SEC Comment Letter 0000000000-25-002216 to CHAMPIONS ONCOLOGY, INC. (CSBR) (CIK 0000771856) (CSBR)
CHAMPIONS ONCOLOGY, INC. (CSBR) (CIK 0000771856)
Date: Feb. 26, 2025 · CIK: 0000771856 · Accession: 0000000000-25-002216
AI Filing Summary & Sentiment
File numbers found in text: 001-11504
Letter
February 26, 2025 David Miller Chief Financial Officer Champions Oncology, Inc. 1 University Plaza Suite 307 Hackensack, New Jersey 07601 Re:Champions Oncology, Inc. Form 10-K for the Fiscal Year Ended April 30, 2024 Form 8-K dated December 11, 2024 File No. 001-11504 Dear David Miller: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for the Fiscal Year Ended April 30, 2024 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations - Oncology Services Revenue, page 18 1.We note your disclosure regarding the decrease in oncology services revenue for the year ended April 30, 2024 compared to the prior annual period. Your explanation for this decrease uses terminology and metrics that are not otherwise defined, such as net bookings and available convertible revenue. Please revise your future filings to define such terminology and clearly correlate these metrics to significant revenue fluctuations. Please also disaggregate your major sources of revenue for each period presented.
February 26, 2025 Page 2 Research and Development, page 18 2.Please revise your disclosure in future filings to quantify the significant components of your research and development expenses for each period presented. Form 8-K dated December 11, 2024 Exhibit 99.1 Non-GAAP Financial Information, page 4 3.We note you present non-GAAP financial measures of Non-GAAP net income (loss), Non-GAAP net income (loss) per share, and Adjusted EBITDA. We further note your various references to Adjusted EBITDA on pages one and two without reference to the most directly comparable GAAP measure. Please revise your future disclosures to comply with Item 10(e)(1)(i) of Regulation S-K. Specifically address the following: •Revise to present your GAAP measures with equal or greater prominence than your non-GAAP measures; and •Provide a reconciliation of Adjusted EBITDA to the most directly comparable financial measure calculated in accordance with GAAP. 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. Please contact Bonnie Baynes at 202-551-4924 or Angela Connell at 202-551-3426 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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February 26, 2025
David Miller
Chief Financial Officer
Champions Oncology, Inc.
1 University Plaza
Suite 307
Hackensack, New Jersey 07601
Re:Champions Oncology, Inc.
Form 10-K for the Fiscal Year Ended April 30, 2024
Form 8-K dated December 11, 2024
File No. 001-11504
Dear David Miller:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended April 30, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations - Oncology Services Revenue, page 18
1.We note your disclosure regarding the decrease in oncology services revenue for the
year ended April 30, 2024 compared to the prior annual period. Your explanation for
this decrease uses terminology and metrics that are not otherwise defined, such as net
bookings and available convertible revenue. Please revise your future filings to define
such terminology and clearly correlate these metrics to significant revenue
fluctuations. Please also disaggregate your major sources of revenue for each period
presented.
February 26, 2025
Page 2
Research and Development, page 18
2.Please revise your disclosure in future filings to quantify the significant components
of your research and development expenses for each period presented.
Form 8-K dated December 11, 2024
Exhibit 99.1
Non-GAAP Financial Information, page 4
3.We note you present non-GAAP financial measures of Non-GAAP net income (loss),
Non-GAAP net income (loss) per share, and Adjusted EBITDA. We further note
your various references to Adjusted EBITDA on pages one and two without reference
to the most directly comparable GAAP measure. Please revise your future disclosures
to comply with Item 10(e)(1)(i) of Regulation S-K. Specifically address the
following:
•Revise to present your GAAP measures with equal or greater prominence than
your non-GAAP measures; and
•Provide a reconciliation of Adjusted EBITDA to the most directly comparable
financial measure calculated in accordance with GAAP.
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.
Please contact Bonnie Baynes at 202-551-4924 or Angela Connell at 202-551-3426
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences