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SEC Comment Letter 0000000000-23-004594 to Imunon, Inc. (IMNN)

Imunon, Inc.
Date: May 3, 2023 · CIK: 0000749647 · Accession: 0000000000-23-004594

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File numbers found in text: 001-15911

Date
May 3, 2023
Author
Vanessa Robertson
Form
UPLOAD
Company
Imunon, Inc.

Letter

United States securities and exchange commission logo May 3, 2023 Jeffrey Church Chief Financial Officer Imunon, Inc. 997 Lenox Drive, Suite 100 Lawrenceville, NJ 08648 Re:Imunon, Inc. Form 10-K for the fiscal year ended December 31, 2022 Filed March 30, 2023 File No. 001-15911 Dear Jeffrey Church: We have limited our review of your filing to the financial statements and related disclosures 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 this 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 this comment, we may have additional comments. Form 10-K for the fiscal year ended December 31, 2022 Management's Discussion and Analysis of Financial Conditions and Results of Operations Results of Operations Research and Development Expenses, page 60 1.Please revise your future filings to break out the development costs incurred during each period presented related to IMNN-001 and PLACCINE separately. If you do not track your research and development costs by program or platform, please disclose that fact and explain why you do not maintain and evaluate research and development costs by project or program. For amounts that are not tracked by project or program, provide other quantitative or qualitative disclosure that provides more transparency as to the type of research and development expenses incurred (i.e. by nature or type of expense) which should reconcile to total research and development expense on the Statements of Operations.

FirstName LastNameJeffrey Church Comapany NameImunon, Inc. May 3, 2023 Page 2 FirstName LastName Jeffrey Church Imunon, Inc. May 3, 2023 Page 2 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 Vanessa Robertson at 202-551-3649 or Kevin Vaughn at 202-551-3494 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences

Show Raw Text
United States securities and exchange commission logo
May 3, 2023
Jeffrey Church
Chief Financial Officer
Imunon, Inc.
997 Lenox Drive, Suite 100
Lawrenceville, NJ 08648
Re:Imunon, Inc.
Form 10-K for the fiscal year ended December 31, 2022
Filed March 30, 2023
File No. 001-15911
Dear Jeffrey Church:
            We have limited our review of your filing to the financial statements and related
disclosures 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 this 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 this comment, we may have additional comments.
Form 10-K for the fiscal year ended December 31, 2022
Management's Discussion and Analysis of Financial Conditions and Results of Operations
Results of Operations
Research and Development Expenses, page 60
1.Please revise your future filings to break out the development costs incurred during each
period presented related to IMNN-001 and PLACCINE separately. If you do not track
your research and development costs by program or platform, please disclose that fact and
explain why you do not maintain and evaluate research and development costs by project
or program. For amounts that are not tracked by project or program, provide other
quantitative or qualitative disclosure that provides more transparency as to the type of
research and development expenses incurred (i.e. by nature or type of expense) which
should reconcile to total research and development expense on the Statements of
Operations.

 FirstName LastNameJeffrey Church
 Comapany NameImunon, Inc.
 May 3, 2023 Page 2
 FirstName LastName
Jeffrey Church
Imunon, Inc.
May 3, 2023
Page 2
            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 Vanessa Robertson at 202-551-3649 or Kevin Vaughn at 202-551-3494
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences