SEC Comment Letter for Aptose Biosciences Inc. (CIK 0000882361) (APTOF) — Jan 30, 2013
Aptose Biosciences Inc. (CIK 0000882361)
Date: Jan. 30, 2013 · CIK: 0000882361 · Accession: 0000000000-13-005285
AI Filing Summary & Sentiment
Letter
January 29, 2013 Via E -mail Elizabeth Williams Director of Finance Lorus Therapeutics Inc. 2 Meridian Road Toronto, Ontario M9W 4Z7 Canada
Re: Lorus Therapeutics Inc. Form 20-F Filed September 28, 2012 File No. 001 -32001
Dear Ms. Williams :
We have reviewed your filing an d have the following comment.
Please respond to this let ter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances , please tell us why in your response.
After reviewing the information you provide in response to our comment, we may have additional comments.
Item 4.B Business Overview, page 18 License Agreements, page 21
1. Please provide proposed draft disclosure for inclusion in future filings that expands your disclosure with respect to your license agr eement with Genentech to disclose the amounts paid to date, aggregate potential milestone payments and a percentage point range (not to exceed ten percentage points) within which the applicable royalty rate falls. Please also disclose the term of the agre ement and any termination provisions.
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 Excha nge Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Eliza beth Williams Lorus Therapeutics Inc. January 29, 2013 Page 2
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 Commissi on 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.
Please contact Karen Ubell, Staff Attorney, at (202) 551 -3873, Jennifer Riegel, Special Counsel, at (202) 551 -3575 or me at (202) 551 -3715 with any questions.
Sincerely,
/s/ Jennifer Riegel for
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January 29, 2013 Via E -mail Elizabeth Williams Director of Finance Lorus Therapeutics Inc. 2 Meridian Road Toronto, Ontario M9W 4Z7 Canada Re: Lorus Therapeutics Inc. Form 20-F Filed September 28, 2012 File No. 001 -32001 Dear Ms. Williams : We have reviewed your filing an d have the following comment. Please respond to this let ter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances , please tell us why in your response. After reviewing the information you provide in response to our comment, we may have additional comments. Item 4.B Business Overview, page 18 License Agreements, page 21 1. Please provide proposed draft disclosure for inclusion in future filings that expands your disclosure with respect to your license agr eement with Genentech to disclose the amounts paid to date, aggregate potential milestone payments and a percentage point range (not to exceed ten percentage points) within which the applicable royalty rate falls. Please also disclose the term of the agre ement and any termination provisions. 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 Excha nge Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Eliza beth Williams Lorus Therapeutics Inc. January 29, 2013 Page 2 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 Commissi on 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. Please contact Karen Ubell, Staff Attorney, at (202) 551 -3873, Jennifer Riegel, Special Counsel, at (202) 551 -3575 or me at (202) 551 -3715 with any questions. Sincerely, /s/ Jennifer Riegel for Jeffrey P. R iedler Assistant Director cc: Via E -mail Dan Miller Dorsey & Whitney LLP