  to  the  Original  Sumitomo  Agreement  (as  amended,  the  “Sumitomo  Agreement”),  pursuant  to  which  (i)
Sumitomo  Dainippon  agreed  to  return  the  rights  to  develop  and  commercialize  OCA  in  Japan  and  Korea  and  waived  its
rights  to  the  Country  Option,  (ii)  the  Company  agreed  to  forego  any  further  milestone  or  royalty  payments  relating  to  the
development and commercialization of OCA in Japan and Korea and (iii) certain milestone payment obligations with respect
to the development and commercialization of OCA were adjusted. In October 2019, the Company and Sumitomo Dainippon
mutually  agreed  to  terminate  with  immediate  effect  the  Sumitomo  Agreement.  In  connection  with  the  termination  of  the
Sumitomo Agreement, Sumitomo Dainippon agreed to return to the Company the rights to develop and commercialize OCA
in  China  and  the  Company  agreed  to  forego  any  further  milestone  or  royalty  payments  relating  to  the  development  and
commercialization  of  OCA  in  China.  No  payment  is  due  from  the  Company  to  Sumitomo  Dainippon  as  a  result  of  the
termination of the Sumitomo Agreement.

The Company has concluded that Sumitomo Dainippon does not represent a customer of the Company, and therefore the
Sumitomo Agreement is outside of the scope of ASC 606. The Company has accounted for this agreement under the legacy
accounting  guidance.  Under  ASC  605,  the  Company  evaluated  this  agreement  and  determined  that  it  is  a  revenue
arrangement  with  multiple  deliverables,  or  performance  obligations.  The  Company’s  substantive  performance  obligations
under this agreement include an exclusive license to its technology, technical and scientific support to the development plan
and  participation  on  a  joint  steering  committee.  The  Company  determined  that  these  performance  obligations  represent  a
single unit of accounting, since, initially, the license does not have stand-alone value to Sumitomo Dainippon

F-18

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

without the Company’s technical expertise and steering committee participation during the development of OCA. During the
years ended December 31, 2019, 2018 and 2017, the Company recorded licensing revenue of approximately $2.4 million,
$2.0 million and $1.8 million, respectively, under this agreement. Included in licensing revenue for the year ended December
31,  2019  is  $1.2  million  related  to  the  accelerated  recognition  as  a  result  of  the  termination  of  the  Sumitomo  Agreement.
Included in licensing revenue for the year ended December 31, 2018 is $0.4 million related to the accelerated recognition, as
a result of the Sumitomo Amendment, of the remaining portion of deferred revenue associated with the $1.0 million upfront
payment  that  the  Company  received  under  the  Original  Sumitomo  Agreement  in  connection  with  Sumitomo  Dainippon’s
exercise  of  the  Country  Option  with  respect  to  Korea.  The  Company  recognizes  milestone  payments  when  the  associated
milestones are achieved.

As of December 31, 2019, and 2018, the Company had recorded deferred revenues of $0 and $2.4 million, respectively,

under this agreement.

4. Cash, Cash Equivalents and Investments

The following table summarizes the Company’s cash, cash equivalents and investments as of December 31, 2019 and

December 31, 2018:

Cash and cash equivalents:
Cash and money market funds
Commercial paper

Total cash and cash equivalents

Investment debt securities:
Commercial paper
Corporate debt securities

Total investment debt securities

Total cash, cash equivalents and investment debt
securities

Cash and cash equivalents:
Cash and money market funds
Investment debt securities:
Commercial paper
Corporate debt securities
U.S. government and agency securities

Total investment debt securities

     Amortized Cost    

As of December 31, 2019
Gross
Gross
Unrealized
Unrealized
Losses
Gains

(in thousands)

Fair Value

$

$

62,557
7,498
70,055

— $
—
—

— $
—
—

62,557
7,498
70,055

42,806
538,965
581,771

43
835
878

(1)
(81)
(82)

42,848
539,719
582,567

$

651,826

$

878

$

(82)

$

652,622

     Amortized Cost    

As of December 31, 2018
Gross
Gross
Unrealized
Unrealized
Losses
Gains

(in thousands)

Fair Value

$

43,248

$

— $

— $

43,248

34,353
349,854
9,410
393,617

—  
27
5
32

(26)
(704)
(7)
(737)

34,327
349,177
9,408
392,912

Total cash, cash equivalents and investment debt
securities

$

436,865

$

32

$

(737)

$

436,160

F-19

    
    
 
    
    
    
  
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
    
    
 
    
    
    
  
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

The Company held zero and twenty-four positions that were in a continuous unrealized loss position for twelve months
or longer as of December 31, 2019 and 2018, respectively. The Company believes that the unrealized losses generally are
caused by increases in the risk premiums required by market participants rather than an adverse change in cash flows or a
fundamental weakness in the credit quality of the issuer or underlying assets. Because the Company has the ability and intent
to  hold  these  investments  until  a  recovery  of  fair  value,  which  may  be  maturity,  it  did  not  consider  the  investments  to  be
other-than-temporarily impaired at December 31, 2018.

The  fair  value  for  the  Company’s  available-for-sale  investment  debt  securities  that  have  been  in  an  unrealized  loss

position for less than twelve months or twelve months or longer is as follows:

Commercial paper
Corporate debt securities
Total

Less than 12 months

Gross
Unrealized

As of December 31, 2019
12 months or longer
(in thousands)

Gross
Unrealized

Total

Gross
Unrealized

     Fair Value      Losses

     Fair Value      Losses

     Fair Value      Losses

$ 50,346
  539,719
$ 590,065

$

$

(1) $ — $
—  
(81)
(82) $ — $

— $ 50,346
—   539,719
— $ 590,065

$

$

(1)
(81)
(82)

Less than 12 months

Gross
Unrealized

     Fair Value      Losses

As of December 31, 2018
12 months or longer
(in thousands)

     Gross

Unrealized

     Fair Value      Losses
— $

Total

     Gross

Unrealized

     Fair Value      Losses

(26) $
(443)

  56,626
1,991
(469) $ 58,617

—  

$

(261)
(7)

— $ 34,327
  317,173
1,991
(268) $ 353,491

$

$

(26)
(704)
(7)
(737)

Commercial paper
Corporate debt securities
U.S. government and agency securities
Total

$ 34,327
  260,547

$

—  
$

$ 294,874

5. Fixed Assets, Net

Fixed  assets  are  stated  at  cost  and  depreciated  or  amortized  using  the  straight-line  method  based  on  useful  lives  as

follows:

Office equipment and software
Leasehold improvements
Furniture and fixtures
Subtotal

Less: accumulated depreciation

Fixed assets, net

Useful lives
(Years)

3

  Shorter of remaining lease term or useful life

7

December 31, 

2019

2018

(in thousands)

$
4,386
  10,489
4,032
  18,907
  (13,705)
5,202
$

$

3,986
14,464
3,907
22,357
(11,946)
$ 10,411

Depreciation expense for the years ended December 31, 2019, 2018 and 2017 was approximately $3.7 million, $4.6

million and $4.6 million, respectively.

F-20

 
 
 
    
    
    
 
 
 
 
 
 
 
    
    
    
 
 
 
 
 
 
 
Table of Contents

6. Inventory

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

Inventories are stated at the lower of cost or market. Inventories consisted of the following:

Work-in-process
Finished goods
Inventory

7. Leases

December 31,

2019

2018

(in thousands)

8,302
160
8,462

$

$

7,019
89
7,108

$

$

The  Company  leases  various  office  spaces  under  non-cancelable  operating  leases  with  original  lease  periods  expiring
between the third quarter in 2020 and 2024. The Company subleases one of its office spaces to a third party. The Company
also enters into leases for equipment. A number of the Company’s leases include one or more options to renew, with renewal
terms that can extend the lease term. The exercise of lease renewal options is typically at the sole discretion of the Company;
therefore,  all  renewals  to  extend  the  lease  terms  are  not  included  in  the  ROU  assets  and  lease  liabilities  as  they  are  not
reasonably certain of exercise. The Company regularly evaluates the renewal options and when they are reasonably certain of
exercise,  includes  the  renewal  period  in  the  lease  term.  These  operating  leases  do  not  contain  material  variable  rent
payments, residual value guarantees, covenants, or other restrictions.

The Company has elected the practical expedient to exclude short-term leases from its ROU assets and lease liabilities;
therefore leases with an initial term of 12 months or less are not recorded on the balance sheet. The Company recognizes
lease expense for these leases on a straight-line basis over the lease term. The Company elected the practical expedient not to
separate non-lease components from all leases. As the Company’s leases do not provide an implicit rate, the Company uses
an incremental borrowing rate based on the information available at the lease commencement date in determining the present
value of the lease payments. The Company’s incremental borrowing rate is the estimated rate that would be required to pay
for a collateralized borrowing equal to the total lease payment over the lease term. The Company estimates its incremental
borrowing rate based on an analysis of publicly traded debt securities of companies with credit and financial profiles similar
to its own.

Operating lease assets and liabilities are classified on the consolidated balance sheet as follows:

Leases
Assets
Operating lease assets
Total leased assets

Liabilities
Current
Operating lease liabilities

Noncurrent
Operating lease liabilities
Total lease liabilities

Classification

Other assets

Accounts payable, accrued expenses and
other liabilities

Long-term other liabilities

F-21

December 31, 2019

(in thousands)

$
$

$

$

13,246
13,246

6,456

9,222
15,678

    
    
 
 
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

Operating lease costs for the year ended December 31, 2019 are as follows:

Lease Cost

Classification

Operating lease cost
Short-term lease cost
Variable lease cost
Sublease income
Net lease cost

Selling, general and administrative expenses
Selling, general and administrative expenses
Selling, general and administrative expenses
Other income, net

$

$

Year Ended

December 31, 2019

(in thousands)

6,176
2,203
829
(788)
8,420

The  weighted-average  remaining  term  of  the  Company’s  operating  leases  was  2.7  years  and  the  weighted-average
discount rate used to measure the present value of the Company’s operating lease liabilities was 4.0% as of December 31,
2019.

Maturities of the Company’s operating lease liabilities, which do not include short-term leases, as of December 31, 2019

are as follows:

Maturity of Lease Liabilities

2020
2021
2022
2023
2024
Thereafter
Total lease payments
Less: Present value discount
Total operating lease liabilities

Operating leases

(in thousands)

6,949
5,978
2,269
965
402
—
16,563
(885)
15,678

$

$

Cash  payments  included  in  the  measurement  of  the  Company’s  lease  liabilities  were  $7.5  million  for  the  year  ended

December 31, 2019.

8. Accounts Payable, Accrued Expenses and Other Liabilities

Accounts payable, accrued expenses and other liabilities consisted of the following:

2019

December 31, 

(in thousands)

2018

Accounts payable
Accrued employee compensation
Accrued contracted services
Accrued rebates, discounts and other incentives
Operating lease liabilities
Other liabilities
Accounts payable, accrued expenses and other liabilities

$

$

18,975
26,483
74,486
21,529
6,456
6,039
153,968

$

$

11,765
20,335
54,681
11,673
—
6,655
105,109

F-22

    
 
 
 
 
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

Research & Development Tax Credit

The Company benefits from the U.K. Small and Medium-sized Enterprise R&D Tax Credit scheme, or the SME scheme,
under which it can obtain a refundable credit of up to 33.4% of eligible research and development expenses incurred by the
Company in the U.K.. Eligible expenses generally include employment costs for research staff, consumables, software and
certain internal overhead costs incurred as part of research projects.

The Company submitted a claim seeking to obtain tax credits for qualifying R&D expenses incurred in the years ended
December  31,  2015  and  2016.  In  September  2019,  the  Company  received  a  partial  payment  of  $10.5  million  from  Her
Majesty’s  Revenue  and  Customs,  the  U.K.’s  government  tax  authority.  Given  the  claim  review  has  not  been  finalized,  the
credit received is recorded as a deferred liability within accounts payable, accrued expenses and other liabilities.

9. Long-Term Debt

Debt, net of discounts and deferred financing costs, consisted of the following:

2023 Convertible Notes
2026 Convertible Notes
Long-term debt, gross

Less: Unamortized debt discounts and fees

Long-term debt, net

2019 Offering

December 31,

2019

2018

(in thousands)

$

$

460,000
230,000
690,000
(157,922)
532,078

$

$

460,000
—
460,000
(88,750)
371,250

On May 14, 2019, the Company issued and sold $230.0 million aggregate principal amount of 2.00% Convertible Senior
Notes due 2026 (the “2026 Convertible Notes”). The Company received net proceeds from the sale of the 2026 Convertible
Notes  of  $223.4  million,  after  deducting  underwriting  discounts,  commissions  and  estimated  offering  expenses  of
approximately $6.6 million.

The 2026 Convertible Notes were issued pursuant to a Second Supplemental Indenture, dated as of May 14, 2019 (the
“Second  Supplemental  Indenture”),  which  supplements  the  Indenture  (the  “Base  Indenture”),  as  supplemented  by  a  First
Supplemental  Indenture  (the  “First  Supplemental  Indenture”  and  collectively  with  the  Base  Indenture  and  the  Second
Supplemental  Indenture,  the  “Indenture”),  each  dated  as  of  July  6,  2016,  by  and  between  the  Company  and  U.S.  Bank
National Association, as trustee. The 2026 Convertible Notes are senior unsecured obligations of the Company, bear interest
at  a  fixed  rate  of  2.00%  per  annum  (payable  semi-annually  on  May  15  and  November  15  of  each  year,  beginning  on
November  15,  2019)  and  will  mature  on  May  15,  2026,  unless  earlier  repurchased,  redeemed  or  converted.  Holders  may
convert  their  2026  Convertible  Notes  at  their  option  at  any  time  prior  to  the  close  of  business  on  the  business  day
immediately preceding February 15, 2026 only under the following circumstances: (i) during any calendar quarter (and only
during such calendar quarter) commencing after the calendar quarter ended on September 30, 2019, if the last reported sale
price  of  the  Company’s  common  stock  for  at  least  20  trading  days  (whether  or  not  consecutive)  during  a  period  of  30
consecutive trading days ending on the last trading day of the immediately preceding calendar quarter is greater than or equal
to  130%  of  the  conversion  price  on  each  applicable  trading  day;  (ii)  during  the  five  business  day  period  after  any  five
consecutive trading day period in which the trading price (as defined in the Indenture) per $1,000 principal amount of 2026
Convertible Notes for each trading day of such five consecutive trading day period was less than 98% of the product of the
last  reported  sale  price  of  the  Company’s  common  stock  and  the  conversion  rate  on  each  such  trading  day;  (iii)  if  the
Company  calls  any  or  all  of  the  2026  Convertible  Notes  for  redemption,  at  any  time  prior  to  the  close  of  business  on  the
scheduled trading day immediately preceding the redemption date; or (iv) upon the occurrence of specified corporate

F-23

    
    
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

events.  On  or  after  February  15,  2026  until  the  close  of  business  on  the  business  day  immediately  preceding  the  maturity
date,  holders  may  convert  their  2026  Convertible  Notes  at  any  time,  regardless  of  the  foregoing  circumstances.  Upon
conversion  of  the  2026  Convertible  Notes,  the  Company  will  pay  or  deliver,  as  the  case  may  be,  cash,  shares  of  the
Company’s common stock (and cash in lieu of any fractional shares) or a combination of cash and shares of the Company’s
common stock, at the Company’s election. The initial conversion rate of the 2026 Convertible Notes is 9.2123 shares of the
Company’s  common  stock  per  $1,000  principal  amount  of  2026  Convertible  Notes,  which  is  equivalent  to  an  initial
conversion  price  of  approximately  $108.55  per  share  of  the  Company’s  common  stock.  The  conversion  rate  is  subject  to
adjustment  in  some  events  but  will  not  be  adjusted  for  any  accrued  and  unpaid  interest.  In  addition,  following  certain
corporate events that occur prior to the maturity date, the Company will increase the conversion rate for a holder who elects
to convert its 2026 Convertible Notes in connection with such a corporate event in certain circumstances. The Company may
not redeem the 2026 Convertible Notes prior to May 20, 2023. The Company may redeem for cash all or any portion of the
2026 Convertible Notes, at the Company’s option, on or after May 20, 2023, if the last reported sale price of the Company’s
common  stock  has  been  at  least  130%  of  the  conversion  price  then  in  effect  for  at  least  20  trading  days  (whether  or  not
consecutive)  during  any  30  consecutive  trading  day  period  (including  the  last  trading  day  of  such  period)  ending  on,  and
including,  the  trading  day  immediately  preceding  the  date  on  which  the  Company  provides  notice  of  redemption  at  a
redemption price equal to 100% of the principal amount of the 2026 Convertible Notes to be redeemed, plus accrued and
unpaid interest to, but excluding, the redemption date. No sinking fund is provided for the 2026 Convertible Notes. If the
Company undergoes a fundamental change (as defined in the Indenture), holders may require the Company to repurchase for
cash  all  or  any  portion  of  their  2026  Convertible  Notes  at  a  fundamental  change  repurchase  price  equal  to  100%  of  the
principal amount of the 2026 Convertible Notes to be repurchased, plus accrued and unpaid interest to, but excluding, the
fundamental change repurchase date. The Indenture provides for customary events of default.

In accordance with ASC Subtopic 470-20, “Debt with Conversion and Other Options” (“ASC 470-20”), the Company
used an effective interest rate of 9.9% to determine the liability component of the 2026 Convertible Notes. This resulted in
the recognition of $137.5 million as the liability component of the 2026 Convertible Notes and the recognition of the residual
$85.9 million as the debt discount with a corresponding increase to additional paid-in capital for the equity component of the
2026  Convertible  Notes.  The  underwriting  discount  and  estimated  offering  expenses  totaling  $6.6  million  were  allocated
between the debt and equity issuance costs in proportion to the allocation of the liability and equity components of the 2026
Convertible Notes. Accordingly, equity issuance costs of $2.5 million were recorded as an offset to additional paid-in capital
and total debt issuance costs of $4.1 million were recorded on the issuance date and are reflected in the consolidated balance
sheet as a direct deduction from the carrying value of the associated debt liability. The debt discount and debt issuance costs
will be amortized as non-cash interest expense through May 15, 2026.

The  fair  value  of  the  2026  Convertible  Notes  was  approximately  $294.9  million  at  December  31,  2019  and  was

determined using Level 2 inputs based on quoted market values.

2016 Offerings

On July 6, 2016, the Company issued and sold $460.0 million aggregate principal amount of 3.25% Convertible Senior
Notes due 2023 (the “2023 Convertible Notes”, and together with the 2026 Convertible Notes, the “Convertible Notes”). The
Company received net proceeds from the sale of the 2023 Convertible Notes of $447.6 million, after deducting underwriting
discounts, commissions and estimated offering expenses of approximately $12.4 million. The Company used approximately
$38.4 million of such net proceeds to fund the cost of the Capped Call Transactions (as defined below) that were entered into
in connection with the issuance of the 2023 Convertible Notes.

The  2023  Convertible  Notes  were  issued  pursuant  to  the  Base  Indenture,  as  supplemented  by  the  First  Supplemental
Indenture.  The  2023  Convertible  Notes  are  senior  unsecured  obligations  of  the  Company,  bear  interest  at  a  fixed  rate  of
3.25% per year (payable semi-annually on January 1 and July 1 of each year, beginning on January 1, 2017) and will mature
on  July  1,  2023,  unless  earlier  repurchased,  redeemed  or  converted.  Holders  may  convert  their  2023  Convertible  Notes  at
their option at any time prior to the close of business on the business day immediately preceding

F-24

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

January  1,  2023  only  under  the  following  circumstances:  (i)  during  any  calendar  quarter  commencing  after  the  calendar
quarter ended on September 30, 2016, if the last reported sale price of the Company’s common stock for at least 20 trading
days  (whether  or  not  consecutive)  during  the  period  of  30  consecutive  trading  days  ending  on  the  last  trading  day  of  the
immediately preceding calendar quarter is greater than or equal to 130% of the conversion price on each applicable trading
day;  (ii)  during  the  five  business  day  period  after  any  five  consecutive  trading  day  period  in  which  the  trading  price  (as
defined  in  the  Indenture)  per  $1,000  principal  amount  of  2023  Convertible  Notes  for  each  trading  day  of  such  five
consecutive trading day period was less than 98% of the product of the last reported sale price of the Company’s common
stock and the conversion rate on each such trading day; (iii) if the Company calls any or all of the 2023 Convertible Notes for
redemption, at any time prior to the close of business on the scheduled trading day immediately preceding the redemption
date; or (iv) upon the occurrence of specified corporate events. On or after January 1, 2023 until the close of business on the
second scheduled trading day immediately preceding the maturity date, holders may convert their 2023 Convertible Notes at
any time, regardless of the foregoing circumstances. Upon conversion of the 2023 Convertible Notes, the Company will pay
or deliver, as the case may be, cash, shares of the Company’s common stock (and cash in lieu of any fractional shares) or a
combination of cash and shares of the Company’s common stock, at the Company’s election. The initial conversion rate of
the  2023  Convertible  Notes  is  5.0358  shares  of  the  Company’s  common  stock  per  $1,000  principal  amount  of  2023
Convertible Notes, which is equivalent to an initial conversion price of approximately $198.58 per share of the Company’s
common stock. The conversion rate is subject to adjustment upon the occurrence of certain events but will not be adjusted for
any accrued and unpaid interest. If the Company undergoes a fundamental change (as defined in the Indenture), holders may
require  the  Company  to  repurchase  for  cash  all  or  any  portion  of  their  2023  Convertible  Notes  at  a  fundamental  change
repurchase price equal to 100% of the principal amount of the 2023 Convertible Notes to be repurchased, plus accrued and
unpaid interest to, but excluding, the fundamental change repurchase date. In addition, if certain make-whole fundamental
changes  occur,  the  Company  will,  in  certain  circumstances,  increase  the  conversion  rate  for  any  2023  Convertible  Notes
converted in connection with such make-whole fundamental change. The Company may not redeem the 2023 Convertible
Notes prior to July 6, 2021. The Company may redeem for cash all or part of the 2023 Convertible Notes, at its option, on or
after July 6, 2021, if the last reported sale price of the Company’s common stock has been at least 130% of the conversion
price then in effect for at least 20 trading days (whether or not consecutive) during any 30 consecutive trading day period
(including the last trading day of such period) ending on, and including, the trading day immediately preceding the date on
which the Company provides notice of redemption at a redemption price equal to 100% of the principal amount of the 2023
Convertible Notes to be redeemed, plus accrued and unpaid interest to, but excluding, the redemption date. The Indenture
provides for customary events of default.

On June 30, 2016, in connection with the pricing of the 2023 Convertible Notes, the Company entered into privately-
negotiated capped call transactions (the “Base Capped Call Transactions”) with each of Royal Bank of Canada, UBS AG,
London  Branch,  and  Credit  Suisse  Capital  LLC  (the  “Option  Counterparties”).  On  July  1,  2016,  in  connection  with  the
underwriters’  exercise  of  their  over-allotment  option  in  full,  the  Company  entered  into  additional  capped  call  transactions
(the  “Additional  Capped  Call  Transactions”  and,  together  with  the  Base  Capped  Call  Transactions,  the  “Capped  Call
Transactions”) with the Option Counterparties. The Capped Call Transactions are expected generally to reduce the potential
dilution with respect to the Company’s common stock and/or offset the cash payments the Company would be required to
make in excess of the principal amount of converted 2023 Convertible Notes, as the case may be, upon conversion of the
2023 Convertible Notes in the event that the market price per share of the Company’s common stock, as measured under the
terms  of  the  Capped  Call  Transactions,  is  greater  than  the  strike  price  of  the  Capped  Call  Transactions,  which  initially
corresponds to the conversion price of the 2023 Convertible Notes and is subject to anti-dilution adjustments substantially
similar  to  those  applicable  to  the  conversion  rate  of  the  2023  Convertible  Notes.  The  cap  price  of  the  Capped  Call
Transactions  is  initially  $262.2725  per  share,  and  is  subject  to  certain  adjustments  under  the  terms  of  the  Capped  Call
Transactions. If, however, the market price per share of the Company’s common stock, as measured under the terms of the
Capped Call Transactions, exceeds the cap price of the Capped Call Transactions, there would nevertheless be dilution and/or
there would not be an offset of such potential cash payments, in each case, upon conversion of the Convertible Notes to the
extent that such market price exceeds the cap price of the Capped Call Transactions.

F-25

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

In  accordance  with  ASC  470-20,  the  Company  used  an  effective  interest  rate  of  8.4%  to  determine  the  liability
component of the 2023 Convertible Notes. This resulted in the recognition of $334.4 million as the liability component of the
2023 Convertible Notes and the recognition of the residual $113.1 million as the debt discount with a corresponding increase
to additional paid-in capital for the equity component of the 2023 Convertible Notes.

The  fair  value  of  the  2023  Convertible  Notes  was  approximately  $463.5  million  and  $410.9  million  at  December  31,

2019 and December 31, 2018, respectively, and was determined using Level 2 inputs based on quoted market values.

Interest Expense on Convertible Notes

Interest expense was $41.1 million, $30.5 million, and $29.3 million for the years ended December 31, 2019, 2018 and
2017,  respectively,  related  to  the  Convertible  Notes.  Accrued  interest  on  the  Convertible  Notes  was  approximately  $8.1
million  and  $7.5  million  as  of  December  31,  2019  and  December  31,  2018,  respectively.  The  Company  recorded  debt
issuance costs of $19.0 million, which are being amortized using the effective interest method. As of December 31, 2019 and
2018, $13.2 million and $8.8 million, respectively, of debt issuance costs are recorded on the consolidated balance sheets in
Long-term debt, in accordance with ASU No. 2015-03, “Interest – Imputation of Interest (Subtopic 835-30): Simplifying the
Presentation  of  Debt  Issuance  Costs.”  As  of  December  31,  2019,  $230.0  million  aggregate  principal  amount  of  the  2026
Convertible Notes and $460.0 million aggregate principal amount of the 2023 Convertible Notes was outstanding, for a total
of $690.0 million aggregate principal amount outstanding.

10. Product Revenue, Net

The Company recognized net sales of Ocaliva of $249.6 million, $177.8 million and $129.2 million for the years ended

December 31, 2019, 2018 and 2017, respectively.

The table below summarizes consolidated product revenue, net by region:

Product revenue, net:

U.S.
ex-U.S.

Total product revenue, net

11. Fair Value Measurements

2019

Years Ended December 31, 
2018
(in thousands)

2017

$

$

187,436
62,134
249,570

$

$

140,822
36,960
177,782

$

$

115,807
13,368
129,175

The  carrying  amounts  of  the  Company’s  receivables  and  payables  approximate  their  fair  value  due  to  their  short

maturities.

Accounting principles provide guidance for using fair value to measure assets and liabilities. The guidance includes a

three-level hierarchy of valuation techniques used to measure fair value, defined as follows:

● Unadjusted Quoted Prices — The fair value of an asset or liability is based on unadjusted quoted prices in

active markets for identical assets or liabilities (Level 1).

● Pricing  Models  with  Significant  Observable  Inputs  — The  fair  value  of  an  asset  or  liability  is  based  on
information derived from either an active market quoted price, which may require further adjustment based
on the attributes of the financial asset or liability being measured, or an inactive market transaction (Level
2).

F-26

    
    
    
 
    
    
  
 
 
 
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

● Pricing Models with Significant Unobservable Inputs — The fair value of an asset or liability is primarily
based on internally derived assumptions surrounding the timing and amount of expected cash flows for the
financial instrument. Therefore, these assumptions are unobservable in either an active or inactive market
(Level 3).

The  Company  considers  an  active  market  as  one  in  which  transactions  for  the  asset  or  liability  occur  with  sufficient
frequency  and  volume  to  provide  pricing  information  on  an  ongoing  basis.  Conversely,  the  Company  views  an  inactive
market as one in which there are few transactions for the asset or liability, the prices are not current, or price quotations vary
substantially either over time or among market makers. Where appropriate, non-performance risk, or that of a counterparty, is
considered in determining the fair values of liabilities and assets, respectively.

The Company’s cash deposits and money market funds are classified within Level 1 of the fair value hierarchy because
they  are  valued  using  bank  balances  or  quoted  market  prices.  Investments  are  classified  as  Level  2  instruments  based  on
market pricing and other observable inputs.

Financial assets carried at fair value are classified in the tables below in one of the three categories described above:

December 31, 2019
Assets
Cash and cash equivalents:

Money market funds
Commercial paper

Available-for-sale investment debt securities:

Commercial paper
Corporate debt securities

Total financial assets

December 31, 2018
Assets
Money market funds (included in cash and cash equivalents)
Available-for-sale investment debt securities:

Commercial paper
Corporate debt securities
U.S. government and agency securities

Total financial assets

Total

     Level 1

     Level 2

     Level 3

Fair Value Measurements Using

(in thousands)

$ 19,376
7,498

$ 19,376
—

$

— $

7,498

42,848
  539,719
$ 609,441

42,848
—  
—   539,719
$ 590,065

$ 19,376

$

$ 11,647

$ 11,647

$

— $

34,327
  349,177
9,408
$ 404,559

—  
34,327
—   349,177
9,408
—  
$ 392,912

$ 11,647

$

—
—

—
—
—

—

—
—
—
—

The  gross  realized  gains  and  losses  on  sales  of  available-for-sale  investment  debt  securities  were  immaterial  for  the

fiscal years ended December 31, 2019, 2018, and 2017.

F-27

    
 
    
    
    
  
 
    
    
    
  
 
  
 
  
 
  
 
  
 
 
 
 
 
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
 
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

The estimated fair value of marketable debt securities (commercial paper, corporate debt securities and U.S. government

and agency securities) as of December 31, 2019 and 2018, respectively, by contractual maturity, are as follows:

Due in one year or less
Due after one year through two years
Total investments in debt securities

Fair Value as of December 31, 

2019

2018

(in thousands)

$

$

473,602
116,463
590,065

$

$

319,717
73,195
392,912

Actual maturities may differ from contractual maturities because issuers may have the right to call or prepay obligations

without call or prepayment penalties.

12. Stockholders’ Equity and Preferred Stock

2019 Public Offering and Concurrent Private Placement

On May 14, 2019, the Company issued and sold (i) 2,760,000 shares of common stock in a registered public offering
(including 360,000 shares issued and sold upon the exercise in full of the underwriters’ option to purchase additional shares),
at a price to the public of $83.50 per share (the “2019 Public Offering”) and (ii) 119,760 shares of common stock (the “2019
Private Placement Shares”) in a concurrent private placement of common stock (the “2019 Concurrent Private Placement”)
exempt from the registration requirements of the Securities Act of 1933, as amended (the “Securities Act”), at a purchase
price  per  share  equivalent  to  the  price  to  the  public  set  in  the  2019  Public  Offering  and  pursuant  to  a  securities  purchase
agreement  (the  “2019  Securities  Purchase  Agreement”)  that  the  Company  entered  into  with  Samsara  BioCapital,  L.P.
(“Samsara”),  one  of  the  Company’s  existing  stockholders.  Pursuant  to  the  2019  Securities  Purchase  Agreement,  the
Company granted to Samsara certain registration rights requiring the Company, upon request of Samsara on or after July 9,
2019 and subject to certain terms and conditions, to register the resale by Samsara of its 2019 Private Placement Shares. Such
registration rights expire upon the earlier of (i) May 8, 2020 and (ii) the date that all of the 2019 Private Placement Shares
have been sold or can be sold publicly under Rule 144 of the Securities Act on a single day. As of the date of this Annual
Report on Form 10-K, Samsara has not exercised any such registration rights.

The  net  proceeds  to  the  Company  from  the  2019  Public  Offering  and  the  2019  Concurrent  Private  Placement  were
approximately  $227.3  million,  after  deducting  underwriting  discounts,  commissions  and  estimated  offering  expenses  of
approximately $13.9 million.

2018 Public Offering and Concurrent Private Placement

On April 9, 2018, the Company issued and sold (i) 2,695,313 shares of common stock in a registered public offering
(including 351,563 shares issued and sold upon the exercise in full of the underwriters’ option to purchase additional shares),
at  a  price  to  the  public  of  $64.00  per  share  (the  “2018  Public  Offering”)  and  (ii)  1,562,500  shares  of  common  stock  (the
“2018 Private Placement Shares”) in a concurrent private placement (the “2018 Concurrent Private Placement”) exempt from
the registration requirements of the Securities Act, at a purchase price per share equivalent to the price to the public set in the
2018 Public Offering and pursuant to a securities purchase agreement (the “2018 Securities Purchase Agreement”) that the
Company entered into with the purchasers in the 2018 Concurrent Private Placement (the “Private Placement Purchasers”).
Pursuant  to  the  2018  Securities  Purchase  Agreement,  the  Company  granted  to  the  Private  Placement  Purchasers  certain
registration rights which expired on April 4, 2019.

F-28

    
    
 
 
Table of Contents

Common Stock

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

As of December 31, 2019 and 2018, the Company had 45,000,000 authorized shares of common stock, par value $0.001

per share.

