SEC Comment Letter for Aptose Biosciences Inc. (CIK 0000882361) (APTOF) — Apr 4, 2019
Aptose Biosciences Inc. (CIK 0000882361)
Date: April 4, 2019 · CIK: 0000882361 · Accession: 0000000000-19-006538
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File numbers found in text: 001-32001
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April 3, 2019
Gregory Chow
Senior Vice President and Chief Financial Officer
Aptose Biosciences Inc.
251 Consumers Road, Suite 1105
Toronto, Ontario, Canada M2J 4R3
Re:Aptose Biosciences Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed March 12, 2019
File No. 001-32001
Dear Mr. Chow:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to the 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 the comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2018
Item 9A. Controls and Procedures, page 44
1.Please revise to include the disclosures required by Item 307 of Regulation S-K. Please
also tell us how the omission of these required disclosures impacts your conclusion with
respect to the effectiveness of disclosure controls and procedures as of December 31,
2018.
FirstName LastNameGregory Chow
Comapany NameAptose Biosciences Inc.
April 3, 2019 Page 2
FirstName LastName
Gregory Chow
Aptose Biosciences Inc.
April 3, 2019
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 Mary Mast at (202) 551-3613 or Angela Connell at (202) 551-
3426 with any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance