SEC Comment Letter for HERON THERAPEUTICS, (HRTX) — Jul 1, 2011
HERON THERAPEUTICS, INC. /DE/ (HRTX) (CIK 0000818033)
Date: July 1, 2011 · CIK: 0000818033 · Accession: 0000000000-11-040245
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-174288
Referenced dates: June 13, 2011
Letter
July 1, 2011 Via E-mail John B. Whelan Chief Executive Officer and Chief Financial Officer AP Pharma, Inc. 123 Saginaw Drive Redwood City, California 94063 Re: AP Pharma, Inc. Registration Statement on Form S-1 Filed May 18, 2011 File No. 333-174288
Dear Mr. Whelan:
We have reviewed your response letter dated June 13, 2011 and Amendment No. 1 to your Form S-1 and have the following comme nt. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amendi ng your registration statement and providing the requested information. Where you do not be lieve our comment applies 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 re gistration statement and the information you provide in response to this comment, we may have additional comments.
1. We note that you have not included the disc losure provided in response to our prior comment 9 regarding the Company’s financia l ability to make all payments on the overlying securities. Please include this disclosure in your next amendment to the registration statement.
You may contact Johnny Ghar ib at (202) 551-3170, Daniel Greenspan at (202) 551- 3623 or me at (202) 551- 3715 with any questions.
Sincerely,
/s/ Daniel Greenspan for Jeffrey Riedler
Assistant Director
cc: Ryan Murr, Esq. Ropes & Gray LLP
Three Embarcadero Center
San Francisco, CA 9411
Show Raw Text
July 1, 2011 Via E-mail John B. Whelan Chief Executive Officer and Chief Financial Officer AP Pharma, Inc. 123 Saginaw Drive Redwood City, California 94063 Re: AP Pharma, Inc. Registration Statement on Form S-1 Filed May 18, 2011 File No. 333-174288 Dear Mr. Whelan: We have reviewed your response letter dated June 13, 2011 and Amendment No. 1 to your Form S-1 and have the following comme nt. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amendi ng your registration statement and providing the requested information. Where you do not be lieve our comment applies 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 re gistration statement and the information you provide in response to this comment, we may have additional comments. 1. We note that you have not included the disc losure provided in response to our prior comment 9 regarding the Company’s financia l ability to make all payments on the overlying securities. Please include this disclosure in your next amendment to the registration statement. You may contact Johnny Ghar ib at (202) 551-3170, Daniel Greenspan at (202) 551- 3623 or me at (202) 551- 3715 with any questions. Sincerely, /s/ Daniel Greenspan for Jeffrey Riedler Assistant Director cc: Ryan Murr, Esq. Ropes & Gray LLP Three Embarcadero Center San Francisco, CA 9411