Dividends

Subject to preferences that may be applicable to any outstanding shares of preferred stock, holders of common stock are
entitled to receive ratably such dividends, if any, as may be declared from time to time by the Company’s board of directors
out  of  funds  legally  available  for  dividend  payments.  The  Company  has  never  declared  or  paid  any  cash  dividends  on  its
common  stock,  and  does  not  anticipate  paying  any  cash  dividends  on  its  common  stock  in  the  foreseeable  future.  The
Company intends to retain all available funds and any future earnings to fund the development and expansion of its business.
Any future determination to pay dividends will be at the discretion of the board of directors and will depend upon a number
of  factors,  including  the  results  of  operations,  financial  condition,  future  prospects,  contractual  restrictions,  restrictions
imposed by applicable law and other factors the board of directors deems relevant.

Voting

Holders of common stock are entitled to one vote for each share held with respect to all matters submitted to a vote

of the stockholders and do not have cumulative voting rights.

Preferred Stock

As of December 31, 2019 and 2018, the Company had 5,000,000 authorized shares of preferred stock, par value $0.001

per share, of which none are issued.

13. Stock Compensation

The Company’s 2012 Equity Incentive Plan (“2012 Plan”) became effective upon the pricing of its initial public offering
in October 2012 (the “IPO”). At the same time, the Company’s 2003 Stock Incentive Plan (“2003 Plan”) was terminated and
555,843 shares available under the 2003 Plan were added to the 2012 Plan.

On January 1, 2019 and 2018, the number of shares available for issuance under the 2012 Plan increased by 1,187,599

and 1,010,693 shares, respectively, as a result of the automatic increase provisions thereof.

The estimated fair value of the stock options granted in the year ended December 31, 2019 was determined utilizing a
Black-Scholes option-pricing model at the date of grant. The fair value of the restricted stock units (“RSUs”) granted in the
year ended December 31, 2019 was determined utilizing the closing price of the Company’s common stock on the date of
grant. The fair value of the performance restricted stock units (“PRSUs”) granted in the year ended December 31, 2019 was
determined utilizing the Monte Carlo simulation method.

There  were  approximately  2.8  million  and  2.2  million  shares  available  for  grant  remaining  under  the  2012  Plan  at

December 31, 2019 and 2018, respectively.

F-29

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

Stock Options and Performance-Based Stock Options

The Company’s combined outstanding employee and non-employee option activity for the period from December 31,

2018 through December 31, 2019 is summarized as follows:

Outstanding at December 31, 2018
Granted
Exercised
Cancelled/forfeited
Expired
Outstanding at December 31, 2019
Expected to vest
Exercisable

Number
of Options
(in thousands)

Weighted
Average
Exercise Price

1,874
551
(179)
(176)
(89)
1,981
885
1,096

$
$
$
$
$
$
$
$

97.64  
101.85  
37.82  
92.35  
156.71  
99.87  
89.24  
108.45  

Weighted
Average
Remaining
Contractual
Term (years)
7.5
$
— $
— $
— $
— $
$
7.4
$
8.5
$
6.5

Aggregate
Intrinsic Value
(in thousands)

45,381
—
—
—
—
65,662
32,201
33,460

The  aggregate  intrinsic  value  of  options  is  calculated  as  the  difference  between  the  exercise  price  of  the  underlying
options and the deemed fair value of the Company’s common stock for those options that had exercise prices lower than the
deemed  fair  value  of  the  Company’s  common  stock.  The  weighted-average  grant  date  fair  value  of  options  granted  in  the
years  ended  December  31,  2019,  2018  and  2017  was  $74.78,  $41.18  and  $63.65  per  option,  respectively.  The  aggregate
intrinsic  value  of  stock  options  exercised  during  the  years  ended  December  31,  2019,  2018  and  2017  was  $10.2  million,
$14.1  million  and  $9.4  million,  respectively.  As  of  December  31,  2019,  the  total  compensation  cost  related  to  non-vested
option awards not yet recognized is approximately $51.3 million with a weighted average remaining vesting period of 1.26
years.

The Company estimated the fair value of stock options granted in the periods presented utilizing a Black-Scholes option-

pricing model utilizing the following assumptions:

Years Ended December 31, 

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

2017

2019

2018
  86.9 - 89.9 % 62 - 73 % 61- 65 %
5.5 - 6.0
6.0
1.4 - 2.9 % 1.8 - 3.0 % 1.8 - 2.4 %
% — % — %

6.0 - 9.9

—

Effective January 1, 2019, the Company changed its expected volatility assumption to be determined based on the actual
historical stock price volatility of the Company over the expected term given the availability of sufficient historical trading
data. In prior years, the expected volatility was estimated based on historical volatility information of publicly-traded peer
companies.

 The Company has in the past, and may in the future, grant performance-based stock option awards with vesting terms
based  on  the  achievement  of  specified  goals.  To  the  extent  such  awards  do  not  contain  a  market  condition,  the  Company
recognizes no expense until achievement of the performance requirement is deemed probable.

In  April  2014,  the  Company  issued  57,063  performance-based  options  to  certain  employees  that  will  vest  upon  the
achievement  of  certain  regulatory  milestones  related  to  OCA  at  future  dates.  In  November  2014,  the  Company  issued  an
additional 10,839 performance-based options that will vest upon the achievement of the same regulatory milestones. As

F-30

    
    
    
    
 
 
 
 
 
 
 
 
 
    
    
    
 
 
 
 
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

of both December 31, 2019 and 2018, the achievement of such milestones was not deemed to be probable and no stock-based
compensation expense was recognized for these performance-based options.

Restricted Stock Units and Awards & Performance-Based Restricted Stock Units and Awards

The  following  table  summarizes  the  aggregate  RSU,  RSA,  PRSU  and  performance  restricted  share  award  (“PRSA”)

activity for the year ended December 31, 2019:

Non-vested awards at December 31, 2018

Granted
Vested
Forfeited

Non-vested awards at December 31, 2019

Number of
Awards
(in thousands)

Weighted
Average Grant Date
Fair Value

$
773
395
$
(358) $
(101) $
709
$

76.10
107.29
83.45
85.74
88.39

For  the  years  ended  December  31,  2019,  2018  and  2017,  the  weighted-average  grant  date  fair  value  of  RSUs,  RSAs,
PRSUs and PRSAs granted was $107.29, $65.28 and $102.35, respectively. The total fair value of RSUs, RSAs, PRSUs and
PRSAs that vested during the years ended December 31, 2019, 2018 and 2017 was $29.8 million, $24.0 million and $16.7
million, respectively. As of December 31, 2019, there was $48.3 million of unrecognized compensation expense related to
unvested  RSUs,  RSAs,  PRSUs,  and  PRSAs,  which  is  expected  to  be  recognized  over  a  weighted  average  period  of  1.33
years.

During  the  years  ended  December  31,  2019  and  2018,  the  Company  granted  a  total  of  57,800  and  51,200  PRSUs  to
certain  of  the  Company’s  executive  officers.  During  the  year  ended  December  31,  2018,  the  Company  granted  a  total  of
4,300 PRSAs to certain of the Company’s executive officers. The performance criterion for such PRSUs and PRSAs is based
on the Total Shareholder Return (“TSR”) of the Company’s common stock relative to the TSR of the companies comprising
the S&P Biotechnology Select Industry Index (the “TSR Peer Group”) over a 3-year performance period and is accounted for
as  a  market  condition  under  ASC  718.  The  TSR  for  the  Company  or  a  member  of  the  TSR  Peer  Group  is  calculated  by
dividing (a) the difference of the ending average stock price minus the beginning average stock price by (b) the beginning
average stock price. The beginning average stock price equals the average closing stock price over the one calendar month
period  prior  to  the  beginning  of  the  performance  period,  after  adjusting  for  dividends,  as  applicable.  The  ending  average
stock price equals the average closing price over the one calendar month period ending on the last day of the performance
period,  after  adjusting  for  dividends,  as  applicable.  The  Company’s  relative  TSR  is  then  used  to  calculate  the  payout
percentage,  which  may  range  from  zero  percent  (0%)  to  one  hundred  and  fifty  percent  (150%)  of  the  target  award.  The
Company utilized a Monte Carlo Simulation to determine the grant date fair value of such PRSUs and PRSAs. The Company
recorded approximately $4.0 million and $1.3 million of stock-based compensation related to such PRSUs and PRSAs during
the years ended December 31, 2019 and 2018, respectively.

The Company accounts for all forfeitures when they occur. Ultimately, the actual expense recognized over the vesting
period will be for only those shares that vest and are not forfeited. The Company has in the past, and may in the future, grant
performance-based awards with vesting terms based on the achievement of specified goals. To the extent such awards do not
contain  a  market  condition,  the  Company  recognizes  no  expense  until  achievement  of  the  performance  requirement  is
deemed probable.

F-31

    
    
 
 
 
 
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

Stock-based compensation expense has been reported in the Company’s statements of operations as follows:

Selling, general and administrative
Research and development
Total stock-based compensation

14. Employee Benefit Plans

$

$

2019

Years Ended December 31, 
2018
(In thousands)
38,361
$
11,553
49,914

$

$

$

43,170
12,812
55,982

2017

40,004
16,964
56,968

The  Company  maintains  a  defined  contribution  plan,  which  is  qualified  under  section  401(k)  of  the  Internal  Revenue
Code for U.S. employees. Employees may make contributions by withholding a percentage of their salary up to the Internal
Revenue Service annual limit of $19,000 and $25,000 in 2019 for employees under 50 years old and employees 50 years old
or  over,  respectively.  The  Company’s  matching  contribution  vests  over  four  years  from  the  start  of  employment.  The
Company  made  approximately  $1.4  million,  $1.9  million  and  $2.7  million  in  matching  contributions  for  the  years  ended
December 31, 2019, 2018 and 2017, respectively.

15. Income Taxes

The  components  of  loss  before  income  taxes  for  the  years  ended  December  31,  2019,  2018  and  2017  includes  the

following:

United States
Foreign
Total

2019

Years Ended December 31, 
2018
(in thousands)
$ (95,708) $ (72,655) $ (102,586)
  (248,973)
(257,781)
(236,587)
$ (344,681) $ (309,242) $ (360,367)

2017

Income tax expense (benefit) differed from the amounts computed by applying the statutory U.S. Federal income tax rate

of 21% (21% for 2018 and 34% for 2017) to loss before income taxes as a result of the following:

Computed "expected" tax benefit
State taxes, net of U.S. Federal benefit
U.S. Federal rate reduction
U.S. Federal valuation allowance
Stock-based compensation
Officer compensation
Foreign valuation allowance
Foreign tax rate differences
Other
Total

F-32

2017

2019

—  
—  

—  
—  

Years Ended December 31, 
2018
(in thousands)
$ (72,383) $ (64,941) $ (122,525)
—
84,787
282
(49,391)
26
52,521
35,125
(825)
—

14,786
4,609
508
19,349
32,936
195
— $

9,352
6,423
22
44,896
4,787
(539)

— $

$

    
    
    
 
 
 
    
    
    
 
 
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

The tax effects of temporary differences that give rise to the deferred tax assets and liabilities at December 31, 2019 and

2018 are presented below:

Deferred tax assets:

U.S. and state net operating loss and other carryforwards
Foreign net operating loss and other carryforwards
Stock compensation
Deferred revenue
Accrued compensation
Accrued expense
Intangible property
Interest limitation
Other

Deferred tax assets before valuation allowance
Valuation allowance
Total deferred tax assets
Deferred tax liabilities:
Convertible Notes

Total deferred tax liabilities
Net deferred tax asset (liability)

Effects of the Tax Cuts and Jobs Act

December 31, 

2019

2018

(in thousands)

$

$

160,079
195,590
13,626

—  

4,997
1,750
2,088
5,183
1,406
384,719
(353,677)
31,042

(31,042)
(31,042)

$

— $

151,416
177,672
13,228
620
3,431
2,340
—
2,913
1,021
352,641
(338,852)
13,789

(13,789)
(13,789)
—

In  late  2017,  the  United  States  enacted  the  TCJA,  which  significantly  changed  U.S.  Federal  income  tax  law  by
implementing a reduction in the Federal corporate income tax rate to 21%, moving from a worldwide tax system towards a
territorial  system  and  imposing  new  or  additional  limitations  on  the  deductibility  of  interest  expense  and  executive
compensation.

Given the significance of the legislation, the staff of the U.S. Securities and Exchange Commission (the “SEC”) issued
Staff Accounting Bulletin No. 118 (“SAB 118”), which allowed registrants to record provisional amounts during a one year
“measurement period” similar to that used when accounting for business combinations.

For  the  year  ended  December  31,  2017,  amounts  recorded  principally  related  to  the  reduction  in  the  U.S.  corporate
income  tax  rate  to  21%,  which  resulted  in  the  Company  reducing  its  net  deferred  tax  asset  and  associated  valuation
allowance. At December 31, 2018, the Company completed its accounting of SAB 118 for all of the enactment-date income
tax  effects  of  the  TCJA.  The  Company  did  not  make  any  measurement-period  adjustments  and  there  were  no  additional
material adjustments related to the TCJA.

Net Operating Loss and other carryforwards

As  of  December  31,  2019,  and  2018,  the  Company  had  net  operating  loss  carryforwards  (“NOLs”)  for  U.S.  Federal
income  tax  purposes  of  $693.3  million  and  $658.4  million,  respectively,  and  other  carryforwards  of  $0.5  million.  The
enactment of the TCJA modified the ability of companies to utilize NOLs arising in tax years beginning on or after January
1,  2018  by  providing  that  such  NOLs  may  be  carried-forward  indefinitely  and  used  to  offset  up  to  80  percent  of  taxable
income in any given future year. Existing NOLs that arose in tax years beginning prior to January 1, 2018 were not affected
by the TCJA and are generally eligible to be carried-forward for up to 20 years and used to fully offset taxable income in
future years. If not utilized, the Company’s pre-2018 NOLs and other carryforwards will expire for U.S. Federal income

F-33

    
    
 
    
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

tax  purposes  between  2024  and  2037.  The  Company  also  has  certain  state  NOLs  in  varying  amounts  depending  on  the
different state tax laws.

As of December 31, 2019, and 2018, the Company had NOLs for foreign income tax purposes of $1.1 billion and $870.3
million, respectively. Of our $1.1 billion of foreign tax loss carryforwards, approximately $1.0 billion may be carried forward
indefinitely and the remainder will expire during the next 18 years.

In addition, the Company’s ability to utilize its NOLs may be limited under Section 382 of the Internal Revenue Code or
applicable  state  and  foreign  tax  law.  The  Section  382  limitations  apply  if  an  “ownership  change”  occurs.  Generally,  an
ownership change occurs when certain shareholders increase their aggregate ownership by more than 50 percentage points
over their lowest ownership percentage in a testing period (typically three years). The Company has evaluated whether one
or more ownership changes under Section 382 have occurred since its inception and has determined that there have been at
least  two  such  changes.  Although  the  Company  believes  that  these  ownership  changes  have  not  resulted  in  material
limitations on its ability to use these NOLs, its ability to utilize these NOLs may be limited due to future ownership changes
or for other reasons. As a result, the Company may not be able to take full advantage of its carryforwards for U.S. Federal,
state, and foreign tax purposes.

Valuation Allowance

At December 31, 2019 and 2018, the Company maintained a full valuation allowance on its deferred tax assets since it
has not yet achieved sustained profitable operations. As a result, the Company has not recorded any income tax benefit since
its  inception.  In  2019,  the  valuation  allowance  for  deferred  tax  assets  increased  by  approximately  $14.8  million.  This
includes  an  increase  of  $14.8  million,  $2.6  million  and  $19.3  million  for  U.S.  Federal,  state  and  foreign  tax,  respectively,
partially offset by a decrease of $21.9 million to equity. The decrease to equity primarily related to the U.S. Federal and state
impact of the equity component associated with the 2026 Convertible Notes. In 2018, the valuation allowance for deferred
tax assets increased by approximately $56.1 million. This includes an increase of $9.4 million, $1.9 million and $44.9 million
for U.S. Federal, state and foreign tax, respectively, partially offset by a decrease of $0.1 million to equity.

Unrecognized Tax Benefits

At December 31, 2019 and 2018, the Company had no reserves for unrecognized tax benefits.

The Company and its subsidiaries are subject to taxation in the United States and various foreign jurisdictions. Of the
major  jurisdictions,  the  Company  is  subject  to  examination  in:  the  United  States  for  U.S.  Federal  purposes  for  2016  and
forward and generally for state purposes for 2015 and forward; and the United Kingdom for 2017 and forward. However,
NOLs are subject to audit in any tax year in which those losses are utilized, notwithstanding the year of origin.

16. Commitments and Contingencies

Facility Leases

In May 2014, the Company entered into a lease agreement with respect to office space in San Diego, California. The
Company leases approximately 47,000 square feet. The lease covering this property is scheduled to expire in July 2020. The
Company will lease and occupy approximately 34,000 square feet of office space in San Diego under a separate lease that is
expected to commence in August 2020 and scheduled to expire 60 months from the commencement date.

In January 2016, Intercept Pharma Europe Ltd. (“IPEL”), a wholly owned subsidiary of the Company, entered into an
underlease with respect to office space in London, United Kingdom. The Company is the guarantor to the underlease. IPEL
leases approximately 8,600 square feet. The lease covering this property is scheduled to expire in May 2024.

F-34

Table of Contents

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

In November 2019, the Company entered into an amendment to the lease agreement with respect to office space at 10
Hudson Yards in New York, New York, where the Company’s corporate headquarters are located. The Company leases an
aggregate of approximately 45,600 square feet of office space at this property. The lease covering this property is scheduled
to expire in March 2022.

The Company also leases office space in several other locations.

Licenses

The  Company  acquired  a  license  from  a  third  party  to  support  the  portfolio  of  product  candidates.  Under  the  license
agreement  with  Aralez  Pharmaceuticals  Canada  Inc.  (“Aralez”)  the  Company  has  rights  to  develop  and  commercialize
bezafibrate in the United States. The Company may pay up to $4.5 million upon the achievement of certain milestones, none
of which is owed as of December 31, 2019. The Company is obligated to pay royalties to at a mid-single digit percentage of
net product sales.

Legal Proceedings

The Company is involved in various disputes, governmental inquiries and investigations, legal proceedings and litigation
in the course of its business, including the matters described below and, from time to time, intellectual property, employment
and other litigation. These matters, which could result in damages, fines or other administrative, civil or criminal remedies,
liabilities or penalties, are often complex and the outcome of such matters is often uncertain. The Company may from time to
time enter into settlements to resolve such matters.

On September 27, 2017, a purported shareholder class action, initially styled DeSmet v. Intercept Pharmaceuticals, Inc.,
et al, was filed in the United States District Court for the Southern District of New York, naming the Company and certain of
its officers as defendants. The Court appointed lead plaintiffs in the lawsuit on June 1, 2018, and the lead plaintiffs filed an
amended complaint on July 31, 2018, captioned Hou Liu and Amy Fu v. Intercept Pharmaceuticals, Inc., et al., naming the
Company  and  certain  of  its  current  and  former  officers  as  defendants.  The  lead  plaintiffs  claim  to  be  suing  on  behalf  of
anyone who purchased or otherwise acquired the Company’s common stock between June 9, 2016 and September 20, 2017.
This lawsuit alleges that material misrepresentations and/or omissions of material fact were made in the Company’s public
disclosures  during  the  period  from  June  9,  2016  to  September  20,  2017,  in  violation  of  Sections  10(b)  and  20(a)  of  the
Securities Exchange Act of 1934, as amended (the “Exchange Act”), and Rule 10b-5 promulgated thereunder. The alleged
improper disclosures relate to statements regarding Ocaliva dosing, use and pharmacovigilance-related matters, as well as the
Company’s operations, financial performance and prospects. The plaintiffs seek unspecified monetary damages on behalf of
the  putative  class,  an  award  of  costs  and  expenses,  including  attorney’s  fees,  and  rescissory  damages.  On  September  14,
2018, the Company filed a motion to dismiss the amended complaint. Separately, on January 5, 2018, a follow-on derivative
suit, styled Davis v. Pruzanski et al., was filed in New York state court by shareholder Gregg Davis based on substantially the
same allegations as those set forth in the securities case. On December 1, 2017, a purported shareholder demand was made
on the Company based on substantially the same allegations as those set forth in the securities case.

While  the  Company  believes  that  it  has  a  number  of  valid  defenses  to  the  claims  described  above  and  intends  to
vigorously  defend  itself,  the  matters  are  in  the  early  stages  of  litigation  and  no  assessment  can  be  made  as  to  the  likely
outcome of the matters or whether they will be material to the Company. Accordingly, an estimate of the potential loss, or
range of loss, if any, to the Company relating to the matters is not possible at this time.

In  May  2018,  the  Company  received  a  subpoena  from  the  SEC  requesting  information  in  connection  with  the
Company’s patient assistance program and certain of the Company’s commercial activities. The Company cooperated fully
with the SEC in this matter and in late 2019 the SEC staff informed the Company that they had concluded the investigation
and did not intend to recommend an enforcement action against the Company.

F-35

Table of Contents

17. Net Loss Per Share

INTERCEPT PHARMACEUTICALS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

Basic loss per share is computed by dividing net loss attributable to common stockholders (numerator) by the weighted
average number of common shares outstanding (denominator) during the period. For the years ended December 31, 2019,
2018 and 2017, as the Company was in a net loss position, the diluted loss per share computations for such periods did not
assume the exercise of stock options or vesting of RSUs as they would have had an anti-dilutive effect on loss per share.

The following potentially dilutive securities have been excluded from the computations of diluted weighted average

shares outstanding as of December 31, 2019, 2018 and 2017 as the inclusion thereof would have been anti-dilutive:

Shares issuable upon conversion of Conversion Notes
Options
Unvested restricted stock units
Total

18. Quarterly Financial Data (unaudited)

2019

4,435
1,981  
556  
6,972  

December 31, 
2018
(in thousands)
2,316
1,874  
441  
4,631  

2017

—
1,808
493
2,301

The following table summarizes the unaudited quarterly financial data for the years ended December 31, 2019 and 2018:

     March 31,       June 30, 

    September 30,      December 31,      

Total

(in thousands, except for per share amounts)

Quarters Ended

2019

Total revenue
Operating loss
Net loss
Net loss per common share - basic and diluted

2018

Total revenue
Operating loss
Net loss
Net loss per common share - basic and diluted

19. Restructuring Charges

$ 52,252
  (83,945)
  (90,270)
$

$ 35,963
  (75,456)
  (81,590)
$

$

$ 66,300
  (63,659)
  (71,420)

$

61,950
(75,533)
(84,833)

(3.03) $

(2.28) $

(2.59) $

$

$ 43,575
  (69,777)
  (75,193)

$

46,986
(58,286)
(64,454)

(3.22) $

(2.58) $

(2.18) $

71,500
(89,290)
(98,158)
(2.99)

53,280
(81,971)
(88,005)
(2.97)

$ 252,002
(312,427)
(344,681)

$ 179,804
(285,490)
(309,242)

In  December  2017,  the  Company  initiated  a  15%  reduction  in  the  workforce  and  concurrently  notified  the  affected
employees.  The  reduction  in  force  supports  the  Company’s  strategy  to  fund  its  development  organization  with  strategic
collaborations  and  to  focus  the  Company’s  resources  to  progress  its  development  and  commercialization  initiatives.  The
actions associated with the reductions were substantially completed during the fourth quarter of 2017 and, as a result of the
reductions,  the  Company  recorded  a  one-time  restructuring  charge  of  $5.2  million  for  termination  benefits  in  the  same
period.  Of  this  charge,  $3.9  million  was  recorded  in  selling,  general  and  administrative  expense  and  $1.3  million  was
recorded in research and development expense. The restructuring charge associated with cash payments of $5.2 million were
paid out in the first quarter of 2018.

No restructuring charges were incurred for the years ended December 31, 2019 and 2018.

F-36

    
    
    
 
 
 
 
 
 
 
 
 
 
  
 
    
    
    
    
  
 
 
 
 
 
 
 
  
Description of the Registrant's Securities Registered Pursuant to Section 12 of the Securities Exchange Act of
1934

Description of the Registrant's Common Stock

References to “Intercept," "our" and the “Company” herein are, unless the context otherwise indicates, only to Intercept
Pharmaceuticals, Inc. and not to any of its subsidiaries.

Exhibit 4.11

Description of Common Stock

General

The following is a summary of information concerning Intercept's common stock, par value $0.001 per share ("Common
Stock"). The summaries and descriptions below do not purport to be complete statements of the relevant provisions of
our  restated  certificate  of  incorporation  and  restated  bylaws  and  are  entirely  qualified  by,  and  should  be  read  in
conjunction with, these documents, each of which is filed as an exhibit to the Annual Report on Form 10-K of which this
Exhibit 4.11 is a part.

Common Stock

Authorized  Capital  Stock  and  Shares  Outstanding.  Our  authorized  capital  stock  consists  of  45,000,000  shares  of
Common  Stock  and  5,000,000  shares  of  preferred  stock,  par  value  $0.001  per  share.  As  of  December  31,  2019,
32,853,066  shares  of  Common  Stock  were  outstanding,  and  no  shares  of  preferred  stock  were  outstanding.  All  of  the
outstanding shares of our Common Stock are fully paid and nonassessable.

Annual Meeting. Annual meetings of our stockholders are held on the date designated in accordance with our restated
bylaws. Written notice must be mailed to each stockholder entitled to vote not less than ten nor more than 60 days before
the  date  of  the  meeting.  The  presence  in  person  or  by  proxy  of  the  holders  of  record  of  a  majority  of  our  issued  and
outstanding shares entitled to vote at such meeting constitutes a quorum for the transaction of business at meetings of the
stockholders. Special meetings of the stockholders may be called for any purpose only by our board of directors pursuant
to  a  resolution  adopted  by  a  majority  of  the  total  number  of  directors.  Except  as  may  be  otherwise  provided  by
applicable  law,  our  restated  certificate  of  incorporation  or  our  restated  bylaws,  all  elections  shall  be  decided  by  a
plurality, and all other questions shall be decided by a majority, of the votes cast by stockholders entitled to vote thereon
at a duly held meeting of stockholders at which a quorum is present.

Voting  Rights.  Holders  of  our  Common  Stock  are  entitled  to  one  vote  for  each  share  held  of  record  on  all  matters
submitted to a vote of the stockholders and do not have cumulative voting rights.

Dividends.  Subject  to  preferences  that  may  be  applicable  to  any  outstanding  shares  of  preferred  stock,  holders  of
Common Stock are entitled to receive ratably such dividends, if any, as may be declared from time to time by our board
of directors out of funds legally available for dividend payments.

Liquidation  and  Dissolution.  In  the  event  of  any  liquidation,  dissolution  or  winding-up  of  our  affairs,  holders  of
Common Stock will be entitled to share ratably in any of our assets remaining after payment or provision for payment of
all of our debts and obligations and after liquidation payments to holders of outstanding shares of preferred stock, if any.

Other Rights. The holders of Common Stock have no preferences or rights of conversion, exchange, preemptive or other
subscription rights. There are no redemption or sinking fund provisions applicable to the Common Stock.

 
 
 
 
 
 
 
 
 
 
 
 
 
Transfer Agent and Registrar.  VStock Transfer, LLC is transfer agent and registrar for the Common Stock.

NASDAQ  Global  Select  Market.  Our  Common  Stock  is  listed  on  The  Nasdaq  Global  Select  Market  under  the
symbol “ICPT.”

Anti-takeover Effects of Our Restated Certificate of Incorporation, Restated Bylaws and Delaware Law

The  provisions  of  Delaware  law  and  our  restated  certificate  of  incorporation  and  restated  bylaws  could  discourage  or
make it more difficult to accomplish a proxy contest or other change in our management or the acquisition of control by
a holder of a substantial amount of our voting stock. It is possible that these provisions could make it more difficult to
accomplish, or could deter, transactions that stockholders may otherwise consider to be in their best interests or in our
best interests.

These provisions are intended to enhance the likelihood of continuity and stability in the composition of our board of
directors and in the policies formulated by the board of directors and to discourage certain types of transactions that may
involve an actual or threatened change of our control. These provisions are designed to reduce our vulnerability to an
unsolicited acquisition proposal and to discourage certain tactics that may be used in proxy fights. Such provisions also
may have the effect of preventing changes in our management.

Delaware Business Combination Statute. We are subject to the anti-takeover provisions of Section 203 of the Delaware
General Corporation Law, which we refer to as the DGCL. With some exception, Section 203 of the DGCL prohibits a
publicly-held Delaware corporation from engaging in a “business combination” with an “interested stockholder” for a
period of three years after the date of the transaction in which the person became an interested stockholder, unless the
business combination is, or the transaction in which the person became an interested stockholder was, approved by the
board of directors and the holders of at least two-thirds of the outstanding voting stock of the corporation. The shares
held  by  the  interested  stockholder  are  not  counted  as  outstanding  when  calculating  the  two-thirds  of  the  outstanding
voting  stock  needed  for  approval.  For  purposes  of  Section  203  of  the  DGCL,  a  “business  combination”  is  defined
broadly to include a merger, asset sale or other transaction resulting in a financial benefit to the interested stockholder,
and,  subject  to  certain  exceptions,  an  “interested  stockholder”  is  a  person  who,  together  with  his  or  her  affiliates  and
associates, owns, or within three years prior, did own, 15% or more of the corporation’s outstanding voting stock.

Advance Notice Provisions for Stockholder Proposals and Stockholder Nominations of Directors. Our restated bylaws
provide  that,  for  nominations  to  the  board  of  directors  or  for  other  business  to  be  properly  brought  by  a  stockholder
before  a  meeting  of  stockholders,  a  stockholder  must  first  have  given  timely  notice  of  the  proposal  in  writing  to  our
secretary. For an annual meeting, a stockholder’s notice generally must be delivered not less than 90 days nor more than
120 days prior to the first anniversary of the previous year’s annual meeting date; provided, that if the date of the annual
meeting is more than 30 days before or more than 30 days after the anniversary of the previous year’s annual meeting
date,  such  stockholder’s  notice  must  be  delivered  not  earlier  than  the  close  of  business  on  the  120  day  prior  to  such
annual meeting and not later than the close of business on the later of the 90 day prior to such annual meeting or the
close of business on the 10 day following the day on which public announcement of the date of such meeting is first
made by us. For a special meeting, the notice must generally be delivered not earlier than the 90 day prior to the meeting
and not later than the later of (1) the 60 day prior to the meeting or (2) the 10 day following the day on which public
announcement of the meeting is first made. Detailed requirements as to the form of the notice and information required
in  the  notice  are  specified  in  the  restated  bylaws.  If  it  is  determined  that  business  was  not  properly  brought  before  a
meeting in accordance with our bylaws provisions, such business will not be conducted at the meeting.

Special Meetings of Stockholders.  Special  meetings  of  the  stockholders  may  be  called  only  by  our  board  of  directors
pursuant to a resolution adopted by a majority of the total number of directors.

No  Stockholder  Action  by  Written  Consent. Any  action  to  be  effected  by  our  stockholders  must  be  effected  at  a  duly
called annual or special meeting of the stockholders provided, however, our restated certificate of incorporation provides
that if any one stockholder, together with its affiliates, collectively holds a majority of the voting power of

 
 
 
 
 
 
 
 
 
the then-outstanding shares of our capital stock, action may be taken without a meeting and vote, through the written
consent of holders of the requisite number of votes necessary to authorize or take such action at a meeting.

Board of Directors. We do not have a classified board of directors. All of our directors are elected annually. The number
of directors comprising our board of directors is fixed from time to time by the board of directors.

Removal of Directors by Stockholders. Our restated bylaws provide that our directors may be removed with or without
cause by the affirmative vote of the holders of a majority of the votes that all our stockholders would be entitled to cast
in  an  annual  election  of  directors,  and  our  restated  certificate  of  incorporation  and  restated  bylaws  provide  that  any
vacancy on our board of directors, including a vacancy resulting from an increase in the size of our board of directors,
may be filled only by vote of a majority of our directors then in office.

Super Majority Stockholder Vote Required for Certain Actions. The DGCL provides generally that the affirmative vote
of a majority of the shares entitled to vote on any matter is required to amend a corporation’s certificate of incorporation
or  bylaws,  unless  the  corporation’s  certificate  of  incorporation  or  bylaws,  as  the  case  may  be,  requires  a  greater
percentage. Our restated certificate of incorporation requires the affirmative vote of the holders of at least 80% of our
outstanding voting stock to amend or repeal any of the provisions discussed in this section of this Exhibit entitled “Anti-
takeover  Effects  of  Our  Restated  Certificate  of  Incorporation,  Restated  Bylaws  and  Delaware  Law.”  This  80%
stockholder vote would be in addition to any separate class vote that might in the future be required pursuant to the terms
of  any  preferred  stock  that  might  then  be  outstanding.  The  affirmative  vote  of  at  least  80%  of  our  outstanding  voting
stock is also required for any amendment to, or repeal of, our restated bylaws by the stockholders. Our restated bylaws
may be amended or repealed by a simple majority vote of the board of directors.

