SEC Comment Letter for SOLIGENIX, INC. (SNGX) (CIK 0000812796) (SNGX) — Aug 24, 2010
SOLIGENIX, INC. (SNGX) (CIK 0000812796)
Date: Aug. 24, 2010 · CIK: 0000812796 · Accession: 0000000000-10-048566
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File numbers found in text: 000-16929
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August 24, 2010
Christopher J. Schaber, Ph.D.
President and Chief Executive Officer
(Principal Executive O fficer)
Soligenix, Inc.
29 Emmons Drive
Suite C -10
Princeton, NJ
Re: Soligenix, Inc.
Form 8-K
Filed August 20, 2010
File No. 000-16929
Dear Mr. Schaber :
We have reviewed your filing an d 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will pr ovide the requested
response. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.
Item 4.01. Changes in Regis trant’s Certifying Accountant.
1. Please amend your filing to specify whether, during your p ast two fiscal years through
August 16, 2010 , you consulted Eisner LLP regarding any of the matters outlined in Item
304(a)(2) of Regulation S -K. The current disclosure is silent with respect to the year
ended December 31, 2008.
2. Upon amending your filing, please include, as Exhibit 16, a letter from your former
accountants, Amper, Politziner & Mattia, LLP , as required by Item 304(a)(3) of
Regulation S -K. Please ensure that your former accountants date their letter.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its management are
Christopher J. Schaber, Ph.D.
Soligenix, Inc.
August 24, 2010
Page 2
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.
In responding to our comments, please provide a written statement from the company
acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.
If you have any questions, please do not hesitate to call me at (202) 551 -3658.
Sincerely,
Tabatha Akins
Staff Accountant