In what presumably is the first of a flood of non-comparable, Reg. S-K Item 402(u) pay ratio disclosures, Cooley reported on Invivo Therapeutics Holdings Corp.'s (Nasdaq: NVIV) Form S-1 disclosure (page 80), which was based on: (i) 16 employees (in total, but for the CEO); (ii) a consistently applied compensation measure of annualized base salary (only); (iii) two potential median employees, with the selected median employee having an annual total compensation of $384,528; (iv) two CEOs (one selected for purposes of ratio calculation); and (v) CEO annual compensation of $2,471,333. The estimated ratio based on these factors was 6.4 to 1.
Notably, the brief disclosure closes with this unquestionably sound advice:
Given the different methodologies that various public companies will use to determine an estimate of their pay ratio, the estimated ratio reported above should not be used as a basis for comparison between companies.
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