 
 
 
 
 
 
 
Exhibit 10.3

Option No.________

INTERCEPT PHARMACEUTICALS, INC.
2012 EQUITY INCENTIVE PLAN
STOCK OPTION GRANT

Stock Option Grant Notice (Employees and Consultants)

Intercept Pharmaceuticals, Inc. (the “Company”) hereby grants to the participant named below (the “Participant”) an
option of the type specified below (this “Option”) to purchase up to the number of shares of the Company’s common
stock, par value $0.001 per share (the “Shares”),  set  forth  below  at  the  exercise  price  set  forth  below.  This  Option  is
subject to all of the terms and conditions set forth in this Stock Option Grant Notice (this “Grant Notice”), the Intercept
Pharmaceuticals,  Inc.  2012  Equity  Incentive  Plan  (the  “Plan”)  and  the  Stock  Option  Agreement  attached  hereto  (the
“Agreement”). Capitalized terms not defined in this Grant Notice but defined in the Agreement or the Plan will have the
meanings  assigned  to  such  terms  in  the  Agreement  or  the  Plan,  as  applicable.  Except  as  expressly  provided  in  the
Agreement, in the event of any conflict between the provisions of this Grant Notice or the Agreement and those of the
Plan, the provisions of the Plan will control.

1.

Name and Address of Participant:

2.

3.

4.

5.

6.

7.

Date of Grant:

Type of Option:

Number of Shares Underlying Option:

Exercise Price Per Share:

Option Expiration Date:

Vesting Commencement Date:

8.            Vesting Schedule:  This Option shall become exercisable (and the Shares issued upon exercise shall be vested)
as  follows  provided  the  Participant  is  an  Employee,  director  or  Consultant  of  the  Company  or  an  Affiliate  on  the
applicable vesting date (see vesting schedule below):

[INSERT VESTING SCHEDULE]

See Section 1(b) of the Agreement for vesting in the event of a Change of Control (as defined in the Agreement). The
foregoing vesting provisions are cumulative and are subject to the other terms and conditions of the Agreement and the
Plan.

By accepting this Option, whether electronically or otherwise, the Participant acknowledges receipt of, and understands
and agrees to, this Grant Notice, the Agreement and the Plan. Unless otherwise specified in a written agreement between
the  Company  and  the  Participant,  this  Grant  Notice,  the  Agreement  and  the  Plan  set  forth  the  entire  understanding
between the Participant and the Company regarding this Option and supersede all prior oral and written agreements on
the terms of this Option.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
INTERCEPT PHARMACEUTICALS, INC.
2012 EQUITY INCENTIVE PLAN
STOCK OPTION AGREEMENT

Pursuant to the Stock Option Grant Notice to which this agreement is attached (the “Grant Notice”) and this
Stock  Option  Agreement  (this  “Agreement”),  Intercept  Pharmaceuticals,  Inc.  (the  “Company”)  has  granted  to  the
participant  named  in  the  Grant  Notice  (the  “Participant”)  an  option  of  the  type  specified  in  the  Grant  Notice  (this
“Option”), under and for the purposes set forth in the Intercept Pharmaceuticals, Inc. 2012 Equity Incentive Plan (the
“Plan”),  to  purchase  up  to  the  number  of  shares  of  the  Company’s  common  stock,  par  value  $0.001  per  share  (the
“Shares”), indicated in the Grant Notice at the exercise price indicated in the Grant Notice (as may be adjusted from
time to time in accordance with this Agreement and the Plan, the “Exercise Price”).  Capitalized  terms  not  defined  in
this Agreement or in the Grant Notice but defined in the Plan will have the meanings assigned to such terms in the Plan.

The terms and conditions of this Option, in addition to those set forth in the Grant Notice and the Plan, are as

follows:

1.            EXERCISABILITY OF OPTION.

(a)          Subject to the terms and conditions set forth in this Agreement and the Plan, this Option shall become
vested  and  exercisable  as  set  forth  in  the  Grant  Notice.  This  Option  shall  continue  to  vest  and  become  exercisable  in
accordance with its terms for so long as the Participant is an Employee, director or Consultant of the Company or an
Affiliate.

(b)                    Notwithstanding  the  foregoing,  except  to  the  extent  specifically  provided  to  the  contrary  in  any
employment agreement between the Participant and the Company or an Affiliate, in the event of (i) a Change of Control
(as  defined  below)  and  the  Participant’s  service  with  the  Company,  the  acquiring  or  succeeding  corporation  or  any
Affiliate of any of the foregoing is terminated by such entity for any reason other than for Cause within 12 months of the
Change of Control, then, immediately prior to such termination, this Option, to the extent then-outstanding, shall become
fully vested and exercisable, or (ii) a Corporate Transaction (as defined in Section 24(b) of the Plan) that is a Change of
Control in which the acquiring entity does not assume this Option, then, immediately prior to the Change of Control, this
Option, to the extent then-outstanding, shall become fully vested and exercisable.

For purposes of this Agreement, “Change of Control” means the occurrence of any of the following events:

(i)           Ownership.  Any “Person” (as such term is used in Sections 13(d) and 14(d) of the Securities
Exchange  Act  of  1934,  as  amended)  becomes  the  “Beneficial  Owner”  (as  defined  in  Rule  13d-3  under  said
Act), directly or indirectly, of securities of the Company representing 50% or more of the total voting power
represented by the Company’s then-outstanding voting securities (excluding for this purpose any such voting
securities held by the Company or its Affiliates or any employee benefit plan of the Company); or

(ii)                    Merger/Sale  of  Assets.    (A)  A  merger  or  consolidation  of  the  Company  whether  or  not
approved  by  the  Board  of  Directors,  other  than  a  merger  or  consolidation  which  would  result  in  the  voting
securities of the Company outstanding immediately prior thereto continuing to represent (either by remaining
outstanding  or  by  being  converted  into  voting  securities  of  the  surviving  entity  or  the  parent  of  such
corporation) more than 50% of the total voting power represented by the voting securities of the Company or
such  surviving  entity  or  parent  of  such  corporation,  as  the  case  may  be,  outstanding  immediately  after  such
merger  or  consolidation;  or  (B)  the  sale  or  disposition  by  the  Company  of  all  or  substantially  all  of  the
Company’s assets in a transaction requiring stockholder approval; or

(iii)         Change in Board Composition.  A change in the composition of the Board of Directors, as a
result of which fewer than a majority of the directors are Incumbent Directors. “Incumbent Directors”  shall
mean  directors  who  either  (A)  are  directors  of  the  Company  as  of  the  date  of  grant,  or  (B)  are  elected,  or
nominated  for  election,  to  the  Board  of  Directors  with  the  affirmative  votes  of  at  least  a  majority  of  the
Incumbent  Directors  at  the  time  of  such  election  or  nomination  (but  shall  not  include  an  individual  whose
election  or  nomination  is  in  connection  with  an  actual  or  threatened  proxy  contest  relating  to  the  election  of
directors to the Company).

2.            TERM OF OPTION.

This Option shall terminate on the Option Expiration Date specified in the Grant Notice (provided, that if this
Option is designated in the Grant Notice as an ISO and the Participant owns as of the date of grant of this Option more
than 10% of the total combined voting power of all classes of capital stock of the Company or an Affiliate, such date
may  not  be  more  than  five  years  from  the  date  of  grant  of  this  Option),  but  shall  be  subject  to  earlier  termination  as
provided herein or in the Plan.

If  the  Participant  ceases  to  be  an  Employee,  director  or  Consultant  of  the  Company  or  an  Affiliate  for  any
reason other than the termination of the Participant for Cause (the date of such cessation of service, the “Termination
Date”),  this  Option,  to  the  extent  then  vested  and  exercisable,  and  not  previously  terminated  in  accordance  with  this
Agreement, may be exercised by the Participant or, as applicable, the Participant’s Survivors on or prior to the earliest of
the following:

(i)                      in  the  event  that  the  Participant  ceases  to  be  an  Employee,  director  or  Consultant  of  the
Company or an Affiliate other than for Cause or due to the Disability or death of the Participant, the date that is
three (3) months after the Termination Date; provided, that the commencement of such three-month period shall
be  tolled  (subject  to  clause  (iii)  below)  for  so  long  as  the  sale  of  any  Shares  received  upon  exercise  of  this
Option  on  or  after  the  Termination  Date  (including  in  connection  with  a  broker-assisted  cashless  exercise)
would result in (a) short swing profit liability for the Participant under Section 16(b) of the Exchange Act or (b)
a  violation  of  the  Company’s  insider  trading  policy;  provided,    further,  that,  in  the  event  of  the  Participant’s
Disability or death within such period, the Participant or, as applicable, the Participant’s Survivors may exercise
this Option on or prior to the date that is one (1) year after the Termination Date;

(ii)                    in  the  event  that  the  Participant  ceases  to  be  an  Employee,  director  or  Consultant  of  the
Company or an Affiliate due to the Disability or death of the Participant, the date that is one (1) year after the
Termination Date; or

(iii)         the Option Expiration Date specified in the Grant Notice.

The unvested portion of this Option shall not be exercisable and shall expire and be cancelled on the Termination Date;
provided, that, in the event that the Participant ceases to be an Employee, director or Consultant of the Company or an
Affiliate due to the Disability or death of the Participant, and rights to exercise this Option accrue periodically, a pro rata
portion of any additional vesting rights that would have accrued on the next vesting date had the Participant not become
Disabled or died shall vest and become exercisable as of the Termination Date. Such proration shall be based upon the
number of days accrued in the current vesting period prior to the date of the Participant’s termination of service due to
Disability or death.

If the Participant ceases to be an Employee of the Company or an Affiliate but continues after termination of

employment to provide services to the Company or an Affiliate as a director or Consultant, this Option shall continue to
vest and become exercisable until the Participant is no longer providing services to the Company or an Affiliate as set
forth above; provided, that if this Option is designated in the Grant Notice as an ISO, it shall automatically convert and
be deemed a Non-Qualified Option as of the date that is three months from termination of the Participant’s employment.

In the event the Participant’s service is terminated by the Company or an Affiliate for Cause, the Participant’s
right  to  exercise  any  unexercised  portion  of  this  Option  (even  if  vested)  shall  cease  immediately  as  of  the  time  the
Participant  is  notified  his  or  her  service  is  terminated  for  Cause,  and  this  Option  shall  thereupon  terminate.
Notwithstanding anything herein to the contrary, if subsequent to the Participant’s termination, but prior to the exercise
of  this  Option,  the  Administrator  determines  that,  either  prior  or  subsequent  to  the  Participant’s  termination,  the
Participant engaged in conduct which would constitute Cause, then the Participant shall immediately cease to have any
right to exercise this Option and this Option shall thereupon terminate.

3.            METHOD OF EXERCISING OPTION.

Subject to the terms and conditions of this Agreement, this Option may be exercised by written notice to the
Company  or  its  designee  (in  a  form  designated  by  the  Company,  which  may  include  electronic  notice)  stating  the
number of Shares with respect to which this Option is being exercised. Payment of the Exercise Price for such Shares
shall be made in accordance with Paragraph 9 of the Plan. The Company shall deliver such Shares as soon as practicable
after  the  notice  shall  be  received,  provided,    however,  that  the  Company  may  delay  issuance  of  such  Shares  until
completion of any action or obtaining of any consent, which the Company deems necessary under any applicable law
(including, without limitation, state securities or “blue sky” laws). The Shares as to which this Option shall have been so
exercised shall be registered in the Company’s share register in the name of the person so exercising this Option (or, if
this  Option  shall  be  exercised  by  the  Participant  and  if  the  Participant  shall  so  request  in  the  notice  exercising  this
Option, shall be registered in the Company’s share register in the name of the Participant and another person jointly, with
right of survivorship) and shall be delivered as provided above to or upon the written order of the person exercising this
Option.  In  the  event  this  Option  shall  be  exercised,  pursuant  to  Section  2  hereof,  by  any  person  other  than  the
Participant, such notice shall be accompanied by appropriate proof of the right of such person to exercise this Option.
All  Shares  that  shall  be  purchased  upon  the  exercise  of  this  Option  as  provided  herein  shall  be  fully  paid  and
nonassessable.

4.            PARTIAL EXERCISE.

Exercise of this Option to the extent above stated may be made in part at any time and from time to time within

the above limits, except that no fractional share shall be issued pursuant to this Option.

5.            PROHIBITIONS ON TRANSFER.

This Option shall not be transferable by the Participant otherwise than by will or by the laws of descent and
distribution. If this Option is a Non-Qualified Option then it may also be transferred pursuant to a qualified domestic
relations  order  as  defined  by  the  Code  or  Title  I  of  the  Employee  Retirement  Income  Security  Act  or  the  rules
thereunder. Except as provided above in this Section 5, this Option shall be exercisable during the Participant’s lifetime
only  by  the  Participant  (or,  in  the  event  of  legal  incapacity  or  incompetency,  by  the  Participant’s  guardian  or
representative)  and  shall  not  be  assigned,  pledged  or  hypothecated  in  any  way  (whether  by  operation  of  law  or
otherwise)  and  shall  not  be  subject  to  execution,  attachment  or  similar  process.  Any  attempted  transfer,  assignment,
pledge, hypothecation or other disposition of this Option or of any rights granted hereunder contrary to the provisions of
this Section 5, or the levy of any attachment or similar process upon this Option shall be null and void.

6.            NO RIGHTS AS STOCKHOLDER.

The  Participant  shall  have  no  rights  as  a  stockholder  with  respect  to  Shares  subject  to  this  Option  until
registration of the Shares in the Company’s share register in the name of the Participant. Except as is expressly provided
in  the  Plan  with  respect  to  certain  changes  in  the  capitalization  of  the  Company,  no  adjustment  shall  be  made  for
dividends or similar rights for which the record date is prior to the date of such registration.

7.            ADJUSTMENTS.

This Option, including the number of Shares subject to this Option and the Exercise Price, shall be subject to

adjustment from time to time as provided for in the Plan upon the occurrence of certain events described therein.

8.            TAXES.

The Participant acknowledges that any income or other taxes due from him or her with respect to this Option or
the Shares issuable pursuant to this Option shall be the Participant’s responsibility. The Participant acknowledges and
agrees  that  (i)  the  Participant  was  free  to  use  professional  advisors  of  his  or  her  choice  in  connection  with  his  or  her
acceptance  of  this  Option,  has  received  advice  from  his  or  her  professional  advisors  in  connection  with  his  or  her
acceptance of this Option, understands its meaning and import, and has accepted this Option freely and without coercion
or duress; (ii) the Participant has not received and is not relying upon any advice, representations or assurances made by
or on behalf of the Company or any Affiliate or any employee of or counsel to the Company or any Affiliate regarding
any tax or other effects or implications of this Option, the Shares subject to this Option or other matters contemplated
hereby; and (iii) neither the Administrator, the Company, its Affiliates, nor any of its or their officers or directors, shall
be held liable for any applicable costs, taxes, or penalties associated with this Option if, in fact, the Internal Revenue
Service were to determine that this Option constitutes deferred compensation under Section 409A of the Code.

The Participant agrees that the Company may withhold from the Participant’s remuneration, if any, the amount
of federal, state and local withholding taxes attributable to such amount that is considered compensation includable in
such  person’s  gross  income  in  connection  with  the  exercise  of  this  Option  and,  as  a  condition  to  the  exercise  of  this
Option, the Participant shall make arrangements satisfactory to the Company to enable it to satisfy all such withholding
requirements. Without limiting the generality of the foregoing, at the Company’s discretion, the amount required to be
withheld  may  be  withheld  in  cash  from  such  remuneration,  or  in  kind  from  the  Shares  otherwise  deliverable  to  the
Participant on exercise of this Option. The Participant further agrees that, to the extent the Company does not withhold
an amount from the Participant’s remuneration sufficient to satisfy the Company’s income tax withholding obligation,
the Participant will reimburse the Company on demand, in cash, for the amount under-withheld.

9.            SECURITIES LAWS COMPLIANCE.

The  Participant  specifically  acknowledges  and  agrees  that  this  Option  and  any  delivery  of  Shares  hereunder
shall be subject to compliance with the requirements of the Securities Act and other applicable securities laws, rules or
regulations. In addition, applicable securities laws, rules or regulations may restrict the ability of the Participant to resell
Shares delivered hereunder, including due to the Participant’s affiliation with the Company. The Company shall not be
obligated to issue the Shares if such issuance would violate any applicable securities law, rule or regulation.

10.          NO OBLIGATION TO MAINTAIN RELATIONSHIP.

The Participant acknowledges that: (i) the Company is not by the Plan or this Option obligated to continue the
Participant as an Employee, director or Consultant of the Company or an Affiliate; (ii) the Plan is discretionary in nature
and  may  be  suspended  or  terminated  by  the  Company  at  any  time;  (iii)  the  grant  of  this  Option  is  a  one-time  benefit
which does not create any contractual or other right to receive future grants of options, or benefits in lieu of options; (iv)
all determinations with respect to future grants, if any, will be at the sole discretion of the Company; (v) the Participant’s
participation  in  the  Plan  is  voluntary;  (vi)  the  value  of  this  Option  is  an  extraordinary  item  of  compensation  which  is
outside  the  scope  of  the  Participant’s  employment  or  consulting  contract,  if  any;  and  (vii)  this  Option  is  not  part  of
normal  or  expected  compensation  for  purposes  of  calculating  any  severance,  resignation,  redundancy,  end  of  service
payments, bonuses, long-service awards, pension or retirement benefits or similar payments.

11.          IF OPTION IS INTENDED TO BE AN ISO.

If this Option is designated in the Grant Notice as an ISO, the Participant (or the Participant’s Survivors) may
qualify for the favorable tax treatment provided to holders of options that meet the standards of Section 422 of the Code
and any provision of this Option or the Plan which conflicts with the Code such that this Option would not be deemed an
ISO shall be null and void, and any ambiguities shall be resolved so that this Option qualifies as an ISO. The Participant
should consult with the Participant’s own tax advisors regarding the tax effects of this Option and the

requirements necessary to obtain favorable tax treatment under Section 422 of the Code, including, but not limited to,
holding period requirements.

Notwithstanding the foregoing, to the extent that this Option is designated in the Grant Notice as an ISO, but
would be deemed not to be an ISO pursuant to Section 422(d) of the Code because the Fair Market Value (determined as
of the date of grant of this Option) of Shares with respect to which this Option becomes exercisable for the first time
during any calendar year, when aggregated with the Fair Market Values (determined as of the respective dates of grant of
such ISOs) of Shares with respect to which all other ISOs granted to the Participant become exercisable for the first time
during such calendar year, exceeds $100,000, the portion of this Option representing such excess value shall be treated
as a Non-Qualified Option (applied pro-rata over all vesting tranches of this Option in the applicable calendar year) and
upon exercise the Participant shall have taxable income measured by the difference between the then Fair Market Value
of the Shares received upon exercise and the price paid for such Shares pursuant to this Option.

Neither  the  Company  nor  any  Affiliate  shall  have  any  liability  to  the  Participant,  or  any  other  party,  if  this
Option  (or  any  part  thereof)  is  intended  to  be  an  ISO  but  is  deemed  not  to  be  an  ISO  or  for  any  action  taken  by  the
Administrator, including without limitation the conversion of an ISO to a Non-Qualified Option.

12.          NOTICE TO COMPANY OF DISQUALIFYING DISPOSITION OF AN ISO.

If  this  Option  is  designated  in  the  Grant  Notice  as  an  ISO,  the  Participant  agrees  to  notify  the  Company  in
writing immediately after the Participant makes a Disqualifying Disposition of any of the Shares acquired pursuant to
the  exercise  of  this  Option.  A  “Disqualifying  Disposition”  is  defined  in  Section  424(c)  of  the  Code  and  includes  any
disposition (including any sale) of such Shares before the later of (a) two years after the date the Participant was granted
the ISO or (b) one year after the date the Participant acquired Shares by exercising the ISO, except as otherwise provided
in Section 424(c) of the Code. If the Participant has died before the Shares are sold, these holding period requirements
do not apply and no Disqualifying Disposition can occur thereafter.

13.          NOTICES.

Any  notices  required  or  permitted  by  the  terms  of  this  Agreement  or  the  Plan  shall  be  given  by  recognized

courier service, registered or certified mail, return receipt requested, addressed as follows:

If to the Company:

Intercept Pharmaceuticals, Inc.
10 Hudson Yards, 37  Floor
New York, NY 10001

th

Attention: General Counsel

If to the Participant at the address set forth on the Grant Notice or to such other address or addresses of which notice in
the same manner has previously been given. Any such notice shall be deemed to have been given upon the earlier of
receipt, one business day following delivery to a recognized courier service or three business days following mailing by
registered or certified mail.

The Company may, in its sole discretion, decide to deliver any documents related to participation in the Plan
and  this  Option  by  electronic  means.  By  accepting  this  Option,  whether  electronically  or  otherwise,  the  Participant
consents to receive such documents by electronic delivery and to participate in the Plan through an online or electronic
system established and maintained by the Company or another third party designated by the Company.

14.          GOVERNING LAW.

The Grant Notice and this Agreement shall be governed by and construed in accordance with the laws of the
State of Delaware, without giving effect to the conflict of law principles thereof. For the purpose of litigating any dispute
that arises under the Grant Notice, this Agreement or the Plan, each of the Company and, by accepting this

Option, whether electronically or otherwise, the Participant hereby consents to exclusive jurisdiction in New York and
agrees that such litigation shall be conducted in the state courts of New York County, New York or the federal courts of
the United States for the District of the Southern District of New York.

15.          BENEFIT OF AGREEMENT.

Subject to the provisions of the Plan and the other provisions hereof, the Grant Notice and this Agreement shall
be for the benefit of and shall be binding upon the heirs, executors, administrators, successors and assigns of the parties
hereto.

16.          ENTIRE AGREEMENT.

The Grant Notice and this Agreement, together with the Plan, embodies the entire agreement and understanding
between the parties hereto with respect to the subject matter hereof and supersedes all prior oral or written agreements
and understandings relating to the subject matter hereof. No statement, representation, warranty, covenant or agreement
not expressly set forth in the Grant Notice or this Agreement shall affect or be used to interpret, change or restrict the
express terms and provisions of the Grant Notice or this Agreement; provided,  however, in any event, the Grant Notice
and this Agreement shall be subject to and governed by the Plan. This Option is subject to all applicable laws, rules, and
regulations, and to such approvals by any governmental agencies or national securities exchanges as may be required. In
addition, this Option (and any compensation paid or shares issued pursuant to this Option) is subject to recoupment in
accordance with The Dodd-Frank Wall Street Reform and Consumer Protection Act and any implementing regulations
thereunder, any clawback policy adopted by the Company and any compensation recovery policy otherwise required by
applicable law.

17.          MODIFICATIONS AND AMENDMENTS.

The terms and provisions of the Grant Notice and this Agreement may be modified or amended as provided in

the Plan.

18.          WAIVERS AND CONSENTS.

Except  as  provided  in  the  Plan,  the  terms  and  provisions  of  the  Grant  Notice  and  this  Agreement  may  be
waived, or consent for the departure therefrom granted, only by written document executed by the party entitled to the
benefits of such terms or provisions. No such waiver or consent shall be deemed to be or shall constitute a waiver or
consent with respect to any other terms or provisions of the Grant Notice or this Agreement, whether or not similar. Each
such waiver or consent shall be effective only in the specific instance and for the purpose for which it was given, and
shall not constitute a continuing waiver or consent.

19.          DATA PRIVACY.

By accepting this Option, whether electronically or otherwise, the Participant: (i) authorizes the Company and
each Affiliate, and any agent of the Company or any Affiliate administering the Plan or providing Plan recordkeeping
services,  to  disclose  to  the  Company  or  any  of  its  Affiliates  such  information  and  data  as  the  Company  or  any  such
Affiliate shall request in order to facilitate the grant of options and the administration of the Plan; (ii) waives any data
privacy  rights  he  or  she  may  have  with  respect  to  such  information  or  the  sharing  of  such  information;  and  (iii)
authorizes the Company and each Affiliate to store and transmit such information in electronic form for the purposes set
forth in the Grant Notice and this Agreement.

20.          SEVERABILITY.

If  all  or  any  part  of  the  Grant  Notice,  this  Award  Agreement  or  the  Plan  is  declared  by  any  court  or
governmental authority to be unlawful or invalid, such unlawfulness or invalidity will not invalidate any portion of the
Grant Notice, this Award Agreement or the Plan not declared to be unlawful or invalid. Any section of the Grant Notice,
this Award Agreement or the Plan (or part of such a section) so declared to be unlawful or invalid shall, if possible, be
construed in a manner which will give effect to the terms of such section or part of a section to the fullest extent possible
while remaining lawful and valid.

21.          NON-U.S. PARTICIPANTS.

If the Participant works and/or resides outside of the United States, the applicable terms and conditions set forth
in Appendix A shall apply to this Option. In addition, the Company reserves the right to impose other requirements on
the  Participant  to  the  extent  the  Company  determines  that  such  requirements  are  necessary  or  advisable  in  order  to
comply with local law or facilitate the administration of the Plan and to require the Participant to sign any additional
agreements or undertakings that may be necessary to accomplish the foregoing.

INTERCEPT PHARMACEUTICALS, INC.
2012 EQUITY INCENTIVE PLAN
STOCK OPTION AGREEMENT

TERMS AND CONDITIONS FOR NON-U.S. PARTICIPANTS

APPENDIX A

This Appendix includes additional or different terms and conditions that govern this Option if the Participant
works and/or resides outside of the United States. This Appendix forms part of the Stock Option Agreement to which it
is attached (the “Agreement”). Capitalized terms not defined in this Appendix but defined in the Agreement or the Plan
will  have  the  meanings  assigned  to  such  terms  in  the  Agreement  or  the  Plan,  as  applicable.  References  within  this
Appendix to “you” refer to the Participant.

These terms are general in nature, may not apply to your particular situation and are based on securities, tax and
other laws that are often complex and subject to frequent change. As such, the Company strongly recommends that you
do  not  rely  on  this  summary  as  your  only  source  of  information  relating  to  the  consequences  of  your  Option  and
participation in the Plan and further that you consult your personal tax or legal advisors for advice as to how the laws in
your country apply to your situation. Note that if you are a citizen or resident of a country other than the one in which
you are working, additional requirements, other than those described herein, may be applicable to you.

1.            TAXES (REPLACING SECTION 8 OF THE AGREEMENT)

ALL NON-U.S. PARTICIPANTS

The Participant acknowledges that any income or other taxes due from him or her with respect to this Option or
the  Shares  issuable  pursuant  to  this  Option  shall  be  the  Participant’s  responsibility.  The  Participant
acknowledges and agrees that (i) the Participant was free to use professional advisors of his or her choice in
connection with his or her acceptance of this Option, has received advice from his or her professional advisors
in connection with his or her acceptance of this Option, understands its meaning and import, and has accepted
this Option freely and without coercion or duress; and (ii) the Participant has not received and is not relying
upon any advice, representations or assurances made by or on behalf of the Company or any Affiliate or any
employee of or counsel to the Company or any Affiliate regarding any tax or other effects or implications of
this Option, the Shares subject to this Option or other matters contemplated hereby.

The Participant agrees that the Company may withhold from the Participant’s remuneration, if any, the statutory
or  contractual  amount  of  any  federal,  provincial,  state,  local  and  personal  income  taxes,  wage  tax  and  social
security contributions (including, as applicable, UK National Insurance Contributions of any kind and Canada
Pension Plan contributions) required by law or contract to be withheld or that the Participant has elected to bear
(including, as applicable, employer National Insurance Contributions) in relation to the grant or exercise of this
Option (“Participant Tax Liability”) and, as a condition to the grant or exercise of this Option (as applicable),
the Participant shall make arrangements satisfactory to the Company to enable it to satisfy all such withholding
requirements.  Without  limiting  the  generality  of  the  foregoing,  at  the  Company’s  discretion,  the  amount
required to be withheld may be withheld in cash from such remuneration. The Participant further agrees that, to
the extent the Company does not withhold an amount from the Participant’s remuneration sufficient to satisfy
the Company’s income or wage tax and social security withholding obligation, the Participant will reimburse
the Company on demand, in cash, for the amount under-withheld.

2.                        WAIVER  OF  RIGHTS  ON  TERMINATION  (EXCEPT  FRANCE,  PORTUGAL,  SPAIN  AND

DENMARK)

The Participant hereby waives all and any rights to compensation or damages in consequence of the termination
of his or her office or employment with the Company or his or her employing entity for any reasons whatsoever
(whether  lawful  or  unlawful  and  including,  without  prejudice  to  the  generality  of  the  foregoing,  in
circumstances giving rise to a claim for wrongful dismissal) insofar as those rights arise or may

arise from his or her ceasing to have rights under or being entitled to exercise this Option as a result of such
termination, or from the loss or diminution in value of any rights or entitlements in connection with the Plan.

The Plan and this Option do not form part of the Participant’s contract of employment. If the Participant ceases
to  be  employed  or  engaged  by  the  Company  or  any  Affiliate  for  any  reason  (including  as  a  result  of  a
repudiatory  breach  of  contract  by  the  Company  or  its  Affiliate),  the  Participant  shall  not  be  entitled,  and  by
participating in the Plan the Participant shall be deemed irrevocably to have waived any entitlement, by way of
compensation  for  loss  of  employment,  breach  of  contract  or  otherwise,  to  any  sum  or  other  benefit  to
compensate the Participant for any rights or prospective rights under the Plan. This exclusion applies equally
(and without limitation) to any loss arising from the way in which the discretion is (or is not) exercised under
any provision of the Plan even if the exercise (or non-exercise) of such discretion is, or appears to be, irrational
or perverse and/or breaches, or is claimed to breach any implied term of the Plan or any other contract between
the Participant and the Participant’s employer. Participation in the Plan and any benefits provided under it shall
not  be  pensionable  nor  will  they  count  as  pay  or  remuneration  when  calculating  salary  related  benefits
(including, but not limited to, pension).

3.                        DATA  PRIVACY  (IN  ADDITION  TO  SECTION  19  OF  THE  AGREEMENT)  (EXCEPT  ITALY,

PORTUGAL AND SPAIN)

(a)          The Participant hereby explicitly and unambiguously consents to the collection, use and transfer, in
electronic or other form, of his or her personal data as described in the Agreement by and among, as
applicable, his or her employing entity or contracting party and the Company for the exclusive purpose
of implementing, administering and managing his or her participation in the Plan.

(b)          The Participant acknowledges the following:

(i)           the Company holds certain personal information about the Participant, including, but not
limited  to,  his  or  her  name,  home  address  and  telephone  number,  work  location  and  phone
number, date of birth, hire date, bank and payroll details, social security numbers, details of
all awards or any other entitlement to shares awarded, cancelled, exercised, vested, unvested
or outstanding in the Participant’s favor, for the purpose of implementing, administering and
managing the Plan (“Personal Data”);

(ii)          providing or transferring Personal Data to the Company is necessary and essential to the
Participant’s  participation  in  the  Plan  and  that  the  Participant’s  refusal  to  provide  Personal
Data  or  withdrawal  of  consent  to  the  collection,  storage  or  transfer  of  Personal  Data  may
affect the Participant’s ability to participate in the Plan since it would be impossible for the
Company to comply with its contractual obligations under the Plan;

(iii)                  the  Participant’s  Personal  Data  may  be  transferred  to  any  third  parties  assisting  in  the
implementation,  administration  and  management  of  the  Plan,  that  these  recipients  may  be
located  in  the  Participant’s  country  or  elsewhere,  and  that  the  recipient’s  country  may  have
different data privacy laws and protections than the Participant’s country;

(iv)         the Participant has been informed that the Company shall not transfer Personal Data from the
Participant’s country without requiring the recipient to comply with the requirements of the
General Data Protection Regulation (as applicable) and applicable data protection laws, and
that the Participant may request a list with the names and addresses of any potential recipients
of the Personal Data by contacting his or her local human resources representative;

(v)          Personal Data will be held only as long as is necessary to implement, administer and manage
the Participant’s participation in the Plan and any potential claim made by the Participant in
relation to any award; and

(vi)         the Participant may, at any time, exercise the right of access, rectification and cancelation of
the Participant’s personal data, oppose, request additional information about the storage and
processing  of  Personal  Data  or  refuse  to  the  further  processing  of  the  Personal  Data  by
contacting  in  writing  the  Participant’s  local  human  resources  representative  (who  can  be
identified on the Company’s intranet).

ADDITIONAL COUNTRY-SPECIFIC PROVISIONS

AUSTRALIA

Financial product advice:  The Participant acknowledges and agrees that advice provided by the Company (if
any) in relation to this Option is of a general nature only and does not take into account the objectives, financial
situation  or  needs  of  the  Participant.  The  Participant  should  consider  obtaining  advice  from  a  person  who  is
licensed  by  the  Australian  Securities  and  Investments  Commission  to  give  such  advice.  The  Company  is  not
licensed  to  provide  financial  product  advice  in  Australia  in  relation  to  options  and  there  is  no  cooling-off
regime in Australia that applies in respect of the grant of options.

