December 20, 2019
Pat Cotroneo
Senior Vice President and Chief Financial Officer
FIBROGEN INC
409 Illinois Street
San Francisco, CA 94158
Re: FIBROGEN INC.
Form 10-K for the Year Ended December 31, 2018
Filed February 27, 2019
File No. 001-36740
Dear Mr. Cotroneo:
We have reviewed your December 13, 2019 response to our comment letter
and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to the comment 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
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in
our December 3, 2019 letter.
Form 10-K for the Year Ended December 31, 2018
Item 1. Business
Pamrevlumab For The Treatment of Fibrosis and Cancer
Clinical Development of Pamrevlumab, page 28
1. We note your response to prior comment 1; however, we do not agree that
the identity of a
serious adverse event (SAE) determined to be possibly related to
Pamrevlumab is
immaterial to investors. Accordingly, please provide us proposed
disclosure for use in
future filings that identifies all such events. With reference to the
third paragraph on page
33 of your Form 10-K, please also tell us whether any of the SAEs
observed in the
pamrevlumab arm of Study 069 were determined to be related to, or
possibly related to,
Pamrevlumab. If so, please include such information in your proposed
disclosure.
Pat Cotroneo
FIBROGEN INC
December 20, 2019
Page 2
You may contact Sasha Parikh at 202-551-3627 or Rolf Sundwall at
202-551-3105 if
you have questions.
FirstName LastNamePat Cotroneo Sincerely,
Comapany NameFIBROGEN INC
Division of Corporation
Finance
December 20, 2019 Page 2 Office of Life Sciences
FirstName LastName