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United States securities and exchange commission logo
November 8, 2022
Terry Kohler
Chief Financial Officer
Verrica Pharmaceuticals Inc.
44 West Gay Street, Suite 400
West Chester, PA 19380
Re: Verrica
Pharmaceuticals Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed March 2, 2022
File No. 001-38529
Dear Terry Kohler:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis
Research and Development Expenses, page 82
1. Given the importance of
research and development expenses to your business model and
the multiple product
candidates under development, please revise future filings to disclose
costs by product
candidate as well as by the nature of expense for each period presented.
To the extent that you
do not track expenses by product candidate, please disclose as such.
Item 9A. Controls and Procedures
Managements Report on Internal Control Over Financial Reporting, page
113
2. We note the disclosure
that you performed an assessment of your internal control over
financial reporting as
of December 31, 2021, however, you did not clearly disclose your
management s
conclusion. Please tell us and revise future filings to disclose
management's conclusion
on whether or not your internal controls were effective at the
Terry Kohler
Verrica Pharmaceuticals Inc.
November 8, 2022
Page 2
end of the period. Refer to the guidance in Item 308(a)(3) of
Regulation S-K. Please also
note that Item 308 of Regulation S-K is an annual assessment and is
not required for
interim periods.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Lynn Dicker at (202) 551-3616 or Kevin Kuhar,
Accounting Branch
Chief, at (202) 551-3662 with any questions.
FirstName LastNameTerry Kohler Sincerely,
Comapany NameVerrica Pharmaceuticals Inc.
Division of
Corporation Finance
November 8, 2022 Page 2 Office of Life
Sciences
FirstName LastName