Risk of acquiring and holding Common Stock:  The Participant acknowledges that there are risks of acquiring
and holding Common Stock. Before accepting or exercising this Option, or acquiring the underlying Shares, the
Participant should satisfy himself or herself that he or she has a sufficient understanding of these matters and
should  consider  whether  Common  Stock  is  a  suitable  investment  for  the  Participant,  having  regard  to  the
investment objectives, financial circumstances and taxation position of the Participant.

(a)          The price at which Common Stock is quoted on the Nasdaq Global Select Market may decrease, even
to the extent that the price is less than the price or prices paid for the Shares by the Participant.

(b)          There is no guarantee that an active market in Common Stock will continue. The number of potential
buyers or sellers of Common Stock on the Nasdaq Global Select Market may vary at any time. This
may increase the volatility of the market price of Common Stock.

(c)                    The  Company  may  not  pay  dividends  on  Common  Stock  at  any  particular  level  or  at  all.  If  the

Company has paid dividends on Common Stock, it may cease to pay such dividends.

(d)          Holding Common Stock may have tax implications for the Participant and the tax regime applying to

the Participant may change.

Market  price  of  Common  Stock:    The  Participant  could,  from  time  to  time,  ascertain  the  market  price  of
Common  Stock  in  Australian  Dollars  by  obtaining  the  market  price  from  the  Nasdaq  Global  Select  Market
website,  the  Company’s  website  or  applicable  U.S.  publication,  and  multiplying  that  market  price  by  a
published exchange rate to convert U.S. Dollars into Australian Dollars.

BELGIUM

Timing and calculation basis of taxation. You are required to accept the offer of this Option in writing. If this
Option is accepted by you on or prior to the 60th day following the offer, you will recognize taxable income on
the  60th  day  following  the  date  of  the  offer  (date  of  grant),  and  you  will  be  required  to  include  the  taxable
income  within  your  yearly  income  tax  return  covering  the  financial  year  during  which  occurred  the  date  of
grant. You will not be subject to income tax upon exercise of this Option. The amount of the taxable income is
calculated as a certain percentage of the fair market value of the underlying shares at the date of the offer. The
income will be taxed as compensation income and subject to income tax and social security contributions.
If this Option is only accepted by you after the 60th day following the date of the offer, you will not recognize
taxable income on the date of grant but upon exercise, and you will be required to include the taxable income
within  your  yearly  income  tax  return  covering  the  financial  year  during  which  occurred  the  exercise  of  this
Option. The amount of taxable income will then be calculated on the basis of the fair market value of the stock
acquired.  The  income  will  be  taxed  as  compensation  income  and  subject  to  income  tax  and  social  security
contributions.

Capital gains on sale. The capital gains on the sale of the stock are not taxable to the extent you qualify as a
Belgian tax resident.

CANADA

Term of Option.  For purposes of Section 2 of the Agreement, “Termination Date” means the later of: (i) the
date  that  is  the  last  day  of  any  statutory  notice  period  applicable  to  the  Participant  pursuant  to  applicable
employment standards legislation; and (ii) the date that is designated by the Company or Affiliate to which the
Participant provides services as the last day of the Participant’s employment, term of office or engagement with
the Company or Affiliate (as applicable); provided, that in the case of termination of employment by voluntary
resignation by the Participant, such date shall not be earlier than the date notice of resignation was given. For
certainty,  except  only  as  expressly  required  by  applicable  employment  standards  legislation,  as  amended  or
replaced, or agreed by the Company, no portion of this Option shall vest following the Participant’s Termination
Date and no period of notice or payment in lieu of notice in respect of a termination of an office or employment
without Cause shall extend such Termination Date.

Method of Exercising Option.  Payment of the Exercise Price for the Shares with respect to which this Option is
exercised may not be made in either of the forms described in clause (b) or clause (c) of Paragraph 9 of the
Plan.

DENMARK

Danish  Stock  Option  Act.    In  accepting  this  Option,  you  acknowledge  that  you  have  received  an  Employer
Statement  translated  into  Danish,  which  is  being  provided  to  comply  with  the  Danish  Stock  Option  Act  and
which sets out the main terms of the Plan applying to you. To the extent more favorable to you and required to
comply with the Stock Option Act, the terms set forth in the Employer Statement, including terms regarding
vesting and forfeiture in connection with termination of your employment will apply to your participation in the
Plan.

Exchange Control Notification.  If you establish an account holding Shares or cash outside Denmark, you must
report  the  account  to  the  Danish  Tax  Administration.  The  form  which  should  be  used  in  this  respect  can  be
obtained  from  a  local  bank.  (Please  note  that  these  obligations  are  separate  from  and  in  addition  to  the
obligations described below.)

Securities and Tax Reporting Notification.  You may hold Shares acquired under the Plan in a safety-deposit
account (e.g., a brokerage account) with either a Danish bank or with an approved foreign broker or bank. If the
Shares are held with a foreign broker or bank, you are required to inform the Danish Tax Administration about
the  safety-deposit  account.  For  this  purpose,  you  must  file  a  Form  V  (Erklaering  V)  with  the  Danish  Tax
Administration. Both you and the broker or bank must sign the Form V. By signing the Form V, the broker or
bank  undertakes  an  obligation,  without  further  request  each  year,  to  forward  information  to  the  Danish  Tax
Administration concerning the Shares in the safety-deposit account. In the event that the applicable broker or
bank with which the account is held does not wish to, or pursuant to the laws of the country in question, is not
allowed  to  assume  such  obligation  to  report,  you  will  be  solely  responsible  for  providing  certain  details
regarding the foreign brokerage or bank account and any Shares acquired in connection with the Plan and held
in such account to the Danish Tax Administration as part of your annual income tax return. By signing the Form
V, you authorize the Danish Tax Administration to examine the account. A sample of the Form V can be found
at the following website: www.skat.dk.

In addition, if you open a brokerage account or a bank account with a U.S. bank, the account will be treated as a
deposit account because cash can be held in the account. Therefore, you must also file a Form K (Erklaering K)
with the Danish Tax Administration. Both you and the broker must sign the Form K. By signing the Form K,
the  broker  or  bank,  as  applicable,  undertakes  an  obligation,  without  further  request  each  year,  to  forward
information to the Danish Tax Administration concerning the content of the deposit account. In the event that
the applicable financial institution (broker or bank) with which the account is held does not wish to, or pursuant
to the laws of the country in question, is not allowed to assume such obligation to report,

you will be solely responsible for providing certain details regarding the foreign brokerage or bank account to
the Danish Tax Administration as part of your annual income tax return. By signing the Form K, you authorize
the  Danish  Tax  Administration  to  examine  the  account.  A  sample  of  Declaration  K  can  be  found  at  the
following website: www.skat.dk.

FRANCE

Language Consent.    By  accepting  the  grant,  you  confirm  that  you  have  read  and  understood  the  documents
relating  to  the  grant  (the  Plan,  the  Grant  Notice  and  the  Agreement,  including  this  Appendix)  which  were
provided in the English language. You confirm that you are fluent in English, written and spoken. You accept
the terms of these documents accordingly.

Consentement Relatif à la Langue Utilisée.  En acceptant l’attribution,  vous confirmez avoir lu et compris les
documents  relatifs  à  l’attribution  (le  Plan,  l’Avis  et  le  Contrat,  y  compris  cette  Annexe)  qui  ont  été
communiqués en langue anglaise. Vous acceptez les termes de ces documents en connaissance de cause.

Tax Notification.  This Option is not intended to qualify for favorable tax or social security treatment in France.

Exchange Control Notification.  If you hold Shares outside of France or maintain a foreign bank account, you
are required to report such to the French tax authorities when filing your annual tax return.

GERMANY

Taxes.  The following provision supplements Section 1 of this Appendix A:

For the avoidance of doubt, under Section 1 of this Appendix A (which replaces Section 8 of the Agreement),
the  Company,  inter  alia,  has  the  authority  to  deduct  or  withhold,  or  require  the  Participant  to  remit  to  the
Company,  an  amount  sufficient  to  satisfy  applicable  taxes  (including  wage  taxes  (Lohnsteuern),  solidarity
surcharges  (Solidaritätszuschläge),  church 
taxes  (Kirchensteuern)  and  social  security  contributions
(Sozialversicherungsbeiträge)) arising from or relating to the (i) the grant, vesting or exercise of this Option or
(ii)  the  delivery  of  the  Shares.  For  the  avoidance  of  doubt,  Section  1  of  this  Appendix  A  shall  remain
unaffected.

ITALY

Data Privacy.  The following provision replaces Section 3 of this Appendix A:

You  understand  that  the  Company  and/or  any  Affiliate  may  hold  certain  personal  information  about  you,
including, without limitation, your name, home address and telephone number, date of birth, social insurance or
other identification number, salary, nationality, job title, any Shares or directorships held in the Company or an
Affiliate,  details  of  all  options,  or  any  other  entitlement  to  Shares  awarded,  canceled,  exercised,  vested,
unvested or outstanding in your favor, for the exclusive purpose of implementing, managing, and administering
the Plan (“Data”) and in compliance with applicable laws and regulations.

You also understand that providing the Company with Data is necessary for the performance of the Plan and
that  your  refusal  to  provide  such  Data  would  make  it  impossible  for  the  Company  to  perform  its  contractual
obligations and may affect your ability to participate in the Plan. The Controller of personal data processing is
Intercept Pharmaceuticals, Inc., 10 Hudson Yards, 37th Floor, New York, NY 10001 and pursuant to Art. 6 let.
b)  and  c)  of  the  General  Data  Protection  Regulation  (“GDPR”)  and  Legislative  Decree  no.  196/2003,  its
representative in Italy.

You  understand  that  Data  will  not  be  publicized,  but  it  may  be  transferred  to  the  Company’s  designated
broker/third party administrator for the Plan or such other stock plan service provider as may be selected by the
Company  in  the  future  (any  such  entity,  “Broker”),  or  other  third  parties  involved  in  the  management  and
administration of the Plan. You understand that Data may also be transferred to the independent

registered public accounting firm engaged by the Company. You further understand that the Company and its
Affiliates will transfer Data amongst themselves as necessary for the purposes of implementing, administering
and  managing  your  participation  in  the  Plan,  and  that  the  Company  and/or  any  Affiliate  may  each  further
transfer Data to third parties assisting the Company in the implementation, administration and management of
the Plan, including any requisite transfer of Data to the Broker or other third party with whom you may elect to
deposit any Shares acquired under the Plan. Such recipients may receive, possess, use, retain, and transfer Data
in electronic or other form, for the purposes of implementing, administering, and managing your participation
in  the  Plan.  You  understand  that  these  recipients  may  be  located  in  or  outside  the  European  Economic  Area,
such as in the United States or elsewhere, and in locations that might not provide the same level of protection as
intended under Italian data privacy laws. In such case, the Company undertakes to comply with the applicable
privacy  law  in  order  to  ensure  that  the  recipient  meets  the  same  standards  provided  by  the  European  Union
legislation,  implementing  appropriate  and  suitable  safeguards,  such  as  using  standard  clauses  or  equivalent
safeguard  measures  as  provided  for  by  Art.  46  of  the  GDPR  and  paragraph  7  of  Legislative  Decree  no.
196/2003. Should the Company exercise its discretion in suspending all necessary legal obligations connected
with  the  management  and  administration  of  the  Plan,  it  will  delete  Data  as  soon  as  it  has  completed  all  the
necessary legal obligations connected with the management and administration of the Plan.

You understand that Data processing related to the purposes specified above shall take place under automated
or  non-automated  conditions,  anonymously  when  possible,  that  comply  with  the  purposes  for  which  Data  is
collected and with confidentiality and security provisions, as set forth by applicable laws and regulations, with
specific reference to Art. 6 let. b) and c) of the GDPR and Legislative Decree no. 196/2003.

The  processing  activity,  including  communication,  the  transfer  of  Data  abroad,  including  outside  of  the
European Economic Area, as herein specified and pursuant to applicable laws and regulations, does not require
your  consent  thereto,  as  the  processing  is  necessary  to  performance  of  contractual  obligations  related  to
implementation, administration, and management of the Plan. You understand that, pursuant to Art. 15 of the
GDPR and paragraph 7 of Legislative Decree no. 196/2003, you have the right to, without limitation, access,
delete,  update,  correct,  or  terminate,  for  legitimate  reason,  the  Data  processing.  Additionally,  you  understand
that you may exercise the right to portability, within the limits set forth by Art. 20 of the GDPR.

Furthermore, you are aware that Data will not be used for direct-marketing purposes. In addition, Data provided
can  be  reviewed  and  questions  or  complaints  can  be  addressed  by  contacting  your  local  human  resources
representative.

Grant  Document  Acknowledgment.    In  accepting  the  grant  of  this  Option,  you  acknowledge  that  you  have
received a copy of the Plan, the Grant Notice and the Agreement, including this Appendix, and have reviewed
the Plan, the Grant Notice and the Agreement, including this Appendix, in their entirety and fully understand
and accepts all provisions thereof.

Foreign  Asset  Reporting  Notification.    If  you  are  an  Italian  resident  and,  during  any  fiscal  year,  hold
investments or financial assets outside of Italy (e.g., cash, Shares) which may generate income taxable in Italy
(or  if  you  are  the  beneficial  owner  of  such  an  investment  or  asset  even  if  you  do  not  directly  hold  the
investment or asset), you are required to report such investments or assets on your annual tax return for such
fiscal year (on UNICO Form, RW Schedule, or on a special form if you are not required to file a tax return).

NORWAY

Securities and Tax Reporting Notification.  You may hold Shares acquired under the Plan in a safety-deposit
account (e.g., a brokerage account) with either a Norwegian bank or with an approved foreign broker or bank. If
the Shares are held with a foreign broker or bank, you are required to inform the Norwegian Tax Administration
about the safety-deposit account. You do this on forms RF-1088 and RF-1059 in connection with filing your
annual tax return (“selvangivelse”). Shares held with a Norwegian bank will be reported automatically.

PORTUGAL

Language Consent. By accepting the grant of this Option, you confirm that you have read and understood the
documents relating to the grant (the Plan, the Grant Notice and the Agreement, including this Appendix) which
were provided to you in English language. You confirm that you are fluent in English, written and spoken. You
accept the terms of these documents accordingly.

Grant  Document  Acknowledgment.  In  accepting  the  grant  of  this  Option,  you  acknowledge  that  you  have
received a copy of the Plan, the Grant Notice and the Agreement, including this Appendix, and have reviewed
the Plan, the Grant Notice and the Agreement, including this Appendix, in their entirety and fully understand
and accept all provisions thereof.

Tax Reporting Obligation.  If the Shares acquired under the Plan are held with a foreign broker or bank, you are
required to inform the Portuguese Tax Authorities about the existence of such account. For this purpose, within
the  annual  submission  of  your  personal  income  tax  return  you  must  file  Annex  J  with  the  Portuguese  Tax
Administration,  identifying  the  account  by  reference  to  the  applicable  IBAN  –  International  Bank  Account
Number and BIC - Bank Identifier Code.
Income  arising  out  of  the  Plan  and/or  derived  from  the  Shares  is  subject  to  reporting  to  the  Portuguese  Tax
Authorities.

Data Privacy.  The following provision replaces Section 3 of this Appendix A:

You understand that the Company holds certain personal information about you, including, but not limited to,
your  name,  home  address  and  telephone  number,  work  location  and  phone  number,  date  of  birth,  hire  date,
details  of  all  awards  or  any  other  entitlement  to  shares  awarded,  cancelled,  exercised,  vested,  unvested  or
outstanding in the Participant’s favor, for the purpose of implementing, administering and managing the Plan
(“Personal Data”).

You understand that the providing or transferring of Personal Data to the Company is necessary and essential to
your participation in the Plan and that your refusal to provide Personal Data or withdrawal of consent to the
collection, storage or transfer of Personal Data may affect your ability to participate in the Plan since it would
be impossible for the Company to comply with its contractual obligations under the Plan.

You understand that your Personal Data may be transferred to any third parties assisting in the implementation,
administration and management of the Plan, that these recipients may be located in the Participant’s country or
elsewhere,  and  that  the  recipient’s  country  may  have  different  data  privacy  laws  and  protections  than  the
Participant’s country.

You  were  informed  that  the  personal  data  communicated  outside  of  Portugal  will  be  protected  identically  as
provided for in Law No. 67/98, of 26 October, and that you may request a list with the names and addresses of
any potential recipients of the Personal Data by contacting your local human resources representative.

You authorize the recipients to receive, possess, use, retain and transfer the Personal Data, in electronic or other
form, for the purposes of implementing, administering and managing your participation in the Plan.

You  understand  that  Personal  Data  will  be  held  only  as  long  as  is  necessary  to  implement,  administer  and
manage your participation in the Plan and any potential claim of the Participant.

You understand that you may, at any time, exercise of the right of access, rectification and cancelation of your
personal  data,  oppose,  request  additional  information  about  the  storage  and  processing  of  Personal  Data  or
refuse  or  withdraw  the  consents  herein,  in  any  case  without  cost,  by  contacting  in  writing  your  local  human
resources representative (who can be identified on the Company’s intranet).

SPAIN

Taxes.  The following provision supplements Section 1 of this Appendix A:

Pursuant  to  Royal  Decree-Law  13/2011  of  16  September  (as  amended),  wealth  tax  (Impuesto  sobre  el
Patrimonio) has been temporarily restored in Spain. If the Participant’s only foreign assets are the Shares and
the value of the Shares on 31 December exceeds the specified threshold the Participant will be required to make
a declaration to the Spanish tax authorities between 1 January and 31 March of the immediately following year.
The  Participant  much  declare  foreign  rights  and  assets  including  (i)  ISIN  code  of  Shares;  (ii)  the  name  and
corporate domicile of the issuing company; and (iii) the number, class, and value of the Shares held as of 31
December.

Exchange Controls. The Participant is responsible for complying with exchange control regulations in Spain.
Declaration  of  the  acquisition  of  Shares  for  statistical  purposes  to  the  Dirección  General  de  Comercio  e
Inversiones  (DGCI)  of  Ministerio  de  Economía  is  compulsory  (i)  if  the  purchase  price  exceeds  the  specified
threshold; (ii) if the investor holds a stake of at least 10 percent in the Company; or (iii) if the investor belongs
to the Company’ s board of directors. If Participants purchase any Shares through the use of a Spanish financial
institution, the institution will automatically make the declaration to the DGCI; otherwise the Participant must
make  the  declaration  by  filing  the  appropriate  form  with  the  DGCI.  The  Participant  must  also  declare
ownership of Shares with the DGCI in January of each year.

Data Privacy. The following provisions replace Section 3 of this Appendix A:

The  Participant’s  personal  data  will  be  processed  by  Intercept  Pharmaceuticals,  Inc.  (the  “Data Controller”)
with a corporate domicile at 10 Hudson Yards, 37th Floor, New York, NY 10001.

The  purpose  of  the  processing  is  to  implement  the  Grant  Notice  and  the  Agreement  under  the  Plan,  verify
eligibility  conditions  and  develop  and  perform  the  contractual  and  legal  obligations  arising  thereof.  The
processing of the Participant’s personal data is necessary for such purposes and its legal basis are the execution
and development of the contractual relationship and, if applicable, the compliance with legal duties applicable
to  the  Data  Controller.  Personal  data  will  be  processed  whilst  the  Participant  holds  the  relevant  awards  and,
after  this,  for  six  years,  or,  exceptionally,  for  the  period  during  which  any  kind  of  liability  may  arise  from  a
legal or contractual obligation applicable to the Data Controller.

The Participant’s personal data will be transferred outside the European Economic Area, to the United States,
where  Intercept  Pharmaceuticals,  Inc.  is  located.  A  copy  of  the  relevant  appropriate  safeguards  subscribed  in
order  to  carry  out  such  international  data  transfer  can  be  requested  from  human  resources.  Additionally,  the
Participant’s personal data may be disclosed only to those group companies which may have a legal basis for
processing this personal data.

The Participant may exercise his/her right of access, rights to rectification, erasure, objection, data portability,
restriction  of  processing  and  any  other  right  recognized  by  the  applicable  regulations  from  time  to  time,  by
sending a request to human resources. The Participant may also file any claim or request related to his or her
data  protection  rights  with  the  relevant  supervisory  authority.  The  personal  data  processed  for  the  purposes
described  above  derives  from  the  execution  of  the  Participant’s  employment  agreement  or,  in  case  that  the
Participant is an independent professional, the relevant services agreement.

UNITED KINGDOM

NIC Joint Election.  Unless the Company permits otherwise, this Option may not be exercised unless and until
the Company (or the employing entity) has received from the Participant a duly completed joint election with
the Company and his or her employing entity (in the form prescribed by the Company from time to time) to the
effect that the Participant will become liable, so far as permissible by law, for the whole of employer national
insurance  contributions  which  may  arise  in  connection  with  this  Option  and  the  Shares  which  may  be  or  are
acquired on the exercise of this Option.

Taxes.  The following provision supplements Section 1 of this Appendix A:

The amount of the Participant Tax Liability may be withheld in cash from such remuneration. The Participant
further agrees that, if the Company does not withhold an amount from the Participant’s remuneration sufficient
to satisfy the Participant Tax Liability, the Participant will reimburse the Company on demand, in cash, for the
amount  under-withheld.  Without  limiting  the  foregoing,  the  Participant  agrees  (i)  that  the  Participant  shall,
promptly  upon  being  requested  to  do  so  by  the  Company,  the  Participant’s  employer  or  former  employer  (as
appropriate),  elect  (using  a  form  approved  by  HM  Revenue  &  Customs)  that  the  whole  or  any  part  of  the
liability for employer National Insurance Contributions shall be transferred to the Participant; and (ii) to enter
into  a  joint  election,  under  section  431(1)  or  431(2)  of  the  Income  Tax  (Earnings  &  Pensions)  Act  2003,  in
respect of the Shares delivered pursuant to the award, if required to do so by the Company, the Participant’s
employer or former employer, before, on or within 14 days after any date of delivery of such Shares.

Exhibit 10.5

Restricted Stock Unit No.________

INTERCEPT PHARMACEUTICALS, INC.
2012 EQUITY INCENTIVE PLAN
RESTRICTED STOCK UNIT GRANT

Restricted Stock Unit Grant Notice (Employees and Consultants)

Intercept Pharmaceuticals, Inc. (the “Company”) hereby grants to the participant named below (the “Participant”) the
number of restricted stock units (“RSUs”) set forth below (this “Award”). This Award is subject to all of the terms and
conditions set forth in this Restricted Stock Unit Grant Notice (this “Grant Notice”), the Intercept Pharmaceuticals, Inc.
2012 Equity Incentive Plan (the “Plan”) and the Restricted Stock Unit Agreement attached hereto (the “Agreement”).
Capitalized  terms  not  defined  in  this  Grant  Notice  but  defined  in  the  Agreement  or  the  Plan  will  have  the  meanings
assigned to such terms in the Agreement or the Plan, as applicable. Except as expressly provided in the Agreement, in
the  event  of  any  conflict  between  the  provisions  of  this  Grant  Notice  or  the  Agreement  and  those  of  the  Plan,  the
provisions of the Plan will control.

1.

Name and Address of Participant:

2.

3.

4.

Date of Grant:

Number of RSUs:

Vesting Commencement Date:

5.                      Vesting  Schedule:    This  Award  shall  vest  as  follows  provided  the  Participant  is  an  Employee,  director  or
Consultant of the Company or an Affiliate on the applicable vesting date (see vesting schedule below):

[INSERT VESTING SCHEDULE]

See Section 2(c) of the Agreement for vesting in the event of a Change of Control (as defined in the Agreement).

By accepting this Award, whether electronically or otherwise, the Participant acknowledges receipt of, and understands
and agrees to, this Grant Notice, the Agreement and the Plan. Unless otherwise specified in a written agreement between
the  Company  and  the  Participant,  this  Grant  Notice,  the  Agreement  and  the  Plan  set  forth  the  entire  understanding
between the Participant and the Company regarding this Award and supersede all prior oral and written agreements on
the terms of this Award.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
INTERCEPT PHARMACEUTICALS, INC.
2012 EQUITY INCENTIVE PLAN
RESTRICTED STOCK UNIT AGREEMENT

Pursuant to the Restricted Stock Unit Grant Notice to which this agreement is attached (the “Grant Notice”)
and  this  Restricted  Stock  Unit  Agreement  (this  “Agreement”),  Intercept  Pharmaceuticals,  Inc.  (the  “Company”)  has
granted to the participant named in the Grant Notice (the “Participant”) a Restricted Stock Unit Award (this “Award”),
under and for the purposes set forth in the Intercept Pharmaceuticals, Inc. 2012 Equity Incentive Plan (the “Plan”), for
the  number  of  Restricted  Stock  Units  (“RSUs”)  indicated  in  the  Grant  Notice.    Capitalized  terms  not  defined  in  this
Agreement or in the Grant Notice but defined in the Plan will have the meanings assigned to such terms in the Plan.

The terms and conditions of this Award, in addition to those set forth in the Grant Notice and the Plan, are as

follows:

1.            GRANT OF AWARD.

This Award represents the Participant’s right to receive one share of the Company’s common stock, par value
$0.001  per  share  (the  “Shares”),  for  each  RSU  that  vests.  Such  Shares  shall  be  delivered  by  the  Company  to  the
Participant within five days of the applicable vesting date and in accordance with this Agreement and the Plan. Except as
otherwise provided herein, the Participant will not be required to make any payment to the Company (other than past
and future services to the Company) with respect to the Participant’s receipt of this Award, the vesting of the RSUs or
the delivery of the Shares to be issued in respect of this Award.

2.            VESTING OF AWARD.

(a)          Subject to the terms and conditions set forth in this Agreement and the Plan, this Award shall vest as
set forth in the Grant Notice. This Award shall continue to vest in accordance with its terms for so long as the Participant
is an Employee, director or Consultant of the Company or an Affiliate.

(b)          Except as otherwise set forth in this Agreement, if the Participant ceases to be an Employee, director
or Consultant of the Company or of an Affiliate for any reason other than the termination of the Participant for Cause
(the  date  of  such  cessation  of  service,  the  “Termination Date”),  then  as  of  the  Termination  Date,  all  unvested  RSUs
shall immediately be forfeited at no cost to the Company and this Agreement shall terminate and be of no further force
or effect; provided,  however, that, in the event that this Award vests in equal annual installments and, following the first
anniversary of the Vesting Commencement Date specified in the Grant Notice, the Participant’s employment with the
Company  or  an  Affiliate  terminates  by  reason  of  death  or  Disability  or,  other  than  in  the  circumstances  described  in
Section 2(c) below, an involuntary termination of employment without Cause, then (i) if the Termination Date is three
(3) months or less before the next scheduled vesting date, 75% of the RSUs that were otherwise eligible to vest on such
vesting  date  shall  become  fully  vested  as  of  the  Termination  Date,  (ii)  if  the  Termination  Date  is  more  than  three  (3)
months but no more than six (6) months before the next scheduled vesting date, 50% of the RSUs that were otherwise
eligible to vest on such vesting date shall become fully vested as of the Termination Date, (iii) if the Termination Date is
more than six (6) months but no more than nine (9) months before the next scheduled vesting date, 25% of the RSUs that
were otherwise eligible to vest on such vesting date shall become fully vested as of the Termination Date or (iv) if the
Termination Date is more than nine (9) months before the next scheduled vesting date, none of such RSUs shall vest and,
in each case, any outstanding RSUs that do not vest in accordance with this Section 2(b) shall be forfeited at no cost to
the Company as of the Termination Date.

In the event the Participant’s service is terminated by the Company or an Affiliate for Cause, then as of the time
the Participant is notified his or her service is terminated for Cause, all unvested RSUs shall immediately be forfeited at
no cost to the Company and this Agreement shall terminate and be of no further force or effect.

(c)                    Notwithstanding  the  foregoing,  except  to  the  extent  specifically  provided  to  the  contrary  in  any
employment agreement between the Participant and the Company or an Affiliate, in the event of (i) a Change of Control
(as  defined  below)  and  the  Participant’s  service  with  the  Company,  the  acquiring  or  succeeding  corporation  or  any
Affiliate of any of the foregoing is terminated by such entity for any reason other than for Cause within 12 months of the
Change  of  Control,  then,  immediately  prior  to  such  termination,  all  of  the  RSUs  subject  to  this  Award  that  are  then
unvested  shall  become  fully  vested,  or  (ii)  a  Corporate  Transaction  (as  defined  in  Section  24(b)  of  the  Plan)  that  is  a
Change of Control in which the acquiring entity does not assume this Award, then, immediately prior to the Change of
Control, all of the RSUs subject to this Award that are then unvested shall become fully vested.

For purposes of this Agreement, “Change of Control” means the occurrence of any of the following events:

(i)           Ownership.  Any “Person” (as such term is used in Sections 13(d) and 14(d) of the Securities
Exchange  Act  of  1934,  as  amended)  becomes  the  “Beneficial  Owner”  (as  defined  in  Rule  13d-3  under  said
Act), directly or indirectly, of securities of the Company representing 50% or more of the total voting power
represented by the Company’s then-outstanding voting securities (excluding for this purpose any such voting
securities held by the Company or its Affiliates or any employee benefit plan of the Company); or

(ii)                    Merger/Sale  of  Assets.    (A)  A  merger  or  consolidation  of  the  Company  whether  or  not
approved  by  the  Board  of  Directors,  other  than  a  merger  or  consolidation  which  would  result  in  the  voting
securities of the Company outstanding immediately prior thereto continuing to represent (either by remaining
outstanding  or  by  being  converted  into  voting  securities  of  the  surviving  entity  or  the  parent  of  such
corporation) more than 50% of the total voting power represented by the voting securities of the Company or
such  surviving  entity  or  parent  of  such  corporation,  as  the  case  may  be,  outstanding  immediately  after  such
merger  or  consolidation;  or  (B)  the  sale  or  disposition  by  the  Company  of  all  or  substantially  all  of  the
Company’s assets in a transaction requiring stockholder approval; or

(iii)         Change in Board Composition.  A change in the composition of the Board of Directors, as a
result of which fewer than a majority of the directors are Incumbent Directors. “Incumbent Directors”  shall
mean  directors  who  either  (A)  are  directors  of  the  Company  as  of  the  date  of  grant,  or  (B)  are  elected,  or
nominated  for  election,  to  the  Board  of  Directors  with  the  affirmative  votes  of  at  least  a  majority  of  the
Incumbent  Directors  at  the  time  of  such  election  or  nomination  (but  shall  not  include  an  individual  whose
election  or  nomination  is  in  connection  with  an  actual  or  threatened  proxy  contest  relating  to  the  election  of
directors to the Company).

(iv)         “Change of Control” shall be interpreted, if applicable, in a manner, and limited to the extent

necessary, so that it will not cause adverse tax consequences under Section 409A of the Code.

3.            PROHIBITIONS ON TRANSFER.

This  Award  (including  any  additional  RSUs  received  by  the  Participant  as  a  result  of  stock  dividends,  stock
splits or any other similar transaction affecting the Company’s securities without receipt of consideration) shall not be
transferable by the Participant otherwise than (i) by will or by the laws of descent and distribution, or (ii) pursuant to a
qualified domestic relations order as defined by the Code or Title I of the Employee Retirement Income Security Act or
the rules thereunder. Except as provided above in this Section 3, the Shares to be issued pursuant to this Award shall be
issued during the Participant’s lifetime only to the Participant (or, in the event of legal incapacity or incompetency, to the
Participant’s  guardian  or  representative).  This  Award  shall  not  be  assigned,  pledged  or  hypothecated  in  any  way
(whether  by  operation  of  law  or  otherwise)  and  shall  not  be  subject  to  execution,  attachment  or  similar  process. Any
attempted  transfer,  assignment,  pledge,  hypothecation  or  other  disposition  of  this  Award  or  of  any  rights  granted
hereunder contrary to the provisions of this Section 3, or the levy of any attachment or similar process upon this Award
shall be null and void.

4.            NO RIGHTS AS STOCKHOLDER.

Subject to Section 5 below, the Participant shall have no rights as a stockholder with respect to the Shares to be
issued  pursuant  to  this  Award  until  registration  of  the  Shares  in  the  Company’s  share  register  in  the  name  of  the
Participant.

5.            ADJUSTMENTS AND CASH DIVIDENDS.

(a)          This Award, including the number of RSUs subject to this Award, shall be subject to adjustment from

time to time as provided for in the Plan upon the occurrence of certain events described therein.

(b)          To the extent that the Company declares and pays any cash dividend on its Common Stock while any
RSUs  subject  to  this  Award  are  unvested,  the  Participant  shall  be  eligible  to  receive  upon  vesting  of  such  RSUs  an
amount equal to the amount of such dividend that the Participant would have received had the Shares underlying such
RSUs been issued and held by the Participant at the time at which such dividend was declared; it being understood that
no such amount shall be payable with respect to any RSUs that are forfeited.

6.            TAXES.

The Participant acknowledges that any income or other taxes due from him or her with respect to this Award or
the  Shares  issuable  pursuant  to  this  Award  shall  be  the  Participant’s  responsibility.  The  Participant  acknowledges  and
agrees  that  (i)  the  Participant  was  free  to  use  professional  advisors  of  his  or  her  choice  in  connection  with  his  or  her
acceptance  of  this  Award,  has  received  advice  from  his  or  her  professional  advisors  in  connection  with  his  or  her
acceptance of this Award, understands its meaning and import, and has accepted this Award freely and without coercion
or duress; and (ii) the Participant has not received and is not relying upon any advice, representations or assurances made
by  or  on  behalf  of  the  Company  or  any  Affiliate  or  any  employee  of  or  counsel  to  the  Company  or  any  Affiliate
regarding  any  tax  or  other  effects  or  implications  of  this  Award,  the  Shares  issuable  pursuant  to  this  Award  or  other
matters contemplated hereby.

Without limiting the foregoing, the Participant agrees that if under applicable law the Participant will owe taxes
upon  the  vesting  of  RSUs  subject  to  this  Award,  the  Company  shall  be  entitled  to  immediate  payment  from  the
Participant of the amount of any tax required to be withheld by the Company. Any taxes due shall be paid, at the option
of the Company, as follows (or utilizing such other arrangement as may be specified by the Company):

  (a)                  through  reducing  the  number  of  Shares  otherwise  entitled  to  be  issued  to  the  Participant  on  the

applicable vesting date in an amount equal to the amount of withholding tax due and payable by the Company;

  (b)                  requiring  the  Participant  to  deposit  with  the  Company  an  amount  of  cash  equal  to  the  amount
determined by the Company to be required with respect to the Participant’s estimated total federal, state and local tax
obligations  or  otherwise  withholding  from  the  Participant’s  remuneration  an  amount  equal  to  the  withholding  tax  due
and payable; or

 (c)         requiring the Participant to make an automatic sale, effected by a broker-dealer designated by the
Company,  of  a  portion  of  the  Shares  issued  to  the  Participant  on  the  applicable  vesting  date  sufficient  to  cover  the
applicable  tax  withholding  obligation  arising  upon  such  vesting,  with  the  proceeds  thereof  to  be  remitted  to  the
Company to satisfy such tax withholding obligation. To the extent that the proceeds of such sale exceed the Company’s
tax withholding obligation, such excess cash shall be paid to the Participant as soon as practicable. In addition, if such
sale is not sufficient to pay the Company’s tax withholding obligation, the Participant agrees to pay to the Company as
soon as practicable, including through additional payroll withholding, the amount of any tax withholding obligation that
is not satisfied by the sale of Shares. The Participant agrees to hold the Company and the broker-dealer harmless from all
costs, damages or expenses relating to any such sale. The Participant acknowledges that the Company and the broker-
dealer are under no obligation to arrange for such sale at any particular price. In connection with such sale of Shares, the
Participant shall execute any such documents requested by the broker-dealer in order to effectuate the sale of Shares and
payment of the proceeds to the Company.

The Company shall not deliver any Shares to the Participant until it is satisfied that all required withholdings

have been made.

7.            SECURITIES LAWS COMPLIANCE.

The  Participant  specifically  acknowledges  and  agrees  that  this  Award  and  any  delivery  of  Shares  hereunder
shall be subject to compliance with the requirements of the Securities Act and other applicable securities laws, rules or
regulations. In addition, applicable securities laws, rules or regulations may restrict the ability of the Participant to resell
Shares delivered hereunder, including due to the Participant’s affiliation with the Company. The Company shall not be
obligated to issue the Shares if such issuance would violate any applicable securities law, rule or regulation.

8.            NO OBLIGATION TO MAINTAIN RELATIONSHIP.

The Participant acknowledges that: (i) the Company is not by the Plan or this Award obligated to continue the
Participant as an Employee, director or Consultant of the Company or an Affiliate; (ii) the Plan is discretionary in nature
and  may  be  suspended  or  terminated  by  the  Company  at  any  time;  (iii)  the  grant  of  this  Award  is  a  one-time  benefit
which does not create any contractual or other right to receive future grants of awards, or benefits in lieu of awards; (iv)
all determinations with respect to future grants, if any, will be at the sole discretion of the Company; (v) the Participant’s
participation  in  the  Plan  is  voluntary;  (vi)  the  value  of  this  Award  is  an  extraordinary  item  of  compensation  which  is
outside  the  scope  of  the  Participant’s  employment  or  consulting  contract,  if  any;  and  (vii)  this  Award  is  not  part  of
normal  or  expected  compensation  for  purposes  of  calculating  any  severance,  resignation,  redundancy,  end  of  service
payments, bonuses, long-service awards, pension or retirement benefits or similar payments.

9.            NOTICES.

Any  notices  required  or  permitted  by  the  terms  of  this  Agreement  or  the  Plan  shall  be  given  by  recognized

courier service, registered or certified mail, return receipt requested, addressed as follows:

If to the Company:

Intercept Pharmaceuticals, Inc.

                             10 Hudson Yards, 37  Floor
                             New York, NY 10001

th

Attention: General Counsel

If to the Participant at the address set forth on the Grant Notice or to such other address or addresses of which notice in
the same manner has previously been given. Any such notice shall be deemed to have been given upon the earlier of
receipt, one business day following delivery to a recognized courier service or three business days following mailing by
registered or certified mail.

The Company may, in its sole discretion, decide to deliver any documents related to participation in the Plan
and  this  Award  by  electronic  means.  By  accepting  this  Award,  whether  electronically  or  otherwise,  the  Participant
consents to receive such documents by electronic delivery and to participate in the Plan through an online or electronic
system established and maintained by the Company or another third party designated by the Company.

10.          GOVERNING LAW.

The Grant Notice and this Agreement shall be governed by and construed in accordance with the laws of the
State of Delaware, without giving effect to the conflict of law principles thereof. For the purpose of litigating any dispute
that  arises  under  the  Grant  Notice,  this  Agreement  or  the  Plan,  each  of  the  Company  and,  by  accepting  this  Award,
whether  electronically  or  otherwise,  the  Participant  hereby  consents  to  exclusive  jurisdiction  in  New  York  and  agrees
that such litigation shall be conducted in the state courts of New York County, New York or the federal courts of the
United States for the District of the Southern District of New York.

11.          BENEFIT OF AGREEMENT.

Subject to the provisions of the Plan and the other provisions hereof, the Grant Notice and this Agreement shall
be for the benefit of and shall be binding upon the heirs, executors, administrators, successors and assigns of the parties
hereto.

12.          ENTIRE AGREEMENT.

The Grant Notice and this Agreement, together with the Plan, embodies the entire agreement and understanding
between the parties hereto with respect to the subject matter hereof and supersedes all prior oral or written agreements
and understandings relating to the subject matter hereof. No statement, representation, warranty, covenant or agreement
not expressly set forth in the Grant Notice or this Agreement shall affect or be used to interpret, change or restrict the
express terms and provisions of the Grant Notice or this Agreement; provided,  however, in any event, the Grant Notice
and this Agreement shall be subject to and governed by the Plan. This Award is subject to all applicable laws, rules, and
regulations, and to such approvals by any governmental agencies or national securities exchanges as may be required. In
addition, this Award (and any compensation paid or shares issued pursuant to this Award) is subject to recoupment in
accordance with The Dodd-Frank Wall Street Reform and Consumer Protection Act and any implementing regulations
thereunder, any clawback policy adopted by the Company and any compensation recovery policy otherwise required by
applicable law.

13.          MODIFICATIONS AND AMENDMENTS.

The terms and provisions of the Grant Notice and this Agreement may be modified or amended as provided in

the Plan.

14.          WAIVERS AND CONSENTS.

Except  as  provided  in  the  Plan,  the  terms  and  provisions  of  the  Grant  Notice  and  this  Agreement  may  be
waived, or consent for the departure therefrom granted, only by written document executed by the party entitled to the
benefits of such terms or provisions. No such waiver or consent shall be deemed to be or shall constitute a waiver or
consent with respect to any other terms or provisions of the Grant Notice or this Agreement, whether or not similar. Each
such waiver or consent shall be effective only in the specific instance and for the purpose for which it was given, and
shall not constitute a continuing waiver or consent.

15.          DATA PRIVACY.

By accepting this Award, whether electronically or otherwise, the Participant: (i) authorizes the Company and
each Affiliate, and any agent of the Company or any Affiliate administering the Plan or providing Plan recordkeeping
services,  to  disclose  to  the  Company  or  any  of  its  Affiliates  such  information  and  data  as  the  Company  or  any  such
Affiliate shall request in order to facilitate the grant of awards and the administration of the Plan; (ii) waives any data
privacy  rights  he  or  she  may  have  with  respect  to  such  information  or  the  sharing  of  such  information;  and  (iii)
authorizes the Company and each Affiliate to store and transmit such information in electronic form for the purposes set
forth in the Grant Notice and this Agreement.

16.          SEVERABILITY.

If  all  or  any  part  of  the  Grant  Notice,  this  Award  Agreement  or  the  Plan  is  declared  by  any  court  or
governmental authority to be unlawful or invalid, such unlawfulness or invalidity will not invalidate any portion of the
Grant Notice, this Award Agreement or the Plan not declared to be unlawful or invalid. Any section of the Grant Notice,
this Award Agreement or the Plan (or part of such a section) so declared to be unlawful or invalid shall, if possible, be
construed in a manner which will give effect to the terms of such section or part of a section to the fullest extent possible
while remaining lawful and valid.

17.          SECTION 409A.

This Award is intended to be exempt from the nonqualified deferred compensation rules of Section 409A of the
Code  as  a  “short  term  deferral”  (as  that  term  is  used  in  the  final  regulations  and  other  guidance  issued  under  Section
409A of the Code, including Treasury Regulation Section 1.409A-1(b)(4)(i)), and shall be construed accordingly.

18.          NON-U.S. PARTICIPANTS.

If the Participant works and/or resides outside of the United States, the applicable terms and conditions set forth
in Appendix A shall apply to this Award. In addition, the Company reserves the right to impose other requirements on
the  Participant  to  the  extent  the  Company  determines  that  such  requirements  are  necessary  or  advisable  in  order  to
comply with local law or facilitate the administration of the Plan and to require the Participant to sign any additional
agreements or undertakings that may be necessary to accomplish the foregoing.

INTERCEPT PHARMACEUTICALS, INC.
2012 EQUITY INCENTIVE PLAN
RESTRICTED STOCK UNIT AGREEMENT

TERMS AND CONDITIONS FOR NON-U.S. PARTICIPANTS

APPENDIX A

This Appendix includes additional or different terms and conditions that govern this Award if the Participant
works and/or resides outside of the United States. This Appendix forms part of the Restricted Stock Unit Agreement to
which it is attached (the “Agreement”). Capitalized terms not defined in this Appendix but defined in the Agreement or
the Plan will have the meanings assigned to such terms in the Agreement or the Plan, as applicable.  References within
this Appendix to “you” refer to the Participant.

These terms are general in nature, may not apply to your particular situation and are based on securities, tax and
other laws that are often complex and subject to frequent change. As such, the Company strongly recommends that you
do  not  rely  on  this  summary  as  your  only  source  of  information  relating  to  the  consequences  of  your  Award  and
participation in the Plan and further that you consult your personal tax or legal advisors for advice as to how the laws in
your country apply to your situation. Note that if you are a citizen or resident of a country other than the one in which
you are working, additional requirements, other than those described herein, may be applicable to you.

1.            TAXES (REPLACING SECTION 6 OF THE AGREEMENT)

ALL NON-U.S. PARTICIPANTS

The Participant acknowledges that any income or other taxes due from him or her with respect to this Award or
the  Shares  issuable  pursuant  to  this  Award,  as  well  as  any  amounts  in  respect  of  taxes  or  social  security
contributions  (including,  as  applicable,  employer  National  Insurance  Contributions)  that  the  Participant  has
elected  to  bear,  shall  be  the  Participant’s  responsibility.  The  Participant  acknowledges  and  agrees  that  (i)  the
Participant was free to use professional advisors of his or her choice in connection with his or her acceptance of
this Award, has received advice from his or her professional advisors in connection with his or her acceptance
of this Award, understands its meaning and import, and has accepted this Award freely and without coercion or
duress;  and  (ii)  the  Participant  has  not  received  and  is  not  relying  upon  any  advice,  representations  or
assurances  made  by  or  on  behalf  of  the  Company  or  any  Affiliate  or  any  employee  of  or  counsel  to  the
Company or any Affiliate regarding any tax or other effects or implications of this Award, the Shares issuable
pursuant to this Award or other matters contemplated hereby.

Without limiting the foregoing, the Participant agrees that if under applicable law the Participant will owe taxes
and social security contributions upon the vesting of RSUs subject to this Award, the Company shall be entitled
to immediate payment from the Participant of the amount of any federal, provincial, state, local and personal
income  taxes,  wage  tax  and  social  security  contributions  (including,  as  applicable,  Canada  Pension  Plan)
required by law to be withheld by the Company. Any such taxes and social security contributions due shall be
paid, at the option of the Company, as follows (or utilizing such other arrangement as may be specified by the
Company):

(a)          withholding from the Participant’s paycheck an amount equal to the federal, provincial, state, local and
personal  income  taxes,  wage  tax  and  social  security  contributions  required  by  law  or  contract  to  be
withheld; or

(b)          requiring the Participant to make an automatic sale, effected by a broker-dealer designated by the
Company, of a portion of the Shares issued to the Participant on the applicable vesting date sufficient
to cover the applicable tax or social security withholding obligation arising upon such vesting, with the
proceeds  thereof  to  be  remitted  to  the  Company  to  satisfy  such  tax  or  social  security  withholding
obligation.  To  the  extent  that  the  proceeds  of  such  sale  exceed  the  Company’s  tax  or  social  security
withholding obligation, such excess cash shall be paid to the Participant as soon as practicable. In

 
 
 
 
 
 
 
addition,  if  such  sale  is  not  sufficient  to  pay  the  Company’s  tax  or  social  security  withholding
obligation,  the  Participant  agrees  to  pay  to  the  Company  as  soon  as  practicable,  including  through
additional payroll withholding, the amount of any tax or social security withholding obligation that is
not satisfied by the sale of Shares. The Participant agrees to hold the Company and the broker-dealer
harmless from all costs, damages or expenses relating to any such sale. The Participant acknowledges
that  the  Company  and  the  broker-dealer  are  under  no  obligation  to  arrange  for  such  sale  at  any
particular  price.  In  connection  with  such  sale  of  Shares,  the  Participant  shall  execute  any  such
documents requested by the broker-dealer in order to effectuate the sale of Shares and payment of the
proceeds to the Company.

The Company shall not deliver any Shares to the Participant until it is satisfied that all required withholdings
have been made.

2.                        WAIVER  OF  RIGHTS  ON  TERMINATION  (EXCEPT  FRANCE,  PORTUGAL,  SPAIN  AND

DENMARK)

The Participant hereby waives all and any rights to compensation or damages in consequence of the termination
of his or her office or employment with the Company or his or her employing entity for any reasons whatsoever
(whether  lawful  or  unlawful  and  including,  without  prejudice  to  the  generality  of  the  foregoing,  in
circumstances giving rise to a claim for wrongful dismissal) insofar as those rights arise or may arise from his
or her ceasing to have rights under or being entitled to be issued shares of Common Stock on vesting of the
RSUs as a result of such termination, or from the loss or diminution in value of any rights or entitlements in
connection with the Plan.

The Plan and this Award do not form part of the Participant’s contract of employment. If the Participant ceases
to  be  employed  or  engaged  by  the  Company  or  any  Affiliate  for  any  reason  (including  as  a  result  of  a
repudiatory  breach  of  contract  by  the  Company  or  its  Affiliate),  the  Participant  shall  not  be  entitled,  and  by
participating in the Plan the Participant shall be deemed irrevocably to have waived any entitlement, by way of
compensation  for  loss  of  employment,  breach  of  contract  or  otherwise  to  any  sum  or  other  benefit  to
compensate the Participant for any rights or prospective rights under the Plan. This exclusion applies equally
(and without limitation) to any loss arising from the way in which the discretion is (or is not) exercised under
any provision of the Plan even if the exercise (or non-exercise) of such discretion is, or appears to be, irrational
or perverse and/or breaches, or is claimed to breach any implied term of the Plan or any other contract between
the Participant and the Participant’s employer. Participation in the Plan and any benefits provided under it shall
not  be  pensionable  nor  will  they  count  as  pay  or  remuneration  when  calculating  salary  related  benefits
(including, but not limited to, pension).

3.                        DATA  PRIVACY  (IN  ADDITION  TO  SECTION  15  OF  THE  AGREEMENT)  (EXCEPT  ITALY,

PORTUGAL AND SPAIN)

(1)          The Participant hereby explicitly and unambiguously consents to the collection, use and transfer, in
electronic or other form, of his or her personal data as described in the Agreement by and among, as
applicable, his or her employing entity or contracting party and the Company for the exclusive purpose
of implementing, administering and managing his or her participation in the Plan.

(2)          The Participant acknowledges the following:

(i)           the Company holds certain personal information about the Participant, including, but not
limited  to,  his  or  her  name,  home  address  and  telephone  number,  work  location  and  phone
number, date of birth, hire date, bank and payroll details, social security numbers, details of
all awards or any other entitlement to shares awarded, cancelled, exercised, vested, unvested
or outstanding in the Participant’s favor, for the purpose of implementing, administering and
managing the Plan (“Personal Data”);

 
 
 
 
(ii)          providing or transferring Personal Data to the Company is necessary and essential to the
Participant’s  participation  in  the  Plan  and  that  the  Participant’s  refusal  to  provide  Personal
Data  or  withdrawal  of  consent  to  the  collection,  storage  or  transfer  of  Personal  Data  may
affect the Participant’s ability to participate in the Plan since it would be impossible for the
Company to comply with its contractual obligations under the Plan;

(iii)                  the  Participant’s  Personal  Data  may  be  transferred  to  any  third  parties  assisting  in  the
implementation,  administration  and  management  of  the  Plan,  that  these  recipients  may  be
located  in  the  Participant’s  country  or  elsewhere,  and  that  the  recipient’s  country  may  have
different data privacy laws and protections than the Participant’s country;

(iv)         the Participant has been informed that the Company shall not transfer Personal Data from the
Participant’s country without requiring the recipient to comply with the requirements of the
General Data Protection Regulation (as applicable) and applicable data protection laws, and
that the Participant may request a list with the names and addresses of any potential recipients
of the Personal Data by contacting his or her local human resources representative;

(v)          Personal Data will be held only as long as is necessary to implement, administer and manage
the Participant’s participation in the Plan and any potential claim made by the Participant in
relation to any award; and

(vi)         the Participant may, at any time, exercise the right of access, rectification and cancelation of
the Participant’s personal data, oppose, request additional information about the storage and
processing  of  Personal  Data  or  refuse  to  the  further  processing  of  the  Personal  Data  by
contacting  in  writing  the  Participant’s  local  human  resources  representative  (who  can  be
identified on the Company’s intranet).

ADDITIONAL COUNTRY-SPECIFIC PROVISIONS

AUSTRALIA

Financial product advice:  The Participant acknowledges and agrees that advice provided by the Company (if
any) in relation to this Award is of a general nature only and does not take into account the objectives, financial
situation  or  needs  of  the  Participant.  The  Participant  should  consider  obtaining  advice  from  a  person  who  is
licensed  by  the  Australian  Securities  and  Investments  Commission  to  give  such  advice.  The  Company  is  not
licensed  to  provide  financial  product  advice  in  Australia  in  relation  to  restricted  stock  units  and  there  is  no
cooling-off regime in Australia that applies in respect of the grant of restricted stock units.

Risk of acquiring and holding Common Stock:  The Participant acknowledges that there are risks of acquiring
and holding Common Stock. Before accepting this Award, or acquiring the underlying Shares, the Participant
should  satisfy  himself  or  herself  that  he  or  she  has  a  sufficient  understanding  of  these  matters  and  should
consider whether Common Stock is a suitable investment for the Participant, having regard to the investment
objectives, financial circumstances and taxation position of the Participant.

(a)          The price at which Common Stock is quoted on the Nasdaq Global Select Market may decrease, even
to the extent that the price is less than the price or prices paid for the Shares by the Participant.

(b)          There is no guarantee that an active market in Common Stock will continue. The number of potential
buyers or sellers of Common Stock on the Nasdaq Global Select Market may vary at any time. This
may increase the volatility of the market price of Common Stock.

(c)                    The  Company  may  not  pay  dividends  on  Common  Stock  at  any  particular  level  or  at  all.  If  the

Company has paid dividends on Common Stock, it may cease to pay such dividends.

 
 
 
 
 
 
 
(d)          Holding Common Stock may have tax implications for the Participant and the tax regime applying to

the Participant may change.

Market  price  of  Common  Stock:    The  Participant  could,  from  time  to  time,  ascertain  the  market  price  of
Common  Stock  in  Australian  Dollars  by  obtaining  the  market  price  from  the  Nasdaq  Global  Select  Market
website,  the  Company’s  website  or  applicable  U.S.  publication,  and  multiplying  that  market  price  by  a
published exchange rate to convert U.S. Dollars into Australian Dollars.

BELGIUM

Timing and calculation basis of taxation. You will recognize taxable income upon vesting of the RSUs, and you
will be required to include the taxable income within your yearly income tax return covering the financial year
during  which  vesting  occurs.  The  amount  of  the  taxable  income  is  calculated  on  the  basis  of  the  fair  market
value of the Shares at the time of vesting. To the extent you are explicitly required to hold the Shares for at least
an  additional  2  years  beyond  the  date  of  vesting,  then  the  taxable  income  may  be  limited  to  the  difference
between 100/120th of the fair market value of the Shares acquired and the price you paid. The income will be
taxed as compensation income and subject to income tax and social security contributions.

Capital gains on sale. The capital gains on the sale of the Shares acquired upon vesting are not taxable to the
extent you qualify as a Belgian tax resident.

CANADA

Vesting of Award.  For purposes of Section 2 of the Agreement, the Participant’s “Termination Date” means the
later of: (i) the date that is the last day of any statutory notice period applicable to the Participant pursuant to
applicable employment standards legislation; and (ii) the date that is designated by the Company or Affiliate to
which  the  Participant  provides  services  as  the  last  day  of  the  Participant’s  employment,  term  of  office  or
engagement  with  the  Company  or  Affiliate  (as  applicable);  provided,  that  in  the  case  of  termination  of
employment by voluntary resignation by the Participant, such date shall not be earlier than the date notice of
resignation  was  given.  For  certainty,  except  only  as  expressly  required  by  applicable  employment  standards
legislation, as amended or replaced, or agreed by the Company, no portion of this Award shall vest following
the  Participant’s  Termination  Date  and  no  period  of  notice  or  payment  in  lieu  of  notice  in  respect  of  a
termination of an office or employment without Cause shall extend such Termination Date.

Dividends.  To the extent that the Company declares and pays any cash dividend on its Common Stock while
any RSUs subject to this Award are unvested, the Participant shall be eligible to receive upon vesting of such
RSUs an amount equal to the amount of such dividend that the Participant would have received had the Shares
underlying such RSUs been issued and held by the Participant at the time at which such dividend was declared;
it being understood that no such amount shall be payable with respect to any RSUs that are forfeited.

DENMARK

Danish  Stock  Option  Act.    In  accepting  this  Award,  you  acknowledge  that  you  have  received  an  Employer
Statement  translated  into  Danish,  which  is  being  provided  to  comply  with  the  Danish  Stock  Option  Act  and
which sets out the main terms of the Plan applying to you. To the extent more favorable to you and required to
comply with the Stock Option Act, the terms set forth in the Employer Statement, including terms regarding
vesting and forfeiture in connection with termination of your employment will apply to your participation in the
Plan.

Exchange Control Notification.  If you establish an account holding Shares or cash outside Denmark, you must
report  the  account  to  the  Danish  Tax  Administration.  The  form  which  should  be  used  in  this  respect  can  be
obtained  from  a  local  bank.  (Please  note  that  these  obligations  are  separate  from  and  in  addition  to  the
obligations described below.)

Securities and Tax Reporting Notification.  You may hold Shares acquired under the Plan in a safety-deposit
account (e.g., a brokerage account) with either a Danish bank or with an approved foreign broker or bank. If

the Shares are held with a foreign broker or bank, you are required to inform the Danish Tax Administration
about the safety-deposit account. For this purpose, you must file a Form V (Erklaering V) with the Danish Tax
Administration. Both you and the broker or bank must sign the Form V. By signing the Form V, the broker or
bank  undertakes  an  obligation,  without  further  request  each  year,  to  forward  information  to  the  Danish  Tax
Administration concerning the Shares in the safety-deposit account. In the event that the applicable broker or
bank with which the account is held does not wish to, or pursuant to the laws of the country in question, is not
allowed  to  assume  such  obligation  to  report,  you  will  be  solely  responsible  for  providing  certain  details
regarding the foreign brokerage or bank account and any Shares acquired in connection with the Plan and held
in such account to the Danish Tax Administration as part of your annual income tax return. By signing the Form
V, you authorize the Danish Tax Administration to examine the account. A sample of the Form V can be found
at the following website: www.skat.dk.

In addition, if you open a brokerage account or a bank account with a U.S. bank, the account will be treated as a
deposit account because cash can be held in the account. Therefore, you must also file a Form K (Erklaering K)
with the Danish Tax Administration. Both you and the broker must sign the Form K. By signing the Form K,
the  broker  or  bank,  as  applicable,  undertakes  an  obligation,  without  further  request  each  year,  to  forward
information to the Danish Tax Administration concerning the content of the deposit account. In the event that
the applicable financial institution (broker or bank) with which the account is held does not wish to, or pursuant
to the laws of the country in question, is not allowed to assume such obligation to report, you will be solely
responsible  for  providing  certain  details  regarding  the  foreign  brokerage  or  bank  account  to  the  Danish  Tax
Administration as part of your annual income tax return. By signing the Form K, you authorize the Danish Tax
Administration  to  examine  the  account.  A  sample  of  Declaration  K  can  be  found  at  the  following  website:
www.skat.dk.

FRANCE

Language Consent.    By  accepting  the  grant,  you  confirm  that  you  have  read  and  understood  the  documents
relating  to  the  grant  (the  Plan,  the  Grant  Notice  and  the  Agreement,  including  this  Appendix)  which  were
provided in the English language. You confirm that you are fluent in English, written and spoken. You accept
the terms of these documents accordingly.

Consentement Relatif à la Langue Utilisée.  En acceptant l’attribution,  vous confirmez avoir lu et compris les
documents  relatifs  à  l’attribution  (le  Plan,  l’Avis  et  le  Contrat,  y  compris  cette  Annexe)  qui  ont  été
communiqués en langue anglaise. Vous acceptez les termes de ces documents en connaissance de cause.

Tax Notification.  This Award is not intended to qualify for favorable tax or social security treatment in France.

Exchange Control Notification.  If you hold Shares outside of France or maintain a foreign bank account, you
are required to report such to the French tax authorities when filing your annual tax return.

Dividends.  To the extent that the Company declares and pays any cash dividend on its Common Stock while
any RSUs subject to this Award are unvested, the Participant shall be eligible to receive upon vesting of such
RSUs an amount equal to the amount of such dividend that the Participant would have received had the Shares
underlying such RSUs been issued and held by the Participant at the time at which such dividend was declared;
it being understood that no such amount shall be payable with respect to any RSUs that are forfeited.

GERMANY

Taxes.  The following provision replaces Section 1 of this Appendix A:

The  Participant  acknowledges  that  any  income  or  other  taxes  (including  solidarity  surcharges,  social  security
contributions and church taxes) due from him or her with respect to this Award or the Shares issuable pursuant
to  this  Award  shall  be  the  Participant’s  responsibility.  The  Participant  acknowledges  and  agrees  that  (i)  the
Participant was free to use professional advisors of his or her choice in connection with his or her acceptance of
this Award, has received advice from his or her professional advisors in connection

 
 
 
with  his  or  her  acceptance  of  this  Award,  understands  its  meaning  and  import,  and  has  accepted  this  Award
freely  and  without  coercion  or  duress;  and  (ii)  the  Participant  has  not  received  and  is  not  relying  upon  any
advice, representations or assurances made by or on behalf of the Company or any Affiliate or any employee of
or counsel to the Company or any Affiliate regarding any tax or other effects or implications of this Award, the
Shares issuable pursuant to this Award or other matters contemplated hereby.

Without  limiting  the  foregoing,  the  Participant  agrees  that  if  under  applicable  law,  income  by  the  Participant
arising from or in relation to (i) the granting or vesting of this Award or (ii) the delivery of the Shares, is subject
to taxes (including solidarity surcharges and church taxes) or social security contributions, the Company shall
be entitled to immediate payment from the Participant of the amount of any federal, provincial, state, local and
personal  income  taxes,  wage  tax  (including  solidarity  surcharges  and  church  taxes)  and  social  security
contributions required by law to be withheld by the Company. Any such taxes (including solidarity surcharges
and  church  taxes)  and  social  security  contributions  due  shall  be  paid  to  the  competent  tax  or  other  public
authority, at the option of the Company, as follows (or utilizing such other arrangement as may be specified by
the Company):

(a)          deduction or withholding from the Participant’s remuneration, or requiring the Participant to remit to
the Company, an amount equal to the statutory or contractual amount of any federal, provincial, state,
local and personal income taxes, wage tax (including solidarity surcharge and church tax) and social
security contributions required by law or contract to be withheld arising from or in relation to (i) the
granting or vesting of this Award or (ii) the delivery of the Shares; or

 (b)         requiring the Participant to make an automatic sale, effected by a broker-dealer designated by the
Company, of a portion of the Shares issued to the Participant on the applicable vesting date sufficient
to  cover  the  applicable  tax  (including  solidarity  surcharge  and  church  tax)  or  social  security
withholding  obligation,  with  the  proceeds  thereof  to  be  remitted  to  the  Company  to  satisfy  such  tax
(including solidarity surcharge and church tax) or social security withholding obligation. To the extent
that  the  proceeds  of  such  sale  exceed  the  Company’s  tax  (including  solidarity  surcharge  and  church
tax) or social security withholding obligation, such excess cash shall be paid to the Participant as soon
as practicable. In addition, if such sale is not sufficient to pay the Company’s tax (including solidarity
surcharge and church tax) or social security withholding obligation, the Participant agrees to pay to the
Company as soon as practicable, including through additional payroll withholding, the amount of any
tax or social security withholding obligation that is not satisfied by the sale of Shares. The Participant
agrees  to  hold  the  Company  and  the  broker-dealer  harmless  from  all  costs,  damages  or  expenses
relating  to  any  such  sale. The  Participant  acknowledges  that  the  Company  and  the  broker-dealer  are
under  no  obligation  to  arrange  for  such  sale  at  any  particular  price.  In  connection  with  such  sale  of
Shares,  the  Participant  shall  execute  any  such  documents  requested  by  the  broker-dealer  in  order  to
effectuate the sale of Shares and payment of the proceeds to the Company.

The Company shall not deliver any Shares to the Participant until it is satisfied that all required withholdings
have  been  made.  The  Participant  further  agrees  that,  if  the  Company  does  not  withhold  an  amount  from  the
Participant’s  remuneration  sufficient  to  satisfy  the  Company’s  income  or  wage  tax  (including  solidarity
surcharge  and  church  tax)  and  social  security  withholding  obligation,  the  Participant  will  reimburse  the
Company on demand, in cash, for the amount under-withheld.

For  the  avoidance  of  doubt,  the  Company,  inter  alia,  has  the  authority  to  deduct  or  withhold,  or  require  the
Participant  to  remit  to  the  Company,  an  amount  sufficient  to  satisfy  applicable  taxes  (including  wage  taxes
(Lohnsteuern), solidarity surcharges (Solidaritätszuschläge), church taxes (Kirchensteuern) and social security
contributions (Sozialversicherungsbeiträge)) arising from or relating to the  (i) the granting or vesting of this
Award or (ii) the delivery of the Shares.

Dividends.  To the extent that the Company declares and pays any cash dividend on its Common Stock while
any RSUs subject to this Award are unvested, the Participant shall be eligible to receive upon vesting of such

RSUs an amount equal to the amount of such dividend that the Participant would have received had the Shares
underlying such RSUs been issued and held by the Participant at the time at which such dividend was declared;
it being understood that no such amount shall be payable with respect to any RSUs that are forfeited.

ITALY

Data Privacy.  The following provision replaces Section 3 of this Appendix A:

You  understand  that  the  Company  and/or  any  Affiliate  may  hold  certain  personal  information  about  you,
including, without limitation, your name, home address and telephone number, date of birth, social insurance or
other identification number, salary, nationality, job title, any Shares or directorships held in the Company or an
Affiliate, details of all restricted stock units, or any other entitlement to Shares awarded, canceled, exercised,
vested,  unvested  or  outstanding  in  your  favor,  for  the  exclusive  purpose  of  implementing,  managing,  and
administering the Plan (“Data”) and in compliance with applicable laws and regulations.

You also understand that providing the Company with Data is necessary for the performance of the Plan and
that  your  refusal  to  provide  such  Data  would  make  it  impossible  for  the  Company  to  perform  its  contractual
obligations and may affect your ability to participate in the Plan. The Controller of personal data processing is
Intercept Pharmaceuticals, Inc., 10 Hudson Yards, 37th Floor, New York, NY 10001 and pursuant to Art. 6 let.
b)  and  c)  of  the  General    Data  Protection  Regulation  (“GDPR”)  and  Legislative  Decree  no.  196/2003,  its
representative in Italy.

You  understand  that  Data  will  not  be  publicized,  but  it  may  be  transferred  to  the  Company’s  designated
broker/third party administrator for the Plan or such other stock plan service provider as may be selected by the
Company  in  the  future  (any  such  entity,  “Broker”),  or  other  third  parties  involved  in  the  management  and
administration  of  the  Plan.  You  understand  that  Data  may  also  be  transferred  to  the  independent  registered
public accounting firm engaged by the Company. You further understand that the Company and its Affiliates
will  transfer  Data  amongst  themselves  as  necessary  for  the  purposes  of  implementing,  administering  and
managing your participation in the Plan, and that the Company and/or Affiliate may each further transfer Data
to  third  parties  assisting  the  Company  in  the  implementation,  administration  and  management  of  the  Plan,
including any requisite transfer of Data to the Broker or other third party with whom you may elect to deposit
any  Shares  acquired  under  the  Plan.  Such  recipients  may  receive,  possess,  use,  retain,  and  transfer  Data  in
electronic or other form, for the purposes of implementing, administering, and managing your participation in
the Plan. You understand that these recipients may be located in or outside the European Economic Area, such
as  in  the  United  States  or  elsewhere,  and  in  locations  that  might  not  provide  the  same  level  of  protection  as
intended under Italian data privacy laws. In such case, the Company undertakes to comply with the applicable
privacy  law  in  order  to  ensure  that  the  recipient  meets  the  same  standards  provided  by  the  European  Union
legislation,  implementing  appropriate  and  suitable  safeguards,  such  as  using  standard  clauses  or  equivalent
safeguard  measures  as  provided  for  by  Art.  46  of  the  GDPR  and  paragraph  7  of  Legislative  Decree  no.
196/2003. Should the Company exercise its discretion in suspending all necessary legal obligations connected
with  the  management  and  administration  of  the  Plan,  it  will  delete  Data  as  soon  as  it  has  completed  all  the
necessary legal obligations connected with the management and administration of the Plan.

You understand that Data processing related to the purposes specified above shall take place under automated
or  non-automated  conditions,  anonymously  when  possible,  that  comply  with  the  purposes  for  which  Data  is
collected and with confidentiality and security provisions, as set forth by applicable laws and regulations, with
specific reference to Art. 6 let. b) and c) of the GDPR and Legislative Decree no. 196/2003.

The  processing  activity,  including  communication,  the  transfer  of  Data  abroad,  including  outside  of  the
European Economic Area, as herein specified and pursuant to applicable laws and regulations, does not require
your  consent  thereto,  as  the  processing  is  necessary  to  performance  of  contractual  obligations  related  to
implementation, administration, and management of the Plan. You understand that, pursuant to Art. 15 of the
GDPR and paragraph 7 of Legislative Decree no. 196/2003, you have the right to, without limitation, access,
delete,  update,  correct,  or  terminate,  for  legitimate  reason,  the  Data  processing.  Additionally,  you  understand
that you may exercise the right to portability, within the limits set forth by Art. 20 of the GDPR.

Furthermore, you are aware that Data will not be used for direct-marketing purposes. In addition, Data provided
can  be  reviewed  and  questions  or  complaints  can  be  addressed  by  contacting  your  local  human  resources
representative.

Grant  Document  Acknowledgment.    In  accepting  the  grant  of  this  Award,  you  acknowledge  that  you  have
received a copy of the Plan, the Grant Notice and the Agreement, including this Appendix, and have reviewed
the Plan, the Grant Notice and the Agreement, including this Appendix, in their entirety and fully understand
and accepts all provisions thereof.

Foreign  Asset  Reporting  Notification.    If  you  are  an  Italian  resident  and,  during  any  fiscal  year,  hold
investments or financial assets outside of Italy (e.g., cash, Shares) which may generate income taxable in Italy
(or  if  you  are  the  beneficial  owner  of  such  an  investment  or  asset  even  if  you  do  not  directly  hold  the
investment or asset), you are required to report such investments or assets on your annual tax return for such
fiscal year (on UNICO Form, RW Schedule, or on a special form if you are not required to file a tax return).

NORWAY

Securities and Tax Reporting Notification.  You may hold Shares acquired under the Plan in a safety-deposit
account (e.g., a brokerage account) with either a Norwegian bank or with an approved foreign broker or bank. If
the Shares are held with a foreign broker or bank, you are required to inform the Norwegian Tax Administration
about the safety-deposit account. You do this on forms RF-1088 and RF-1059 in connection with filing your
annual tax return (“selvangivelse”). Shares held with a Norwegian bank will be reported automatically.

PORTUGAL

Language Consent. By accepting the grant of this Award, you confirm that you have read and understood the
documents relating to the grant (the Plan, the Grant Notice and the Agreement, including this Appendix) which
were provided to you in English language. You confirm that you are fluent in English, written and spoken. You
accept the terms of these documents accordingly.

Grant Document Acknowledgment. In accepting the grant of the this Award, you acknowledge that you have
received a copy of the Plan, the Grant Notice and the Agreement, including this Appendix, and have reviewed
the Plan, the Grant Notice and the Agreement, including this Appendix, in their entirety and fully understand
and accept all provisions thereof.

Tax Reporting Obligation.  If the Shares acquired under the Plan are held with a foreign broker or bank, you are
required to inform the Portuguese Tax Authorities about the existence of such account. For this purpose, within
the  annual  submission  of  your  personal  income  tax  return  you  must  file  Annex  J  with  the  Portuguese  Tax
Administration,  identifying  the  account  by  reference  to  the  applicable  IBAN  –  International  Bank  Account
Number  and  BIC  -  Bank  Identifier  Code.  Income  arising  out  of  the  Plan  and/or  derived  from  the  Shares  is
subject to reporting to the Portuguese Tax Authorities.

Data Privacy.  The following provision replaces Section 3 of this Appendix A:

You understand that the Company holds certain personal information about you, including, but not limited to,
your  name,  home  address  and  telephone  number,  work  location  and  phone  number,  date  of  birth,  hire  date,
details  of  all  awards  or  any  other  entitlement  to  shares  awarded,  cancelled,  exercised,  vested,  unvested  or
outstanding in the Participant’s favor, for the purpose of implementing, administering and managing the Plan
(“Personal Data”).

You understand that the providing or transferring of Personal Data to the Company is necessary and essential to
your participation in the Plan and that your refusal to provide Personal Data or withdrawal of consent to the
collection, storage or transfer of Personal Data may affect your ability to participate in the Plan since it would
be impossible for the Company to comply with its contractual obligations under the Plan.

You understand that your Personal Data may be transferred to any third parties assisting in the implementation,
administration and management of the Plan, that these recipients may be located in the Participant’s country or
elsewhere,  and  that  the  recipient’s  country  may  have  different  data  privacy  laws  and  protections  than  the
Participant’s country.

You  were  informed  that  the  personal  data  communicated  outside  of  Portugal  will  be  protected  identically  as
provided for in Law No. 67/98, of 26 October, and that you may request a list with the names and addresses of
any potential recipients of the Personal Data by contacting your local human resources representative.

You authorize the recipients to receive, possess, use, retain and transfer the Personal Data, in electronic or other
form, for the purposes of implementing, administering and managing your participation in the Plan.

You  understand  that  Personal  Data  will  be  held  only  as  long  as  is  necessary  to  implement,  administer  and
manage your participation in the Plan and any potential claim of the Participant.

You understand that you may, at any time, exercise of the right of access, rectification and cancelation of your
personal  data,  oppose,  request  additional  information  about  the  storage  and  processing  of  Personal  Data  or
refuse  or  withdraw  the  consents  herein,  in  any  case  without  cost,  by  contacting  in  writing  your  local  human
resources representative (who can be identified on the Company’s intranet).

SPAIN

Taxes.  The following provision supplements Section 1 of this Appendix A:

Pursuant  to  Royal  Decree-Law  13/2011  of  16  September  (as  amended),  wealth  tax  (Impuesto  sobre  el
Patrimonio) has been temporarily restored in Spain. If the Participant’s only foreign assets are the Shares and
the value of the Shares on 31 December exceeds the specified threshold the Participant will be required to make
a declaration to the Spanish tax authorities between 1 January and 31 March of the immediately following year.
The  Participant  much  declare  foreign  rights  and  assets  including  (i)  ISIN  code  of  Shares;  (ii)  the  name  and
corporate domicile of the issuing company; and (iii) the number, class, and value of the Shares held as of 31
December.

Exchange Controls.  The Participant is responsible for complying with exchange control regulations in Spain.
Declaration  of  the  acquisition  of  Shares  for  statistical  purposes  to  the  Dirección  General  de  Comercio  e
Inversiones  (DGCI)  of  Ministerio  de  Economía  is  compulsory  (i)  if  the  purchase  price  exceeds  the  specified
threshold; (ii) if the investor holds a stake of at least 10 percent in the Company; or (iii) if the investor belongs
to the Company’ s board of directors. If Participants purchase any Shares through the use of a Spanish financial
institution, the institution will automatically make the declaration to the DGCI; otherwise the Participant must
make  the  declaration  by  filing  the  appropriate  form  with  the  DGCI.  The  Participant  must  also  declare
ownership of Shares with the DGCI in January of each year.

Data Privacy. The following provisions replace Section 3 of this Appendix A:

The  Participant’s  personal  data  will  be  processed  by  Intercept  Pharmaceuticals,  Inc.  (the  “Data Controller”)
with a corporate domicile at 10 Hudson Yards, 37th Floor, New York, NY 10001.

The  purpose  of  the  processing  is  to  implement  the  Grant  Notice  and  the  Agreement  under  the  Plan,  verify
eligibility  conditions  and  develop  and  perform  the  contractual  and  legal  obligations  arising  thereof.  The
processing of the Participant’s personal data is necessary for such purposes and its legal basis are the execution
and development of the contractual relationship and, if applicable, the compliance with legal duties applicable
to  the  Data  Controller.  Personal  data  will  be  processed  whilst  the  Participant  holds  the  relevant  awards  and,
after  this,  for  six  years,  or,  exceptionally,  for  the  period  during  which  any  kind  of  liability  may  arise  from  a
legal or contractual obligation applicable to the Data Controller.

The Participant’s personal data will be transferred outside the European Economic Area, to the United States,
where  Intercept  Pharmaceuticals,  Inc.  is  located.  A  copy  of  the  relevant  appropriate  safeguards  subscribed  in
order  to  carry  out  such  international  data  transfer  can  be  requested  from  human  resources.  Additionally,  the
Participant’s personal data may be disclosed only to those group companies which may have a legal basis for
processing this personal data.

The Participant may exercise his/her right of access, rights to rectification, erasure, objection, data portability,
restriction  of  processing  and  any  other  right  recognized  by  the  applicable  regulations  from  time  to  time,  by
sending a request to human resources. The Participant may also file any claim or request related to his or her
data  protection  rights  with  the  relevant  supervisory  authority.  The  personal  data  processed  for  the  purposes
described  above  derives  from  the  execution  of  the  Participant’s  employment  agreement  or,  in  case  that  the
Participant is an independent professional, the relevant services agreement.

Dividends.  To the extent that the Company declares and pays any cash dividend on its Common Stock while
any RSUs subject to this Award are unvested, the Participant shall be eligible to receive upon vesting of such
RSUs an amount equal to the amount of such dividend that the Participant would have received had the Shares
underlying such RSUs been issued and held by the Participant at the time at which such dividend was declared;
it being understood that no such amount shall be payable with respect to any RSUs that are forfeited.

UNITED KINGDOM

Taxes.  The following provision replaces Section 1 of this Appendix A:

The Participant acknowledges that any income or other taxes and social security contributions due from him or
her in connection with this Award or the Shares to be issued pursuant to this Award, as well as any amounts in
respect of taxes or social security contributions (including employer National Insurance Contributions) that the
Participant  has  elected  to  bear,  shall  be  the  Participant’s  responsibility  (“Participant  Tax  Liability”).  The
Participant acknowledges and agrees that (i) the Participant was free to use professional advisors of his or her
choice in connection with his or her acceptance of this Award, has received advice from his or her professional
advisors in connection with his or her acceptance of this Award, understands its meaning and import, and has
accepted this Award freely and without coercion or duress; and (ii) the Participant has not received and is not
relying upon any advice, representations or assurances made by or on behalf of the Company or any Affiliate or
any employee of or counsel to the Company or any Affiliate regarding any tax or other effects or implications
of this Award, the Shares issuable pursuant to this Award or other matters contemplated hereby.

Without  limiting  the  foregoing,  the  Participant  agrees  (i)  that  the  Participant  shall  pay  to  the  Company,  the
Participant’s employer or former employer (as appropriate) the amount of any Participant Tax Liability; (ii) that
the  Company,  the  Participant’s  employer  or  former  employer  (as  appropriate)  may,  if  it  so  elects  by  written
notice to the Participant, recover the whole or any part of any employer National Insurance Contributions from
the  Participant;  (iii)  that  the  Participant  shall,  promptly  upon  being  requested  to  do  so  by  the  Company,  the
Participant’s employer or former employer (as appropriate), elect (using a form approved by HM Revenue &
Customs)  that  the  whole  or  any  part  of  the  liability  for  employer  National  Insurance  Contributions  shall  be
transferred  to  the  Participant;  and  (iv)  to  enter  into  a  joint  election,  under  section  431(1)  or  431(2)  of  the
Income  Tax  (Earnings  &  Pensions)  Act  2003,  in  respect  of  the  Shares  delivered  pursuant  to  this  Award,  if
required to do so by the Company, the Participant’s employer or former employer, before, on or within 14 days
after any date of delivery of such Shares. Any such Participant Tax Liability due shall be paid, at the option of
the Company, as follows (or utilizing such other arrangement as may be specified by the Company):

(a)                    through  reducing  the  number  of  Shares  otherwise  entitled  to  be  issued  to  the  Participant  on  the
applicable vesting date in an amount equal to the amount of withholding tax due and payable by the Company;
or

(b)          withholding from the Participant’s paycheck an amount equal to the Participant Tax Liability.

Exhibit 10.8

Performance Stock Unit No.________

INTERCEPT PHARMACEUTICALS, INC.
2012 EQUITY INCENTIVE PLAN
PERFORMANCE STOCK UNIT GRANT

Performance Stock Unit Grant Notice

Intercept  Pharmaceuticals,  Inc.  (the  “Company”)  hereby  grants  to  the  participant  named  below  (the  “Participant”)  the
number of performance stock units (“PSUs”) set forth below (this “Award”). This Award is subject to all of the terms and
conditions set forth in this Performance Stock Unit Grant Notice (this “Grant Notice”), the Intercept Pharmaceuticals, Inc.
2012  Equity  Incentive  Plan  (the  “Plan”)  and  the  Performance  Stock  Unit  Agreement  attached  hereto  (the  “Agreement”).
Capitalized terms not defined in this Grant Notice but defined in the Agreement or the Plan will have the meanings assigned
to such terms in the Agreement or the Plan, as applicable. Except as expressly provided in the Agreement, in the event of any
conflict between the provisions of this Grant Notice or the Agreement and those of the Plan, the provisions of the Plan will
control.

1.

Name and Address of Participant:

2.

3.

Date of Grant:

Number of PSUs
(the “Target Award Amount”):

4.            Vesting of Award: Following the Performance Period, the Participant shall receive the number of shares of the
Company’s common stock, par value $0.001 per share (the “Shares”), equal to the Payout Percentage (as calculated below);
provided,  however, that, except as otherwise set forth in the Agreement, no portion of this Award shall vest unless (i) the
Participant is an Employee, director or Consultant of the Company or an Affiliate on the last day of the Performance Period
and (ii) the Company has attained a TSR during the Performance Period that places the Company in the 25th percentile or
higher of the Peer Group (as such terms are defined below).

The following definitions shall apply for purposes of this Grant Notice and the Agreement:

The “Beginning Stock Price” for the Company and each member of the Peer Group shall equal the average closing price for
such  company’s  common  equity  on  the  principal  exchange  on  which  such  equity  is  traded  for  each  of  the  trading  days  in
December 2019, after adjusting for the Dividend Value, as applicable.

The “Ending Stock Price” for the Company and each member of the Peer Group shall equal the average closing price for
such  company’s  common  equity  on  the  principal  exchange  on  which  such  equity  is  traded  for  each  of  the  trading  days  in
December 2022, after adjusting for the Dividend Value, as applicable.

The “Dividend Value” shall mean the value of any dividends paid on a share in December 2019 or during the Performance
Period, with the payment date deemed to have occurred on the ex-dividend date for such dividend and the amount of such
dividend deemed reinvested in shares of the applicable issuer as of the ex-dividend date (based on the closing price of such
shares on such date).

The “Performance Period” shall mean the three-year period commencing on January 1, 2020 and ending on December 31,
2022.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The “Peer Group” shall consist of the companies that comprised the S&P Biotechnology Select Industry Index as of January
1, 2020; provided,  however, that any company included in the Peer Group that (i) ceases to be publicly traded during the
Performance  Period  shall  be  removed  from  the  Peer  Group  or  (ii)  subsequently  reorganizes  under  the  United  States
Bankruptcy Code (or any successor or comparable law) shall remain in the Peer Group and all such companies (if any) shall
be deemed to be ranked below all other companies in the Peer Group.

“TSR”  shall  mean  the  percent  return  of  an  applicable  share  of  common  equity  of  the  Company  or  a  member  of  the  Peer
Group, determined using the following calculation:

TSR =

Ending Stock Price - Beginning Stock Price
Beginning Stock Price

Except  as  otherwise  set  forth  in  the  Agreement,  following  the  completion  of  the  Performance  Period,  the  vesting  of  this
Award  shall  be  determined  by  (i)  calculating  the  TSR  of  the  Company  and  each  member  of  the  Peer  Group  for  the
Performance Period and (ii) determining the Company’s ranking within the Peer Group based on its TSR for the Performance
Period.

The Company’s Percentile Rank within the Peer Group shall be calculated using the formula below, where “N” is the total
companies in the Peer Group including the Company and “R” is the Company’s ranking within the Peer Group:

Percentile Rank =

N - R
N - 1

Payment of this Award shall be made as specified in the following chart:

th

Percentile Rank
75  Percentile and Above
50  Percentile
25  Percentile
Below 25  Percentile

th

th

th

Payout Percentage 
(number of Shares as a percentage 
of Target Award Amount)
150%
100%
50%
0%

There shall be straight line interpolation to determine the Payout Percentage earned for results falling in between the quartiles
specified in the above chart. Notwithstanding the above, in the event that the Company’s TSR for the Performance Period is
negative, the maximum Payout Percentage for this Award shall be the Target Award Amount.

By accepting this Award, whether electronically or otherwise, the Participant acknowledges receipt of, and understands and
agrees  to,  this  Grant  Notice,  the  Agreement  and  the  Plan.  Unless  otherwise  specified  in  a  written  agreement  between  the
Company and the Participant, this Grant Notice, the Agreement and the Plan set forth the entire understanding between the
Participant and the Company regarding this Award and supersede all prior oral and written agreements on the terms of this
Award.

 
 
   
 
 
 
   
 
 
 
 
 
INTERCEPT PHARMACEUTICALS, INC.
2012 EQUITY INCENTIVE PLAN
PERFORMANCE STOCK UNIT AGREEMENT

Pursuant to the Performance Stock Unit Grant Notice to which this agreement is attached (the “Grant Notice”) and
this Performance Stock Unit Agreement (this “Agreement”), Intercept Pharmaceuticals, Inc. (the “Company”) has granted
to the participant named in the Grant Notice (the “Participant”) a Performance Stock Unit Award (this “Award”), under and
for the purposes set forth in the Intercept Pharmaceuticals, Inc. 2012 Equity Incentive Plan (the “Plan”), for the number of
Performance Stock Units (“PSUs”) indicated in the Grant Notice. Capitalized terms not defined in this Agreement or in the
Grant Notice but defined in the Plan will have the meanings assigned to such terms in the Plan.

The  terms  and  conditions  of  this  Award,  in  addition  to  those  set  forth  in  the  Grant  Notice  and  the  Plan,  are  as

follows:

1.            GRANT OF AWARD.

This Award represents the Participant’s right to receive the number of shares of the Company’s common stock, par
value  $0.001  per  share  (the  “Shares”),  as  calculated  pursuant  to  the  Grant  Notice.  Such  Shares  shall  be  delivered  by  the
Company to the Participant on or prior to the date that is 60 days following the end of the Performance Period (as defined in
the Grant Notice) and in accordance with this Agreement and the Plan. Except as otherwise provided herein, the Participant
will not be required to make any payment to the Company (other than past and future services to the Company) with respect
to the Participant’s receipt of this Award, the vesting of the PSUs or the delivery of the Shares to be issued in respect of this
Award.

2.            VESTING OF AWARD.

(a)          Subject to the terms and conditions set forth in this Agreement and the Plan, this Award shall vest as set
forth in the Grant Notice. This Award shall continue to vest in accordance with its terms for so long as the Participant is an
Employee, director or Consultant of the Company or an Affiliate.

(b)          Except as otherwise set forth in this Agreement, if the Participant ceases to be an Employee, director or
Consultant of the Company or of an Affiliate for any reason (the date of such cessation of service, the “Termination Date”),
then  as  of  the  Termination  Date,  all  unvested  PSUs  shall  immediately  be  forfeited  at  no  cost  to  the  Company  and  this
Agreement  shall  terminate  and  be  of  no  further  force  or  effect;  provided,    however,  that,  in  the  event  that  the  Participant
ceases  to  be  an  Employee,  director  or  Consultant  of  the  Company  or  an  Affiliate  due  to  the  death  or  Disability  of  the
Participant, then the Participant shall become vested in a number of PSUs equal to the Target Award Amount, pro-rated for
the  portion  of  the  Performance  Period  that  has  elapsed  as  of  the  Termination  Date  (and  the  delivery  of  Shares  in  respect
thereof shall occur within 60 days of such Termination Date).

(c)                    Notwithstanding  the  foregoing,  except  to  the  extent  specifically  provided  to  the  contrary  in  any
employment  agreement  between  the  Participant  and  the  Company  or  an  Affiliate,  in  the  event  of  a  Change  of  Control  (as
defined below), the Performance Period shall end and amounts payable pursuant to this Award shall be determined based on
an  Ending  Stock  Price  for  the  Company  and  each  member  of  the  Peer  Group  equal  to  the  average  closing  price  for  such
company’s common equity on the principal exchange on which such equity is traded for each of the trading days in last full
calendar month prior to the month in which the Change in Control occurs (without any subsequent pro-ration) and payment
shall be made with respect to this Award within 5 business days following the occurrence of the Change in Control.

For purposes of this Agreement, “Change of Control” means the occurrence of any of the following events:

(i)           Ownership.  Any “Person” (as such term is used in Sections 13(d) and 14(d) of the Securities
Exchange  Act  of  1934,  as  amended)  becomes  the  “Beneficial  Owner”  (as  defined  in  Rule  13d-3  under  said  Act),
directly or indirectly, of securities of the Company representing 50% or more of the total

 
 
voting power represented by the Company’s then-outstanding voting securities (excluding for this purpose any such
voting securities held by the Company or its Affiliates or any employee benefit plan of the Company); or

(ii)          Merger/Sale of Assets.  (A) A merger or consolidation of the Company whether or not approved
by the Board of Directors, other than a merger or consolidation which would result in the voting securities of the
Company  outstanding  immediately  prior  thereto  continuing  to  represent  (either  by  remaining  outstanding  or  by
being converted into voting securities of the surviving entity or the parent of such corporation) more than 50% of the
total voting power represented by the voting securities of the Company or such surviving entity or parent of such
corporation,  as  the  case  may  be,  outstanding  immediately  after  such  merger  or  consolidation;  or  (B)  the  sale  or
disposition by the Company of all or substantially all of the Company’s assets in a transaction requiring stockholder
approval; or

(iii)         Change in Board Composition.  A change in the composition of the Board of Directors, as a result
of  which  fewer  than  a  majority  of  the  directors  are  Incumbent  Directors.  “Incumbent  Directors”  shall  mean
directors who either (A) are directors of the Company as of the date of grant, or (B) are elected, or nominated for
election, to the Board of Directors with the affirmative votes of at least a majority of the Incumbent Directors at the
time  of  such  election  or  nomination  (but  shall  not  include  an  individual  whose  election  or  nomination  is  in
connection with an actual or threatened proxy contest relating to the election of directors to the Company).

(iv)         “Change of Control” shall be interpreted, if applicable, in a manner, and limited to the extent

necessary, so that it will not cause adverse tax consequences under Section 409A of the Code.

3.            PROHIBITIONS ON TRANSFER.

This Award (including any additional PSUs received by the Participant as a result of stock dividends, stock splits or
any other similar transaction affecting the Company’s securities without receipt of consideration) shall not be transferable by
the Participant otherwise than (i) by will or by the laws of descent and distribution, or (ii) pursuant to a qualified domestic
relations  order  as  defined  by  the  Code  or  Title  I  of  the  Employee  Retirement  Income  Security  Act  or  the  rules
thereunder. Except as provided above in this Section 3, the Shares to be issued pursuant to this Award shall be issued during
the  Participant’s  lifetime  only  to  the  Participant  (or,  in  the  event  of  legal  incapacity  or  incompetency,  to  the  Participant’s
guardian or representative). This Award shall not be assigned, pledged or hypothecated in any way (whether by operation of
law or otherwise) and shall not be subject to execution, attachment or similar process. Any attempted transfer, assignment,
pledge, hypothecation or other disposition of this Award or of any rights granted hereunder contrary to the provisions of this
Section 3, or the levy of any attachment or similar process upon this Award shall be null and void.

4.            NO RIGHTS AS STOCKHOLDER.

Subject  to  Section  5  below,  the  Participant  shall  have  no  rights  as  a  stockholder  with  respect  to  the  Shares  to  be

issued pursuant to this Award until registration of the Shares in the Company’s share register in the name of the Participant.

5.            ADJUSTMENTS AND CASH DIVIDENDS.

(a)          This Award, including the number of PSUs subject to this Award, shall be subject to adjustment from time

to time as provided for in the Plan upon the occurrence of certain events described therein.

(b)          To the extent that the Company declares and pays any cash dividend on its Common Stock while any PSUs
subject to this Award are unvested, the Participant shall be eligible to receive upon vesting of such PSUs an amount equal to
the amount of such dividend that the Participant would have received had the Shares underlying such PSUs been issued and
held by the Participant at the time at which such dividend was declared; it being understood that no such amount shall be
payable with respect to any PSUs that are forfeited.

 
 
6.            TAXES.

The Participant acknowledges that any income or other taxes due from him or her with respect to this Award or the
Shares issuable pursuant to this Award shall be the Participant’s responsibility. The Participant acknowledges and agrees that
(i) the Participant was free to use professional advisors of his or her choice in connection with his or her acceptance of this
Award,  has  received  advice  from  his  or  her  professional  advisors  in  connection  with  his  or  her  acceptance  of  this  Award,
understands  its  meaning  and  import,  and  has  accepted  this  Award  freely  and  without  coercion  or  duress;  and  (ii)  the
Participant has not received and is not relying upon any advice, representations or assurances made by or on behalf of the
Company or any Affiliate or any employee of or counsel to the Company or any Affiliate regarding any tax or other effects or
implications of this Award, the Shares issuable pursuant to this Award or other matters contemplated hereby.

Without  limiting  the  foregoing,  the  Participant  agrees  that  if  under  applicable  law  the  Participant  will  owe  taxes
upon the vesting of PSUs subject to this Award, the Company shall be entitled to immediate payment from the Participant of
the amount of any tax required to be withheld by the Company. Any taxes due shall be paid, at the option of the Company, as
follows (or utilizing such other arrangement as may be specified by the Company):

(a)          through reducing the number of Shares otherwise entitled to be issued to the Participant on the applicable

vesting date in an amount equal to the amount of withholding tax due and payable by the Company;

(b)          requiring the Participant to deposit with the Company an amount of cash equal to the amount determined
by  the  Company  to  be  required  with  respect  to  the  Participant’s  estimated  total  federal,  state  and  local  tax  obligations  or
otherwise withholding from the Participant’s remuneration an amount equal to the withholding tax due and payable; or

(c)                    requiring  the  Participant  to  make  an  automatic  sale,  effected  by  a  broker-dealer  designated  by  the
Company, of a portion of the Shares issued to the Participant on the applicable vesting date sufficient to cover the applicable
tax withholding obligation arising upon such vesting, with the proceeds thereof to be remitted to the Company to satisfy such
tax withholding obligation. To the extent that the proceeds of such sale exceed the Company’s tax withholding obligation,
such excess cash shall be paid to the Participant as soon as practicable. In addition, if such sale is not sufficient to pay the
Company’s  tax  withholding  obligation,  the  Participant  agrees  to  pay  to  the  Company  as  soon  as  practicable,  including
through  additional  payroll  withholding,  the  amount  of  any  tax  withholding  obligation  that  is  not  satisfied  by  the  sale  of
Shares.  The  Participant  agrees  to  hold  the  Company  and  the  broker-dealer  harmless  from  all  costs,  damages  or  expenses
relating to any such sale. The Participant acknowledges that the Company and the broker-dealer are under no obligation to
arrange for such sale at any particular price. In connection with such sale of Shares, the Participant shall execute any such
documents  requested  by  the  broker-dealer  in  order  to  effectuate  the  sale  of  Shares  and  payment  of  the  proceeds  to  the
Company.

The Company shall not deliver any Shares to the Participant until it is satisfied that all required withholdings have

been made.

7.            SECURITIES LAWS COMPLIANCE.

The Participant specifically acknowledges and agrees that this Award and any delivery of Shares hereunder shall be
subject to compliance with the requirements of the Securities Act and other applicable securities laws, rules or regulations. In
addition, applicable securities laws, rules or regulations may restrict the ability of the Participant to resell Shares delivered
hereunder, including due to the Participant’s affiliation with the Company. The Company shall not be obligated to issue the
Shares if such issuance would violate any applicable securities law, rule or regulation.

8.            NO OBLIGATION TO MAINTAIN RELATIONSHIP.

The  Participant  acknowledges  that:  (i)  the  Company  is  not  by  the  Plan  or  this  Award  obligated  to  continue  the
Participant as an Employee, director or Consultant of the Company or an Affiliate; (ii) the Plan is discretionary in nature and
may be suspended or terminated by the Company at any time; (iii) the grant of this Award is a one-time benefit which does
not create any contractual or other right to receive future grants of awards, or benefits in lieu of

 
 
awards;  (iv)  all  determinations  with  respect  to  future  grants,  if  any,  will  be  at  the  sole  discretion  of  the  Company;  (v)  the
Participant’s  participation  in  the  Plan  is  voluntary;  (vi)  the  value  of  this  Award  is  an  extraordinary  item  of  compensation
which is outside the scope of the Participant’s employment or consulting contract, if any; and (vii) this Award is not part of
normal  or  expected  compensation  for  purposes  of  calculating  any  severance,  resignation,  redundancy,  end  of  service
payments, bonuses, long-service awards, pension or retirement benefits or similar payments.

9.            NOTICES.

Any notices required or permitted by the terms of this Agreement or the Plan shall be given by recognized courier

service, registered or certified mail, return receipt requested, addressed as follows:

If to the Company:

Intercept Pharmaceuticals, Inc.
10 Hudson Yards, 37  Floor
New York, NY 10001
Attention: General Counsel

th

If to the Participant at the address set forth on the Grant Notice or to such other address or addresses of which notice in the
same manner has previously been given. Any such notice shall be deemed to have been given upon the earlier of receipt, one
business  day  following  delivery  to  a  recognized  courier  service  or  three  business  days  following  mailing  by  registered  or
certified mail.

The Company may, in its sole discretion, decide to deliver any documents related to participation in the Plan and
this  Award  by  electronic  means.  By  accepting  this  Award,  whether  electronically  or  otherwise,  the  Participant  consents  to
receive  such  documents  by  electronic  delivery  and  to  participate  in  the  Plan  through  an  online  or  electronic  system
established and maintained by the Company or another third party designated by the Company.

10.          GOVERNING LAW.

The Grant Notice and this Agreement shall be governed by and construed in accordance with the laws of the State of
Delaware, without giving effect to the conflict of law principles thereof. For the purpose of litigating any dispute that arises
under  the  Grant  Notice,  this  Agreement  or  the  Plan,  each  of  the  Company  and,  by  accepting  this  Award,  whether
electronically  or  otherwise,  the  Participant  hereby  consents  to  exclusive  jurisdiction  in  New  York  and  agrees  that  such
litigation shall be conducted in the state courts of New York County, New York or the federal courts of the United States for
the District of the Southern District of New York.

11.          BENEFIT OF AGREEMENT.

Subject to the provisions of the Plan and the other provisions hereof, the Grant Notice and this Agreement shall be

for the benefit of and shall be binding upon the heirs, executors, administrators, successors and assigns of the parties hereto.

12.          ENTIRE AGREEMENT.

The  Grant  Notice  and  this  Agreement,  together  with  the  Plan,  embodies  the  entire  agreement  and  understanding
between the parties hereto with respect to the subject matter hereof and supersedes all prior oral or written agreements and
understandings  relating  to  the  subject  matter  hereof.  No  statement,  representation,  warranty,  covenant  or  agreement  not
expressly set forth in the Grant Notice or this Agreement shall affect or be used to interpret, change or restrict the express
terms  and  provisions  of  the  Grant  Notice  or  this  Agreement;  provided,    however,  in  any  event,  the  Grant  Notice  and  this
Agreement shall be subject to and governed by the Plan. This Award is subject to all applicable laws, rules, and regulations,
and to such approvals by any governmental agencies or national securities exchanges as may be required. In addition, this
Award (and any compensation paid or shares issued pursuant to this Award) is subject to recoupment in accordance with The
Dodd-Frank Wall Street Reform and Consumer Protection

 
 
Act  and  any  implementing  regulations  thereunder,  any  clawback  policy  adopted  by  the  Company  and  any  compensation
recovery policy otherwise required by applicable law.

13.          MODIFICATIONS AND AMENDMENTS.

The terms and provisions of the Grant Notice and this Agreement may be modified or amended as provided in the

Plan.

14.          WAIVERS AND CONSENTS.

Except as provided in the Plan, the terms and provisions of the Grant Notice and this Agreement may be waived, or
consent for the departure therefrom granted, only by written document executed by the party entitled to the benefits of such
terms or provisions. No such waiver or consent shall be deemed to be or shall constitute a waiver or consent with respect to
any other terms or provisions of the Grant Notice or this Agreement, whether or not similar. Each such waiver or consent
shall  be  effective  only  in  the  specific  instance  and  for  the  purpose  for  which  it  was  given,  and  shall  not  constitute  a
continuing waiver or consent.

15.          DATA PRIVACY.

By accepting this Award, whether electronically or otherwise, the Participant: (i) authorizes the Company and each
Affiliate, and any agent of the Company or any Affiliate administering the Plan or providing Plan recordkeeping services, to
disclose to the Company or any of its Affiliates such information and data as the Company or any such Affiliate shall request
in order to facilitate the grant of awards and the administration of the Plan; (ii) waives any data privacy rights he or she may
have with respect to such information or the sharing of such information; and (iii) authorizes the Company and each Affiliate
to store and transmit such information in electronic form for the purposes set forth in the Grant Notice and this Agreement.

16.          SEVERABILITY.

If all or any part of the Grant Notice, this Award Agreement or the Plan is declared by any court or governmental
authority to be unlawful or invalid, such unlawfulness or invalidity will not invalidate any portion of the Grant Notice, this
Award Agreement or the Plan not declared to be unlawful or invalid. Any section of the Grant Notice, this Award Agreement
or the Plan (or part of such a section) so declared to be unlawful or invalid shall, if possible, be construed in a manner which
will give effect to the terms of such section or part of a section to the fullest extent possible while remaining lawful and valid.

17.          SECTION 409A.

This  Award  is  intended  to  be  exempt  from  the  nonqualified  deferred  compensation  rules  of  Section  409A  of  the
Code as a “short term deferral” (as that term is used in the final regulations and other guidance issued under Section 409A of
the Code, including Treasury Regulation Section 1.409A-1(b)(4)(i)), and shall be construed accordingly.

18.          NON-U.S. PARTICIPANTS.

If the Participant works and/or resides outside of the United States, the applicable terms and conditions set forth in
Appendix A  shall  apply  to  this  Award.  In  addition,  the  Company  reserves  the  right  to  impose  other  requirements  on  the
Participant to the extent the Company determines that such requirements are necessary or advisable in order to comply with
local  law  or  facilitate  the  administration  of  the  Plan  and  to  require  the  Participant  to  sign  any  additional  agreements  or
undertakings that may be necessary to accomplish the foregoing.

 
 
INTERCEPT PHARMACEUTICALS, INC.
2012 EQUITY INCENTIVE PLAN
PERFORMANCE STOCK UNIT AGREEMENT

TERMS AND CONDITIONS FOR NON-U.S. PARTICIPANTS

APPENDIX A

This Appendix includes additional or different terms and conditions that govern this Award if the Participant works
and/or resides outside of the United States. This Appendix forms part of the Performance Stock Unit Agreement to which it
is attached (the “Agreement”). Capitalized terms not defined in this Appendix but defined in the Agreement or the Plan will
have the meanings assigned to such terms in the Agreement or the Plan, as applicable. References within this Appendix to
“you” refer to the Participant.

These  terms  are  general  in  nature,  may  not  apply  to  your  particular  situation  and  are  based  on  securities,  tax  and
other laws that are often complex and subject to frequent change. As such, the Company strongly recommends that you do
not rely on this summary as your only source of information relating to the consequences of your Award and participation in
the Plan and further that you consult your personal tax or legal advisors for advice as to how the laws in your country apply
to  your  situation.  Note  that  if  you  are  a  citizen  or  resident  of  a  country  other  than  the  one  in  which  you  are  working,
additional requirements, other than those described herein, may be applicable to you.

COUNTRY-SPECIFIC PROVISIONS

UNITED KINGDOM

Taxes.  The following provision replaces Section 6 of the Agreement:

The Participant acknowledges that any income or other taxes and social security contributions due from him or her
in connection with this Award or the Shares to be issued pursuant to this Award, as well as any amounts in respect of
taxes or social security contributions (including employer National Insurance Contributions) that the Participant has
elected to bear, shall be the Participant’s responsibility (“Participant Tax Liability”). The Participant acknowledges
and agrees that (i) the Participant was free to use professional advisors of his or her choice in connection with his or
her acceptance of this Award, has received advice from his or her professional advisors in connection with his or her
acceptance  of  this  Award,  understands  its  meaning  and  import,  and  has  accepted  this  Award  freely  and  without
coercion or duress; and (ii) the Participant has not received and is not relying upon any advice, representations or
assurances made by or on behalf of the Company or any Affiliate or any employee of or counsel to the Company or
any Affiliate regarding any tax or other effects or implications of this Award, the Shares issuable pursuant to this
Award or other matters contemplated hereby.

Without  limiting  the  foregoing,  the  Participant  agrees  (i)  that  the  Participant  shall  pay  to  the  Company,  the
Participant’s employer or former employer (as appropriate) the amount of any Participant Tax Liability; (ii) that the
Company, the Participant’s employer or former employer (as appropriate) may, if it so elects by written notice to the
Participant, recover the whole or any part of any employer National Insurance Contributions from the Participant;
(iii) that the Participant shall, promptly upon being requested to do so by the Company, the Participant’s employer or
former employer (as appropriate), elect (using a form approved by HM Revenue & Customs) that the whole or any
part of the liability for employer National Insurance Contributions shall be transferred to the Participant; and (iv) to
enter into a joint election, under section 431(1) or 431(2) of the Income Tax (Earnings & Pensions) Act 2003, in
respect  of  the  Shares  delivered  pursuant  to  this  Award,  if  required  to  do  so  by  the  Company,  the  Participant’s
employer  or  former  employer,  before,  on  or  within  14  days  after  any  date  of  delivery  of  such  Shares.  Any  such
Participant  Tax  Liability  due  shall  be  paid,  at  the  option  of  the  Company,  as  follows  (or  utilizing  such  other
arrangement as may be specified by the Company):

 
 
(a)          through reducing the number of Shares otherwise entitled to be issued to the Participant on the applicable

vesting date in an amount equal to the amount of withholding tax due and payable by the Company; or

(b)          withholding from the Participant’s paycheck an amount equal to the Participant Tax Liability.

 
 
EMPLOYMENT AGREEMENT

Exhibit 10.17

THIS EMPLOYMENT AGREEMENT (this “Agreement”), made effective as of November 19, 2019, is entered into

by Intercept Pharmaceuticals, Inc. (the “Company”) and Jason Campagna (“Executive”).

WHEREAS, Executive has been employed by the Company pursuant to that certain employment agreement, made

effective as July 22, 2016, by the Company and Executive (the “Prior Agreement”);

WHEREAS,  the  Company  now  desires  to  employ  Executive,  and  Executive  now  desires  to  be  employed  by  the

Company, on the terms set forth in this Agreement; and

WHEREAS, Executive has also entered into an Invention, Non-Disclosure, and Non-Solicitation Agreement as of

even date herewith.

NOW THEREFORE, in consideration of the mutual covenants and promises contained in this Agreement, and other
good  and  valuable  consideration,  the  receipt  and  sufficiency  of  which  are  hereby  acknowledged  by  the  parties  to  this
Agreement, the parties agree as follows:

1.          Term  of  Employment.    The  Company  hereby  agrees  to  employ  Executive,  and  Executive  hereby  accepts
employment with the Company, upon the terms set forth in this Agreement, for the period commencing on December 1, 2019
or such date as may be otherwise agreed upon with the Company (the “Commencement Date”) and ending on the one year
anniversary  thereof,  unless  sooner  terminated  in  accordance  with  the  provisions  of  Section  4  (such  period,  the  “Initial
Term”);  provided,    however,  that  on  each  anniversary  of  the  Commencement  Date,  the  term  of  employment  under  this
Agreement shall be automatically extended for an additional one-year period (each such period, a “Subsequent Term”) unless
terminated  sooner  pursuant  to  Section  4  or  if,  at  least  thirty  (30)  days  prior  to  the  applicable  anniversary  date,  either
Executive or the Company provides written notice to the other party electing not to extend. The Initial Term together with
each Subsequent Term, if any, are referred to hereinafter as the “Agreement Term.”

2.     Title; Capacity.  During the Agreement Term, the Company will employ Executive as its Chief Medical Officer
to perform the duties and responsibilities inherent in such position and such other duties and responsibilities consistent with
such position as the Chief Executive Officer of the Company (the “CEO”) shall from time to time reasonably assign to him.
On an annual basis, the Company’s Board of Directors (the “Board”) in consultation with Executive and the CEO, will set
reasonably attainable, specific goals pursuant to the objectives of the Company as in effect from time to time. Executive shall
report  directly  to  the  CEO  and  shall  be  subject  to  the  supervision  of,  and  shall  have  such  authority  as  is  delegated  to
Executive by, the CEO, which authority shall be sufficient to perform Executive’s duties hereunder. Executive will be based
in  Massachusetts.  Subject  to  Section  4.3  below,  the  location  of  Executive’s  employment  is  subject  to  change  during  the
course of the Agreement Term as determined by the CEO in consultation with the Executive. Executive hereby accepts such
employment and agrees to undertake the duties and responsibilities inherent in such position and such other duties as may be
reasonably assigned to Executive. Executive shall devote substantially all of his business time, energies and attention in the
performance  of  the  foregoing  services.  Notwithstanding  the  foregoing,  nothing  herein  shall  preclude  Executive  from  (i)
performing services for such other companies as the Company may designate or permit, (ii) serving, with the prior written
consent of the Board, which consent shall not be unreasonably withheld, as an officer or member of the boards of directors or
advisory boards (or their equivalents in the case of a non-corporate entity) of non-competing businesses, (iii) serving as an
officer  or  a  member  of  charitable,  educational  or  civic  organizations,  (iv)  engaging  in  charitable  activities  and  community
affairs,  and  (v)  managing  Executive's  personal  investments  and  affairs;  provided,  however,  that  the  activities  set  out  in
clauses  (i)  –  (v)  shall  be  limited  by  Executive  so  as  not  to  materially  interfere,  individually  or  in  the  aggregate,  with  the
performance of Executive's duties and responsibilities hereunder.

3.     Compensation and Benefits.

payable in accordance with the Company’s regular payroll practices. Such base salary shall be subject

3.1                    Salary.    The  Company  shall  pay  Executive  an  initial  annualized  base  salary  of  $465,000.00,

to  annual  review  and  increase  (but  not  decrease)  as  may  be  determined  and  approved  by  the  Board  or  the  Company’s
Compensation Committee in its sole discretion.

3.2          Bonuses.

(a)          Annual Bonus. At the end of a given fiscal year, Executive will be eligible to receive a
bonus based on a target equal to 50% of his base salary in effect at the end of such fiscal year. Executive’s annual bonus for
the  fiscal  year  in  which  the  Commencement  Date  occurs  shall  be  based  upon  his  annualized  base  salary  and  shall  not  be
prorated. The amount of any such bonus shall be based on factors including, but not limited to, Executive’s achievement, as
determined  by  the  Board  or  the  Compensation  Committee  in  its  sole  discretion,  of  reasonable  goals  and  milestones
established  in  advance  by  the  Board  or  the  Compensation  Committee  in  consultation  with  the  CEO  and  Executive.  The
period  for  calculation  of  the  bonus  shall  be  consistent  with  the  Company’s  fiscal  year.  Such  bonus,  if  any,  will  be  paid  to
Executive on or after January 1 and in any case no later than March 15 of the immediately succeeding fiscal year. The bonus
shall be paid in cash; provided that, if requested by Executive and approved by the Board, some or all of the bonus may be
paid in equity under the Company’s stockholder approved stock plan then in effect (valued at the fair market value thereof),
or any combination of the foregoing. To the extent that the Company is required pursuant to Section 954 of the Dodd-Frank
Wall  Street  Reform  and  Consumer  Protection  Act  to  develop  and  implement  a  policy  (the  “Policy”)  providing  for  the
recovery  from  the  Executive  of  any  payment  of  incentive-based  compensation  paid  to  the  Executive  that  was  based  upon
erroneous data contained in an accounting statement, this Agreement shall be deemed amended and the Policy incorporated
herein by reference as of the date that the Company takes all necessary corporate action to adopt the Policy, without requiring
any further action of the Company or the Executive, provided that any such Policy shall only be binding on the Executive if
the same Policy applies to the Company's other executive officers.

3.3          Equity Awards.  At the sole discretion of the Board or the Company’s Compensation Committee,
stock options or other equity-based awards may be granted to Executive from time to time under the Company’s 2012 Equity
Incentive Plan (the “2012 Plan”).

3.4          Fringe Benefits.  Executive shall be entitled to participate in all bonus and benefit programs that
the Company establishes and makes available to its U.S.-based executives and/or employees from time to time, including, but
not  limited  to,  health  care  plans,  dental  care  plans,  vision  care  plans,  supplemental  retirement  plans,  life  insurance  plans,
disability insurance plans and incentive compensation plans, to the extent that Executive is eligible under, and subject to the
terms  and  conditions  of,  the  applicable  plan  documents  governing  such  programs.  The  Company  shall  pay  100%  of  the
premium cost for health insurance coverage for Executive, his spouse and children, provided that his spouse and dependents
are  not  covered  by  an  equivalent  health  insurance  plan  provided  by  his  spouse’s  employer.    Executive  shall  be  eligible  to
accrue up to four (4) weeks of paid vacation each calendar year (to be taken at such times and in such number of days as
Executive  shall  determine  in  consultation  with  the  CEO  and  in  a  manner  so  as  not  to  impair  or  otherwise  interfere  with
Executive’s ability to perform his duties and responsibilities hereunder). The vacation days for which Executive is eligible
shall accrue at the rate of 1.67 days per month that Executive is employed during such calendar year. Vacation accrual will be
capped at 1.75 times Executive’s annual vacation accrual. When Executive’s accrued vacation reaches the cap, he will not
accrue additional vacation time until some of the previously accrued vacation is used and the accrued amount falls below the
cap, unless the Company is acquired by another business venture, in which case none of the previous year’s accrued vacation
will be subject to a cap. Executive shall also be eligible for paid holidays and paid sick days annually, in accordance with the
Company’s policies for its senior executives as in effect from time to time. At the end of each calendar year, all unused sick
days shall be forfeited.

3.5          Reimbursement of Expenses.   The  Company  shall  reimburse  Executive  for  reasonable  travel,
entertainment and other expenses incurred or paid in connection with, or related to the performance of Executive’s duties,
responsibilities  or  services  under  this  Agreement,  upon  presentation  by  Executive  of  documentation,  expense  statements,
vouchers  and/or  such  other  supporting  information  as  the  Company  may  request.  Executive  must  submit  proper
documentation for each such expense within sixty (60) days after the later of (i) his incurrence of such expense or (ii) his
receipt of the invoice for such expense. The Company will reimburse Executive for that expense within thirty (30) days after
receipt of the documentation.

and local taxes and withholdings, if any.

3.6          Withholdings.  Payments made under this Section 3 shall be subject to applicable federal, state

4.     Termination of Employment Period.  The Agreement Term shall terminate upon the occurrence of any of the

following:

Term; provided,  that notice is given in accordance with Section 1 of this Agreement.

4.1          Expiration of the Agreement Term.  This Agreement shall expire at the end of the Agreement

4.2          Termination by the Company for Cause.   At the election of the Company, the Executive may be
terminated  by  the  Company  for  Cause  (as  defined  below),  immediately  following  written  notice  by  the  Company  to
Executive, which notice shall identify in reasonable detail the Cause upon which termination is based, except that for reason
4.2(a)(iv) below, termination may not occur prior to the expiration of the thirty (30) day period to cure. For the purposes of
this Agreement, “Cause” for termination shall be deemed to exist upon:

(a)                    a  good  faith  finding  by  the  Company  that  (i)  Executive  has  engaged  in  material
dishonesty,  willful  misconduct  or  gross  negligence  in  connection  with  the  performance  of  his  duties;  (ii)  Executive  has
committed any act of fraud or embezzlement with respect to the Company or any of its affiliates; (iii) Executive has breached
or has threatened to breach his Invention, Non-Disclosure, and Non-Solicitation Agreement; or (iv) Executive has materially
breached this Agreement, and Executive has failed to cure such conduct or breach within thirty (30) days after his receipt of
written notice from the Company of such breach; or

moral turpitude, fraud or embezzlement, or any felony.

(b)          Executive’s conviction, guilty plea, or entry of nolo contendere to any crime involving

4.3          Termination By Executive with Good Reason.  Executive may terminate the Agreement Term
with  Good  Reason.  For  purposes  of  this  Agreement,  “Good  Reason”  means  the  occurrence,  without  Executive’s  written
consent,  of  any  of  the  events  or  circumstances  set  forth  in  clauses  (a)  through  (c)  below.  In  addition,  notwithstanding  the
occurrence  of  any  of  the  events  enumerated  in  clauses  (a)  through  (c),  such  occurrence  shall  not  be  deemed  to  constitute
Good Reason if, within thirty (30) days after the Company’s receipt of written notice from Executive of the occurrence or
existence of an event or circumstance enumerated in clauses (a) through (c), such event or circumstance has been remedied
by the Company. Executive shall not be deemed to have terminated his employment with Good Reason unless Executive first
delivers  a  written  notice  of  termination  to  the  Company  identifying  in  reasonable  detail  the  acts  or  omissions  constituting
Good Reason within ninety (90) days after their occurrence and the provision of this Agreement relied upon, such acts or
omissions are not cured by the Company within thirty (30) days of the receipt of such notice, and Executive actually ends his
employment within one-hundred and twenty (120) days after the Company’s failure to cure.

(a)                    the  assignment  to  Executive  of  duties  inconsistent  in  any  material  respect  with
Executive’s  position  as  Chief  Medical  Officer  (including  status,  offices,  titles,  authority,  or  responsibilities)  or  any  other
action  or  omission  by  the  Company  which  results  in  a  material  diminution  in  Executive’s  position,  status,  offices,  titles,
authority, responsibilities, or reporting requirements;

(b)                    a  change  by  the  Company  in  the  location  at  which  Executive  performs  his  principal
duties  for  the  Company  to  a  different  location  that  is  outside  a  radius  of  fifty  (50)  miles  from  (i)  Executive’s  principal
residence immediately prior to the date on which such change occurs and (ii) the location at which Executive performed his
principal duties for the Company immediately prior to the date on which such change occurs; or

between the Company and Executive.

(c)          any material breach by the Company of this Agreement or any other material agreement

4.4          Death or Disability.  This Agreement shall terminate upon Executive’s death or disability. As used
in this Agreement, the determination of “disability” shall occur when Executive, due to a physical or mental disability, for a
period of 60 consecutive days, or 120 days in the aggregate whether or not consecutive, during any 360-day period, is unable
to perform the services contemplated under this Agreement. A determination of disability

shall be made by a physician satisfactory to both Executive and the Company; provided,  that, if Executive and the Company
do not agree on a physician, Executive and the Company shall each select a physician and these two together shall select a
third physician, whose determination as to disability shall be binding on all parties.

4.5          Termination by Executive Without Good Reason or Termination by the Company Without Cause.
At the election of Executive without Good Reason or by the Company without Cause, upon not less than thirty (30) days’
prior written notice to the other party.

5.     Effect of Termination.

5.1          Payments Upon Termination for Any Reason.  In the event Executive’s employment terminates
pursuant to Section 4, the Company shall pay to Executive (or Executive’s estate or legal representative, if applicable), on the
date  of  Executive’s  termination  of  employment  with  the  Company  (or  as  soon  thereafter  as  is  practicable,  consistent  with
applicable law and the terms of any deferred compensation plan or agreement), the compensation and benefits under Sections
3.1, 3.4 and 3.5 that are accrued and unpaid through such termination date (including, without limitation, an amount equal to
all accrued but unused vacation pay and unreimbursed expenses). In the event of termination of Executive’s employment by
Executive by reason of non-renewal of the Agreement Term pursuant to Sections 1 and 4.1, the Company for Cause pursuant
to Section 4.2, by reason of Executive’s death or disability pursuant to Section 4.4, or by Executive without Good Reason
pursuant  to  Section  4.5,  Executive  shall  not  receive  any  compensation  or  benefits  other  than  as  expressly  stated  in  this
Section 5.1 and as otherwise required by law.

5.2          Termination by the Company Without Cause, by the Company by Reason of Non-Renewal of
Agreement  Term,  or  by  Executive  for  Good  Reason.    Subject  to  Section  5.3  below,  in  addition  to  the  payments  and
provisions  under  Section  5.1,  in  the  event  of  termination  of  Executive’s  employment  by  the  Company  by  reason  of  non-
renewal of the Agreement Term pursuant to Sections 1 and 4.1, by Executive for Good Reason pursuant to Section 4.3, or by
the Company without Cause pursuant to Section 4.5, provided that Executive executes a release of claims substantially in the
form attached hereto as Exhibit A (the “Release”), which Release must be effective and irrevocable prior to the sixtieth (60 )
day following the termination of the Executive's employment (the “Review Period”), the Company shall provide Executive
with the following:

th

(a)          twelve (12) months of Executive’s base salary in effect at the time of termination of
employment,  payable  according  to  the  Company’s  payroll  commencing  on  the  first  payroll  date  following  the  date  the
Release is effective and irrevocable (the “Payment Date”), subject to compliance with Sections 5.5 and 12.6; and

(b)          the Company will, for a period of twelve (12) months following Executive’s termination
from employment, continue Executive’s participation in the Company’s group health plan and dental plan and shall pay that
portion of the premiums that the Company paid on behalf of Executive and his dependents during Executive’s employment,
provided,    however,  that  if  the  Company’s  health  insurance  plan  and/or  dental  plan  does  not  permit  such  continued
participation  in  such  plan  after  Executive’s  termination  of  employment,  then  the  Company  shall  pay  that  portion  of  the
premiums associated with COBRA continuation coverage that the Company paid on behalf of Executive and his dependents
during Executive’s employment, including any administrative fee, on Executive’s behalf for such twelve-month period; and
provided,  further, that if Executive becomes employed with another employer during the period in which continued health
insurance and/or dental insurance is being provided pursuant to this Section, the Company shall not be required to continue
such health and dental benefits, or if applicable, to pay the costs of COBRA, if Executive becomes covered under a health
insurance plan of the new employer. (For purposes of this Section 5.2(b), the term “Executive” shall include, to the extent
applicable,  Executive’s  spouse  and  any  of  Executive’s  dependents  covered  under  the  Company’s  group  health  plan  and/or
dental plan prior to his termination of employment.)

5.3          Termination in the Event of a Change in Control.

(a)          In addition to the payments and provisions under Section 5.1 but in lieu of, and not in
addition to, the payments required pursuant to Section 5.2 above, in the event Executive’s employment with the Company is
terminated by the Company by reason of non-renewal of the Agreement Term pursuant to Sections 1 and 4.1, by Executive
for Good Reason pursuant to Section 4.3, or by the Company without Cause pursuant to Section 4.5, in any such case, in
anticipation  of  and/or  within  twelve  (12)  months  following  a  Change  in  Control  (as  defined  below)  provided  that  such
Change in Control also qualifies as a “change in control event” within the meaning of Treasury Regulation Section 1.409A-
3(i)(5)(i)  (where  required  to  avoid  the  imposition  of  penalty  taxes  under  Section  409A)  and  provided  that  Executive  (or
Executive’s legal representative, if applicable) executes a Release and the Release becomes effective and irrevocable prior to
the end of the Review Period, Executive shall be entitled to the following:

(i)           a lump sum cash amount equal to twelve (12) months of Executive’s base salary
in effect at the time of Executive’s termination, such payment to be made on the Payment Date, subject to compliance with
Sections 5.5 and 12.6;

(ii)          for up to twelve (12) months after Executive’s date of termination, the Company
shall  continue  Executive’s  participation  in  the  Company’s  group  health  and  dental  plan  and  shall  pay  that  portion  of  the
premiums  that  the  Company  paid  on  behalf  of  Executive  and  his  dependents  during  Executive’s  employment;  provided,
 however, that if the Company’s health insurance plan and/or dental insurance plan does not permit Executive’s continued
participation  in  such  plan  after  his  termination  of  employment,  then  the  Company  shall  pay  that  portion  of  the  premiums
associated  with  COBRA  continuation  coverage  that  the  Company  paid  on  behalf  of  Executive  and  his  dependents  during
Executive’s employment, including administrative fees, on Executive’s behalf for so long as COBRA continuation coverage
is available, up to twelve (12) months; and provided,  further,  that  if  Executive  becomes  employed  with  another  employer
during the period in which continued health insurance and/or dental insurance is being provided pursuant to this Section, the
Company  shall  not  be  required  to  continue  the  relevant  benefits,  or  if  applicable,  to  pay  the  relevant  costs  of  COBRA,  if
Executive  becomes  covered  under  a  health  insurance  plan  and/or  dental  plan  of  the  new  employer.  (For  purposes  of  this
Section  5.3(a)(ii),  the  term  “Executive”  shall  include,  to  the  extent  applicable,  Executive’s  spouse  and  any  of  Executive’s
dependents covered under the Company’s group health plan and/or dental plan prior to his termination of employment.)

following events occur:

(b)          As used herein, “Change in Control” shall occur or be deemed to occur if any of the

transactions) of all or substantially all of the assets of the Company; or

(i)           any sale, lease, exchange or other transfer (in one transaction or a series of

(ii)          any consolidation or merger of the Company (including, without limitation, a
triangular  merger)  where  the  shareholders  of  the  Company  immediately  prior  to  the  consolidation  or  merger,  would  not,
immediately after the consolidation or merger, beneficially own, directly or indirectly, shares representing in the aggregate
more than fifty percent (50%) of the combined voting power of all the outstanding securities of the corporation issuing cash
or securities in the consolidation or merger (or of its ultimate parent corporation, if any); or

(iii)                  a  third  person,  including  a  “person”  as  defined  in  Section  13(d)(3)  of  the
Securities  Exchange  Act  of  1934,  as  amended  (the  “Exchange  Act”)  (but  other  than  (x)  the  Company,  (y)  any  employee
benefit plan of the Company, or (z) investors purchasing equity securities of the Company pursuant to a financing or a series
of financings approved by the Board of Directors of the Company) becomes the beneficial owner (as defined in Rule 13d-3
under the Exchange Act) directly or indirectly, of Controlling Securities (as defined below). “Controlling Securities” shall
mean securities representing 25% or more of the total number of votes that may be cast for the election of the directors of the
Company.

 
5.4          Effect of Termination on Stock Options and Other Equity Compensation.

(a)          In the event of Executive’s termination by Executive by reason of non-renewal of the
Agreement Term pursuant to Sections 1 and 4.1, by the Company for Cause pursuant to Section 4.2, or by Executive without
Good Reason pursuant to Section 4.5, all unvested stock options and other equity-based awards granted to Executive before
and  after  the  date  of  this  Agreement  shall  be  immediately  forfeited  upon  the  effective  date  of  such  termination  of
employment or as otherwise provided in the award agreement; provided,  that, Executive shall have until the earlier of the
expiration  date  of  the  option  or  ninety  (90)  days  from  the  date  of  termination  of  Executive  to  exercise  all  vested  options
unless the stock plan pursuant to which the option is granted requires earlier termination in connection with a liquidation or
sale of the Company.

(b)          In the event of Executive’s termination by the Company by reason of non-renewal of the
Agreement Term pursuant to Sections 1 and 4.1, by Executive for Good Reason pursuant to Section 4.3, or by the Company
without  Cause  pursuant  to  Section  4.5,  and  provided  that  Executive  (or  Executive’s  legal  representative,  if  applicable)
executes a Release and the Release becomes effective and irrevocable prior to the end of the Review Period, that number of
Executive’s unvested stock options and other equity-based awards that would otherwise have vested from the effective date
of  Executive’s  termination  to  the  first  anniversary  of  such  date  shall  vest  as  of  the  date  the  Release  is  effective  and
irrevocable  and  Executive  (or  Executive’s  estate  or  legal  representative,  if  applicable)  shall  have  until  the  earlier  of  the
expiration date of the option or one (1) year from the date of termination of Executive’s employment to exercise all vested
options  unless  the  stock  plan  pursuant  to  which  the  option  is  granted  requires  earlier  termination  in  connection  with  a
liquidation or sale of the Company.

(c)          In the event Executive’s employment with the Company is terminated by the Company
by reason of non-renewal of the Agreement Term pursuant to Sections 1 and 4.1, by Executive for Good Reason pursuant to
Section  4.3,  or  by  the  Company  without  Cause  pursuant  to  Section  4.5,  in  any  such  case,  in  anticipation  of  and/or  within
twelve (12) months following a Change in Control, in lieu of the acceleration provided for pursuant to Section 5.4(b) above,
provided  that  Executive  (or  Executive’s  legal  representative,  if  applicable)  executes  a  Release  and  the  Release  becomes
effective  and  irrevocable  prior  to  the  end  of  the  Review  Period,  to  the  extent  vesting  and  acceleration  will  not  result  in  a
violation of Section 409A, all of Executive’s unvested stock options and other equity-based awards then in effect shall vest as
of the date the Release is effective and irrevocable and Executive (or Executive’s estate or legal representative, if applicable)
shall have until the earlier of the expiration date of the option or one (1) year from the date of termination of Executive’s
employment  to  exercise  all  vested  options  unless  the  stock  plan  pursuant  to  which  the  option  is  granted  requires  earlier
termination in connection with a liquidation or sale of the Company.

(d)                    In  the  event  Executive’s  employment  with  the  Company  is  terminated  by  reason  of
disability pursuant to Section 4.4, all unvested stock and stock options granted to Executive before and after the date of this
Agreement  shall  be  immediately  forfeited  upon  the  effective  date  of  such  termination  of  employment  or  as  otherwise
provided in the option agreement; provided,  that, Executive shall have until the earlier of the expiration date of the option or
one  (1)  year  from  the  date  of  termination  of  Executive’s  employment  to  exercise  all  vested  options  unless  the  stock  plan
pursuant to which the option is granted requires earlier termination in connection with a liquidation or sale of the Company.

5.5          Review Period.  In the event that the Review Period begins in one taxable year of the Executive
and ends in a later taxable year, any payments contingent upon Executive’s execution without revocation of the Release prior
to the end of the Review Period will commence to be paid (or as applicable, made in full) on the first payroll date in the later
taxable year. In no event will any payments be made or commence to be paid later than the ninetieth (90th) day following the
Executive’s date of termination, subject to compliance with Section 12.6 herein.

5.6             Limitation  on  Benefits.    The  Company  will  make  the  payments  under  this  Agreement  without
regard to whether the deductibility of such payments (or any other payments or benefits) would be limited or precluded by
Section 280G of the Internal Revenue Code of 1986, as amended (the “Code”) and without regard to whether such payments
would subject Executive to the federal excise tax levied on certain “excess parachute payments” under Section 4999 of the
Code (the “Excise Tax”); provided, however, that if the Total After-Tax Payments (as defined below) would be increased by
the  reduction  or  elimination  of  any  payment  and/or  other  benefit  (including  the  vesting  of  the  equity  awards)  under  this
Agreement, then the amounts payable under this Agreement will be reduced or

eliminated  as  follows,  if  possible:  (i)  first,  by  reducing  or  eliminating  any  cash  payments  or  other  benefits  (other  than  the
vesting of the equity awards) and (ii) second, by reducing or eliminating the vesting of those equity awards that occur as a
result of such Change in Control (as provided above), to the extent necessary to maximize the Total After-Tax Payments. The
Company’s independent, certified public accounting firm (the “Accounting Firm”) will determine whether and to what extent
payments or vesting under this agreement are required to be reduced in accordance with the preceding sentence. For purposes
of  this  Agreement,  “Total  After-Tax  Payments”  means  the  total  of  all  “parachute  payments”  (as  that  term  is  defined  in
Section 280G(b)(2) of the Code) made to or for the benefit of Executive (whether made under the Agreement or otherwise)
by the Company or any of its affiliates, after reduction for all applicable federal, state and local income taxes, employment,
social security and Medicare taxes, the imposition of the Excise Tax and all other taxes, determined by applying the highest
marginal  rate  under  Section  1  of  the  Code  and  under  state  and  local  laws  which  applied  (or  is  likely  to  apply)  to  the
Executive’s  taxable  income  for  the  tax  year  in  which  the  transaction  which  causes  the  application  of  Section  280G  of  the
Code occurs, or such other rate(s) as the Accounting Firm determines to be likely to apply to the Executive in the relevant tax
year(s) in which any of the parachute payments are expected to be made. The Company agrees to pay for all costs associated
with the Accounting Firm and the determination of the payments or vesting required to be reduced and for the avoidance of
doubt, shall not be required to pay any taxes, penalties, interest or other expenses to which Executive may be subject. If it is
ultimately  determined  (by  IRS  private  letter  ruling  or  closing  agreement,  court  decision  or  otherwise)  that  Executive’s
parachute  payments  were  reduced  by  too  much  or  by  too  little  in  order  to  accomplish  the  purpose  of  this  Section  5.6,  the
Executive and the Company shall promptly cooperate to correct such underpayment or overpayment in a manner consistent
with the purpose of this Section 5.6.

5.7          Withholdings.  Payments made under this Section 5 shall be subject to applicable federal, state
and local taxes and withholdings. If the payment of any COBRA or health insurance premiums would otherwise violate the
nondiscrimination rules or cause the reimbursement of claims to be taxable under the Patient Protection and Affordable Care
Act  of  2010,  together  with  the  Health  Care  and  Education  Reconciliation  Act  of  2010  (collectively,  the  “Act”)  or  Section
105(h) of the Code, the Company paid premiums shall be treated as taxable payments and be subject to imputed income tax
treatment to the extent necessary to eliminate any discriminatory treatment or taxation under the Act or Section 105(h) of the
Code.

6.          Notices.    All  notices,  requests,  consents  and  other  communications  hereunder  will  be  in  writing,  will  be
addressed, if to the Company, at its principal corporate offices to the attention of the Legal Department, and if to Executive,
at his address set forth on the signature page hereto or in the personnel records of the Company (as applicable), or in either
case, such other address as a party may designate by notice hereunder, and will be either (i) delivered by hand, (ii) sent by
overnight courier, or (iii) sent by registered or certified mail, return receipt requested, postage prepaid. All notices, requests,
consents  and  other  communications  hereunder  will  be  deemed  to  have  been  given  either  (i)  if  by  hand,  at  the  time  of  the
delivery thereof to the receiving party at the address of such party set forth above, (ii) if sent by overnight courier, on the next
business day following the day such notice is delivered to the courier service, or (iii) if sent by registered or certified mail, on
the fifth business day following the day such mailing is made.

7.     Absence of Restrictions.  Executive represents and warrants that Executive is not bound by any employment
contracts, restrictive covenants or other restrictions that prevent him from entering into employment with, or carrying out his
responsibilities for, the Company, or which are in any way inconsistent with any of the terms of this Agreement. Executive
further represents that, except as Executive has previously disclosed or described to the Company, Executive is not bound by
the terms of any agreement with any previous employer or other party to refrain from using or disclosing any trade secret or
confidential  or  proprietary  information  in  the  course  of  his  employment  with  the  Company,  to  refrain  from  competing,
directly or indirectly, with the business of such previous employer or any other party, or to refrain from soliciting employees,
customers or suppliers of such previous employer or other party. Executive further represents that he will not disclose to the
Company or induce the Company to use any confidential or proprietary information or material belonging to any previous
employer or others.

8.     Entire Agreement.  This Agreement constitutes the entire agreement between the parties and supersedes and
replaces  all  prior  agreements  and  understandings,  whether  written  or  oral  relating  to  the  subject  matter  of  this  Agreement
(including,  from  and  after  the  Commencement  Date,  the  Prior  Agreement),  with  the  exception  of  any  Invention,  Non-
Disclosure,  Non-Competition  and  Non-Solicitation  Agreement  by  and  between 
the  Company  and  Executive.
Notwithstanding the foregoing, the parties to this Agreement acknowledge that stock options and other equity awards may be
granted  by  the  Company  to  Executive  under  and  pursuant  to  the  2012  Plan  and  any  amendments  thereto,  as  well  as  any
additional plans, and the award agreements related to such plans.

9.     Amendment.  This Agreement may be amended or modified only by a written instrument executed by both the

Company and Executive.

10.      Governing  Law;  Consent  to  Jurisdiction.    This  Agreement  shall  be  construed,  interpreted  and  enforced  in
accordance with the laws of the State of New York without regard to conflict of law principles. Any action, suit or other legal
proceeding arising under or relating to any provision of this Agreement shall be commenced only in a court of the State of
New York (or, if appropriate, a federal court located within the State of New York), and the Company and Executive each
consents  to  the  jurisdiction  of  such  a  court.  THE  COMPANY  AND  EXECUTIVE  EACH  HEREBY  IRREVOCABLY
WAIVE ANY RIGHT TO A TRIAL BY JURY IN ANY ACTION, SUIT OR OTHER LEGAL PROCEEDING ARISING
UNDER OR RELATING TO ANY PROVISION OF THIS AGREEMENT.

11.   Successors and Assigns.  This Agreement shall be binding upon and inure to the benefit of both parties and
their  respective  successors  and  assigns,  including  any  corporation  or  other  entity  with  which,  or  into  which,  the  Company
may  be  merged  or  which  may  succeed  to  the  Company’s  assets  or  business,  provided,    however,  that  the  obligations  of
Executive are personal and shall not be assigned by him. Notwithstanding the foregoing, if Executive dies the compensation
and benefits stated in this Agreement will be paid to his beneficiary or his estate if no beneficiary.

12.   Miscellaneous.

12.1        No Waiver.  No delay or omission by the Company in exercising any right under this Agreement shall
operate as a waiver of that or any other right. A waiver or consent given on any one occasion shall be effective only in
that instance and shall not be construed as a bar or waiver of any right on any other occasion.

12.2        Captions.  The captions of the sections of this Agreement are for convenience of reference only and in no

way define, limit or affect the scope or substance of any section of this Agreement.

12.3        Severability.  In case any provision of this Agreement shall be invalid, illegal or otherwise unenforceable,

the validity, legality and enforceability of the remaining provisions shall in no way be affected or impaired thereby.

12.4                Counterparts.    This  Agreement  may  be  executed  in  two  or  more  counterparts,  each  of  which  shall  be
deemed  an  original  but  all  of  which  together  shall  constitute  one  and  the  same  instrument.  This  Agreement  may  be
delivered by facsimile, and facsimile signatures shall be treated as original signatures for all applicable purposes.

12.5                Blue  Penciling.    To  the  extent  that  any  provision  herein  or  in  any  plan  of  nonqualified  deferred
compensation  that  this  document  is  a  part  of  contravenes  the  requirements  of  Code  Section  409A  (or  the  regulations
thereunder),  such  provision  shall  be  appropriately  modified  in  accordance  with  available  IRS  guidance  (including
without  limitation  IRS  Notice  2010-6  and  related  guidance)  so  that  Executive  is  not  subject  to  the  adverse  effects  of
Code Section 409A but will nevertheless retain, to the extent possible, the economic benefit of the provision.

12.6        Section 409A; Withholding.

12.6.1     The payments under this Agreement are intended either to be exempt from Section 409A of the
Code under the short-term deferral, separation pay, or other applicable exception, or to otherwise comply
with  Section  409A.  The  parties  agree  that  this  Agreement  shall  be  administered  in  a  manner  consistent
with such intent. For purposes of Section 409A, all payments under this Agreement shall be considered
separate  payments.  If  any  amount  or  benefit  payable  to  the  Executive  under  this  Agreement  upon  a
“termination of employment” is determined by the Company to constitute a “deferral of compensation”
for purposes of Section 409A (after taking into account any applicable exceptions), such

amount  or  benefit  shall  not  be  paid  or  provided  until  the  Executive  has  also  experienced  a  “separation
from service” from the Company within the meaning of Section 409A. Notwithstanding any provision to
the contrary, to the extent Executive is considered a specified employee under Section 409A and would be
entitled during the six-month  period beginning on Executive’s separation from service to a payment that
is not otherwise excluded under Section 409A, such payment will not be made until the earlier of the six-
month  anniversary  of  Executive’s  separation  from  service  or  death;  provided  that  the  first  payment
made after the delay shall include all amounts that would have been paid earlier but for such six (6) month
delay. At the request of the Executive, the Company shall set aside those payments that would otherwise
be made in such six-month period in a trust is in compliance with Rev. Proc. 92-64.

12.6.2   If an expense reimbursement or provision of in-kind benefit provided to the Executive under this
Agreement is not exempt from Section 409A of the Code, the following rules apply: (i) in no event shall
any reimbursement be paid after the last day of the taxable year following the taxable year in which the
expense was incurred; (ii) the amount of reimbursable expenses incurred or provision of in-kind benefits
in one tax year shall not affect the expenses eligible for reimbursement or the provision of in-kind benefits
in any other tax year; and (iii) the right to reimbursement for expenses or provision of in-kind benefits is
not subject to liquidation or exchange for any other benefit.

12.6.3   If an expense reimbursement or provision of in-kind benefit provided to the Executive under this
Agreement is not exempt from Section 409A of the Code, the following rules apply: (i) in no event shall
any reimbursement be paid after the last day of the taxable year following the taxable year in which the
expense was incurred; (ii) the amount of reimbursable expenses incurred or provision of in-kind benefits
in one tax year shall not affect the expenses eligible for reimbursement or the provision of in-kind benefits
in any other tax year; and (iii) the right to reimbursement for expenses or provision of in-kind benefits is
not subject to liquidation or exchange for any other benefit.

12.6.4      All  compensatory  payments  under  this  Agreement  are  subject  to  any  required  tax  or  other
withholdings.

12.7        Interpretation. References to decisions by the Company will be made by the Board or the applicable Board

committee.

[signature page follows]

IN  WITNESS  WHEREOF,  the  parties  hereto  have  executed  this  Agreement  as  of  the  day  and  year  set  first  forth

above.

THE COMPANY:

INTERCEPT PHARMACEUTICALS, INC.

By: /s/ Mark Pruzanski

Name: Mark E. Pruzanski, MD
Title: President and Chief Executive Officer

EXECUTIVE:

By: /s/ Jason Campagna

Name: Jason Campagna

Address for Notice Purposes:

[Last address in books and records of the Company]

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit A

RELEASE OF CLAIMS

1

FOR AND IN CONSIDERATION OF the payments and benefits (the “Separation Benefits”) to be provided to
me in connection with the separation of my employment, in accordance with the Employment Agreement between Intercept
Pharmaceuticals,  Inc.  (the  “Company”)  and  me  dated  [(cid:0)],  2019  (the  “Agreement”),  which  Separation  Benefits  are
conditioned on my signing this Release of Claims (“Release”) and which I will forfeit unless I execute and do not revoke this
Release of Claims, I, on my own behalf and on behalf of my heirs and estate, voluntarily, knowingly and willingly release
and forever discharge the Company, its subsidiaries, affiliates, parents, and, in their capacities as such, stockholders, together
with  each  of  those  entities’  respective  officers,  directors,  stockholders,  employees,  agents,  fiduciaries  and  administrators,
each in their capacities as such (collectively, the “Releasees”) from any and all claims and rights of any nature whatsoever
which I now have or in the future may have against them up to the date I execute this Release, whether known or unknown,
suspected  or  unsuspected.  This  Release  includes,  but  is  not  limited  to,  any  rights  or  claims  relating  in  any  way  to  my
employment  relationship  with  the  Company  or  any  of  the  other  Releasees  or  the  termination  thereof,  any  contract  claims
(express or implied, written or oral), including, but not limited to, the Agreement, or any rights or claims under any statute,
including,  without  limitation,  the  Americans  with  Disabilities  Act,  the  Age  Discrimination  in  Employment  Act,  the  Older
Workers’ Benefit Protection Act, the Rehabilitation Act of 1973 (including Section 504 thereof), Title VII of the 1964 Civil
Rights Act, the Civil Rights Act of 1866 (42 U.S.C. § 1981), the Civil Rights Act of 1991, the Equal Pay Act, the National
Labor  Relations  Act,  the  Worker  Adjustment  and  Retraining  Notification  Act,  the  Family  Medical  Leave  Act,  the  Lilly
Ledbetter Fair Pay Act, the Genetic Information Non-Discrimination Act, the New York State Human Rights Law, the New
York City Human Rights Law, and the Employee Retirement Income Security Act of 1974, all as amended, and any other
federal,  state  or  local  law.  This  Release  specifically  includes,  but  is  not  limited  to,  any  claims  based  upon  the  right  to  the
payment of wages, incentive and performance compensation, bonuses, equity grants, vacation, pension benefits, 401(k) Plan
benefits,  stock  benefits  or  any  other  employee  benefits,  or  any  other  rights  arising  under  federal,  state  or  local  laws
prohibiting discrimination and/or harassment on the basis of race, color, age, religion, sexual orientation, religious creed, sex,
national  origin,  ancestry,  alienage,  citizenship,  nationality,  mental  or  physical  disability,  denial  of  family  and  medical  care
leave,  medical  condition  (including  cancer  and  genetic  characteristics),  marital  status,  military  status,  gender  identity,
harassment or any other basis prohibited by law.

As  a  condition  of  the  Company  entering  into  this  Release,  I  further  represent  that  I  have  not  filed  against  the
Company or any of the other Releasees, any complaints, claims or lawsuits with any arbitral tribunal, administrative agency,
or court prior to the date hereof, and that I have not transferred to any other person any such complaints, claims or lawsuits. I
understand that by signing this Release, I waive my right to any monetary recovery in connection with a local, state or federal
governmental  agency  proceeding  and  I  waive  my  right  to  file  a  claim  seeking  monetary  damages  in  any  arbitral  tribunal,
administrative  agency,  or  court.  This  Release  does  not:  (i)  prohibit  or  restrict  me  from  communicating,  providing  relevant
information  to  or  otherwise  cooperating  with  the  U.S.  Equal  Employment  Opportunity  Commission  or  any  other
governmental authority with responsibility for the administration of fair employment practices laws (including with respect to
SEC Whistleblowing) regarding a possible violation of such laws or responding to any inquiry from such authority, including
an  inquiry  about  the  existence  of  this  Release  or  its  underlying  facts,  or  (ii)  require  me  to  notify  the  Company  of  such
communications or inquiry. Furthermore, notwithstanding the foregoing, this Release does not include and will not preclude:
(a) rights or claims to vested benefits under any applicable retirement and/or pension plans; (b) rights under the Consolidated
Omnibus Budget Reconciliation Act of 1985 (“COBRA”); (c) claims for unemployment compensation; (d) rights to defense
and indemnification or under the Company’s directors’ and officers’ liability insurance, if any, from the Company for actions
or inactions taken by me in the course and scope of my employment with the Company and its parents, subsidiaries and/or
affiliates; (e) any rights I may have to obtain contribution as permitted by law in the event of entry of judgment against the
Company as a result of any act or failure to act for which I and the Company are held jointly

1               

The Executive agrees that the Company may revise this release to satisfy the purpose of providing as full a release of
claims  (subject  to  payment  of  any  benefits  provided  on  the  applicable  termination  of  employment)  as  may  be  legally
permissible.  The  Company  may  revise  it  to  reflect  changes  in  law  for  releases  and  may  add  language  for  ADEA
compliance.

 
liable; (f) any rights to vested equity that vested prior to or because of the termination of my employment and rights as a
stockholder; and/or (g) any actions to enforce the Agreement.

I acknowledge that, in signing this Release, I have not relied on any promises or representations, express or
implied, other than those that are set forth expressly herein or in the Agreement and that are intended to survive separation
from employment, in accordance with the terms of the Agreement.

Nondisclosure; Continuing Obligations - I understand and agree that, to the extent permitted by law, the
terms  and  contents  of  this  Release  (as  modified  before  signature)  and  the  contents  of  the  negotiations  and  discussions
resulting in this Release shall be maintained as confidential by me and must not be disclosed to anyone other than a member
of my immediate family, my attorney, accountant or other advisor (and, even as to such a person, only if the person agrees to
honor  this  confidentiality  requirement)  except  to  the  extent  required  by  federal  or  state  law  or  as  otherwise  agreed  to  in
writing by the Company. I acknowledge and reaffirm my obligation to keep confidential and not disclose any and all non-
public information concerning the Company that I acquired during the course of my employment or other relationship with
the  Company,  including  any  non-public  information  concerning  the  Company’s  business  affairs,  business  prospects  and
financial  condition,  as  is  stated  more  fully  in  any  Invention,  Non-Disclosure,  Non-Competition  and  Non-Solicitation
Agreement and that I will comply with such agreement in all other respects.

The Company understands and agrees that the contents of the negotiations and discussions resulting in this
Release shall be maintained as confidential and shall not be disclosed to any third parties, except to the extent required by
federal or state law or as otherwise agreed to in writing with you.

Mutual    Non-Disparagement  –  I  understand  and  agree  that  I  shall  not  make  any  false,  disparaging  or
derogatory statements to any person or entity, including any media outlet, industry group or financial institution, regarding
the Company, or any of the other Releasees or about the Company’s business affairs and financial condition. The Company
confirms that it has instructed the members of its Board of Directors and its current executive officers to not make any false,
disparaging  or  derogatory  statements  to  any  person  or  entity,  including  any  media  outlet,  industry  group  or  financial
institution,  regarding  me,  my  employment  with  the  Company,  or  my  departure  from  the  Company.  Notwithstanding  the
foregoing,  nothing herein prevents either the Releasees or me from making truthful disclosures to any governmental entity or
to  enforce  the  Agreement  or  this  Release.  For  the  avoidance  of  doubt,  nothing  in  this  Release  prohibits  me  from
communicating with a government agency, regulator or legal authority concerning any possible violations of federal or state
law  or  regulation.  Nothing  in  this  Release,  however,  authorizes  the  disclosure  of  information  I  obtained  through  a
communication  that  was  subject  to  the  attorney-client  privilege,  unless  disclosure  of  the  information  would  otherwise  be
permitted by an applicable law or rule.

Return of Company Property - I confirm that I have returned to the Company in good working order all
Company-owned keys, files, records (and copies thereof), equipment (including computer hardware, software and printers,
wireless handheld devices, cellular phones, tablets, smartphones, etc.), Company identification, the Company proprietary and
confidential information, and any other Company-owned property in my possession or control and I have left intact with, or
delivered intact to, the Company all electronic Company documents and internal and external websites, including those that I
developed or helped to develop during my employment, and that I have thereafter deleted, and destroyed any hard copies of,
all electronic files relating to the Company that are in my possession or control, including any that are located on any of my
personal computers or external or cloud storage. I further confirm that I have cancelled all accounts for my benefit, if any, in
the Company’s name including, but not limited to, credit cards, telephone charge cards, cellular phone and/or wireless data
accounts and computer accounts. Notwithstanding the foregoing, I understand that I shall be permitted to retain my contacts
and calendars and personal correspondence and any documents or data related to my compensation or reasonably needed for
tax preparation purposes.

Final Compensation  –  I  acknowledge  that  I  have  received  payment  in  full  for  all  services  rendered  in
conjunction  with  my  employment  by  the  Company,  including  payment  for  all  wages,  bonuses,  and  equity  for  any  period
before the date of this Release (other than any current salary and benefits due in the ordinary course in a final

paycheck or thereafter), and that no other compensation is owed to me, except as provided in the applicable provisions of
Section 5 of the Agreement; provided that nothing herein shall affect any claims of entitlement I may have to vested benefits
under any 401(k) plan or other ERISA-covered benefit plan (excluding severance) provided by the Company.

Cooperation – I agree to cooperate with, provide assistance to, and make myself reasonably available to
the  Company  and  its  legal  counsel  in  connection  with  any  litigation  (including  arbitration  or  administrative  hearings)  or
investigation or examination relating to the Company or any of its current or former employees, in which, in the reasonable
judgment  of  the  Company  or  its  counsel,  my  assistance  or  cooperation  is  needed  due  to  my  personal  involvement  in  or
knowledge about the circumstances to which the litigation or investigation relates. I will, when the Company or its counsel
requests, provide testimony, be available for interviews or other assistance and travel at the Company’s reasonable request in
order  to  fulfill  this  obligation.  In  connection  with  such  litigation  or  investigation,  the  Company  will  use  its  best  efforts  to
accommodate  my  schedule,  will  provide  me  with  as  much  notice  as  possible  in  advance  of  the  times  during  which  my
cooperation  or  assistance  is  needed,  and  will  reimburse  me  for  any  reasonable  travel  and  lodging  expenses  incurred  in
connection  with  such  matters  (at  a  level  of  travel  consistent  with  my  travel  while  employed  by  the  Company)  and  the
reasonable fees of any independent counsel retained by me if I reasonably believe separate counsel to be appropriate. I agree
not to assist or provide information to any adverse party in any litigation against the Company or any of its current or former
employees, except as required under law or formal legal process, unless I provide advance notice to the Company at least 10
days before such assistance or provision of information (or, if I am so required to assist or provide such information within
less  than  10  days  of  receipt  of  such  requirement,  after  I  provide  timely  advance  notice  to  the  Company)  to  allow  the
Company to take legal action with respect to the matter. Finally, I will undertake to satisfy requests for information from the
Company  with  respect  to  the  above  undertaking.  Nothing  in  this  Release  is  intended  to  restrict  or  preclude  me  from,  or
otherwise  influence  me  in,  testifying  fully  and  truthfully  in  legal,  administrative,  or  any  other  proceedings  involving  the
Company, as required by law or formal legal process.

Tax Provision – I acknowledge that I am not relying upon advice or representation of the Company with
respect to the tax treatment of any of the payments or benefits provided by the Company. The benefits provided to me are
intended to be exempt from or compliant with Section 409A of the Internal Revenue Code of 1986. The Company makes no
representation or warranty and shall have no liability to me or to any other person if any of the provisions of the Agreement
or this Release are determined to constitute deferred compensation subject to Section 409A but not to satisfy an exemption
for, or the conditions of, that section. All payments stated will be reduced by all applicable taxes and withholdings.

constitute an admission of liability or wrongdoing on the part of the Company.

Nature of Agreement – I  understand  and  agree  that  this  Release  is  a  severance  agreement  and  does  not

Voluntary Assent – I affirm that no other promises or agreements of any kind have been made to or with
me by any person or entity whatsoever to cause me to sign this Release, other than as reflected in the Agreement and that I
fully understand the meaning and intent of the Release. I acknowledge that, in signing this Release, I have not relied on any
promises or representations, express or implied, other than those that are set forth expressly herein or in the Agreement and
that are intended to survive separation from employment, in accordance with the terms of the Agreement. I further state and
represent  that  I  have  carefully  read  this  Release,  understand  the  contents  herein,  freely  and  voluntarily  assent  to  all  of  the
terms and conditions hereof, and sign my name of my own free act.

Validity – Should any provision of this Release be declared or be determined by any court of competent
jurisdiction to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected thereby and
said illegal or invalid part, term or provision shall be deemed not to be a part of this Release.

I further acknowledge that:

(1)          I first received this Release on the date of the Agreement to which it is attached as Exhibit A;

(2)          I understand that, in order for this Release to be effective, I may not sign it prior to the date of my
separation of employment with the Company but that if I wish to receive the Separation Benefits, I
must  sign  and  return  this  Release  prior  to  the  sixtieth  (60 )  day  following  my  separation  of
employment;

th

(3)          I have carefully read and understand this Release;

(4)          The Company advised me to consult with an attorney and/or any other advisors of my choice

before signing this Release;

(5)          I understand that this Release is LEGALLY BINDING and by signing it I give up certain rights;

(6)          I have voluntarily chosen to enter into this Release and have not been forced or pressured in any

way to sign it;

(7)          I acknowledge and agree that the Separation Benefits are contingent on execution of this Release,
which  releases  all  of  my  claims  against  the  Company  and  the  Releasees,  and  I  KNOWINGLY
AND VOLUNTARILY AGREE TO RELEASE the Company and the Releasees from any and
all claims I may have, known or unknown, in exchange for the benefits I have obtained by signing,
and that these benefits are in addition to any benefit I would have otherwise received if I did not
sign this Release;

(8)          I have seven (7) days after I sign this Release to revoke it by notifying the Company in writing.
The Release will not become effective or enforceable until the seven (7) day revocation period has
expired;

(9)          This Release includes a WAIVER OF ALL RIGHTS AND CLAIMS I may have under the Age

Discrimination in Employment Act of 1967 (29 U.S.C. §621 et seq.); and

(10)                This  Release  does  not  waive  any  rights  or  claims  that  may  arise  after  this  Release  becomes
effective, which is seven (7) days after I sign it, provided that I do not exercise my right to revoke
this Release.

Intending to be legally bound, I have signed this Release as of the date written below.

Signature:

Jason Campagna

  Date signed

 
      
 
  
 
 
 
Exhibit 10.41

Sumitomo Dainippon Pharma Co., Ltd. 
13-1, Kyobashi 1-chome, Chuo-ku,
Tokyo 104-8356, Japan
Phone: (81) 3 (5159) 2510
Telefax: (81) 3 (5159) 3004

October 25, 2019

Via Facsimile (with copy by email)
Mark Pruzanski, M.D.
President and Chief Executive Officer
Intercept Pharmaceuticals, Inc.
Fax: +1-646-747-1001

               Re: Termination of License Agreement

Dear Dr. Pruzanski:

Reference is made to that certain LICENSE AGREEMENT between Intercept Pharmaceuticals, Inc. (“Intercept”) and
Sumitomo Dainippon Pharma Co., Ltd. (“Sumitomo”) dated as of March 29 , 2011 regarding INT-747, as amended (the
“License Agreement”).

th

Sumitomo and Intercept hereby mutually agree to terminate the License Agreement in its entirety with immediate effect
as  of  the  date  first  written  above  (the  “Termination  Date”).  Further,  the  parties  hereby  agree  that  the  provisions  of
Section  15.4.2  of  the  License  Agreement  shall  apply  upon  such  termination  (and,  for  clarity,  that  the  provisions  of
Section  15.4.1  shall  not  apply)  and  that,  in  accordance  therewith,  among  other  things,  all  licenses  and  sublicenses
granted  by  Intercept  to  Sumitomo  under  the  License  Agreement  shall  revert  in  full  to  Intercept  as  of  the  Termination
Date. Without limiting the foregoing, the parties hereby agree that the review period provided under Section 11.2 and
associated rights and obligations of the parties thereunder will survive for a period of twenty-eight (28) days following
the Termination Date solely with respect to that certain proposed publication tentatively titled “A phase 2, randomized,
double-blind,  placebo-controlled  multicenter  study  of  obeticholic  acid  in  Japanese  patients  with  nonalcoholic
steatohepatitis” and tentatively forthcoming in the Journal of Gastroenterology.

For the avoidance of doubt, Section 15.4.5 (and the provisions set forth therein) shall survive termination of the License
Agreement. Nothing contained in this letter shall be construed as a waiver of any rights, remedies or claims of either
party or, except to the extent expressly provided in this letter, a limitation, modification or restriction of either party’s
rights or remedies under the License Agreement and any related agreements, all of which are expressly reserved. This
letter may be executed simultaneously in one or more counterparts, each of which shall be deemed an original, but all of
which together shall constitute one and the same instrument.

 [Continues on Next Page]

 
 
 
 
 
 
 
 
 
Please confirm lntercept's agreement to the foregoing by signing where indicated below and providing us with a signed
copy of this letter for our records.

Kind regards,

Sumitomo Dainippon Pharma Co., Ltd.

/s/ Shigeyuki Nishinaka

By:
Name: Shigeyuki Nishinaka
Title: Executive Officer, Senior

Director, Global Business Development

Accepted and agreed:

Intercept Pharmaceuticals, Inc.

/s/ David Chung

By:
Name: David Chung
Title: Vice President, Business Development

                                                               
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
SUBSIDIARIES OF THE REGISTRANT

Exhibit 21.1

Name                                                                                  

          Jurisdiction of Incorporation or
Organization               

Intercept Pharma International Limited
Intercept Pharmaceuticals, LLC
Intercept Italia S.r.l.
Intercept Pharma Europe Ltd.
Intercept Pharma UK & Ireland Ltd
Intercept Pharma Ltd
Intercept Pharma Canada Inc.
Intercept Pharma Switzerland GmbH
Intercept Pharma Deutschland GmbH
Intercept Pharma France SAS
Intercept Pharma Austria GmbH
Intercept Pharma Spain, S.L.U.
Intercept Pharma Portugal Unipessoal Lda
Intercept Pharma Danmark ApS
Intercept Pharma Nederland B.V.

Republic of Ireland
Delaware
Italy
England and Wales
England and Wales
England and Wales
British Columbia
Switzerland
Germany
France
Austria
Spain
Portugal
Denmark
The Netherlands

 
 
 
 
 
 
Consent of Independent Registered Public Accounting Firm

Exhibit 23.1

The Board of Directors
Intercept Pharmaceuticals, Inc.:

We  consent  to  the  incorporation  by  reference  in  the  registration  statements  (No.  333-184810,  No.  333-188064,  No.  333-
206247, No. 333-217863, No. 333-226405, and No. 333-233248) on Form S-8 and (No. 333-194974 and No. 333-217861)
on  Form  S-3  of  Intercept  Pharmaceuticals,  Inc.  of  our  reports  dated  February  25,  2020,  with  respect  to  the  consolidated
balance sheets of Intercept Pharmaceuticals, Inc. as of December 31, 2019 and 2018, the related consolidated statements of
operations, comprehensive loss, changes in stockholders’ equity, and cash flows for each of the years in the three-year period
ended  December  31,  2019,  and  the  related  notes  and  the  effectiveness  of  internal  control  over  financial  reporting  as  of
December  31,  2019,  which  reports  appear 
the  December  31,  2019  annual  report  on  Form  10-K  of
Intercept Pharmaceuticals, Inc.

in 

/s/ KPMG LLP

New York, New York
February 25, 2020

 
 
 
I, Mark Pruzanski, M.D., certify that:

CERTIFICATION

Exhibit 31.1

1.    I have reviewed this Annual Report on Form 10-K of Intercept Pharmaceuticals, Inc.;

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  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: February 25, 2020

/s/ Mark Pruzanski, M.D.
Mark Pruzanski, M.D.
President and Chief Executive Officer
(Principal Executive Officer)

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
I, Sandip Kapadia, certify that:

CERTIFICATION

Exhibit 31.2

1.    I have reviewed this Annual Report on Form 10-K of Intercept Pharmaceuticals, Inc.;

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  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: February 25, 2020

/s/ Sandip Kapadia
Sandip Kapadia
Chief Financial Officer and Treasurer
(Principal Financial Officer)

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CERTIFICATION

Exhibit 32.1

Pursuant  to  the  requirement  set  forth  in  Rule  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),  Mark
Pruzanski,  M.D.,  President  and  Chief  Executive  Officer  of  Intercept  Pharmaceuticals,  Inc.  (the  “Company”),  and  Sandip
Kapadia, Chief Financial Officer and Treasurer 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 year ended December 31, 2019 to which this Certification is
attached as Exhibit 32.1 (the “Periodic Report”), fully complies with the requirements of Section 13(a) or Section
15(d) of the Exchange Act; and

(2) The information contained in the Periodic Report fairly presents, in all material respects, the financial condition and

results of operations of the Company.

Dated: February 25, 2020

Dated: February 25, 2020

/s/ Mark Pruzanski, M.D.
Mark Pruzanski, M.D.
President and Chief Executive Officer
(Principal Executive Officer)

/s/ Sandip Kapadia
Sandip Kapadia
Chief Financial Officer and Treasurer
(Principal Financial Officer)

A signed original of this written statement required by Rule 13a-14(b) of the Exchange Act and Section 1350 of Chapter
63 of Title 18 of the United States Code (18 U.S.C. §1350) has been provided to Intercept Pharmaceuticals, Inc. and will be
retained  by  Intercept  Pharmaceuticals,  Inc.  and  furnished  to  the  Securities  and  Exchange  Commission  or  its  staff  upon
request.

This  certification  accompanies  the  Annual  Report  on  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 Intercept Pharmaceuticals,
Inc. under the Securities Act of 1933, as amended, or the Exchange Act (whether made before or after the date of the Annual
Report on Form 10-K), irrespective of any general incorporation language contained in such filing.