SEC Comment Letter for Theriva Biologics, Inc. (TOVX) (CIK 0000894158) (TOVX) — Jan 31, 2011
Theriva Biologics, Inc. (TOVX) (CIK 0000894158)
Date: Jan. 31, 2011 · CIK: 0000894158 · Accession: 0000000000-11-006099
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January 31, 2011 Mr. James S. Kuo, M.D., M.B.A President and Chief Executive Officer Adeona Pharmaceuticals, Inc. 3930 Varsity Drive Ann Arbor, MI 48108 Re: Adeona Pharmaceuticals, Inc. Form 10- K for the Year Ended December 31, 2009 Form 10- Q for the Interim Period Ended June 30, 2010 File No. 001 -12584 Dear Mr. Kuo : We have reviewed your December 22, 2010 response to our December 15, 2010 letter and have the following comment. Please respond to this letter 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 the comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comment . After reviewing the information provide d, we may raise additional comments and/or request that you amend your filing . Form 10- Q for the Interim Period Ended June 30, 2010 Note 2. Basis of Presentation Revenue Recognition, page 7 1. We acknowledge your response to comment 8. Plea se revise your draft disclosures to include how revenue will be recognized to the extent contracts have continuing obligations or additional deliverables . Additionally, revise your draft disclosure to include your revenue recognition policy for royalty pa yments, including how royalty revenue will be calculated and recognized . Mr. James S. Kuo, M.D., M.B.A Adeona Pharmaceuticals, Inc. January 31, 2011 Page 2 You may contact Christine Allen, Staff Accountant, at (202) 551- 3652 or Melissa N. Rocha, Accounting Branch Chief at (202) 551 -3854 if y ou have any questions regarding the comment. In this regard, do not hesitate to contact me at (202) 551- 3679. Sincerely, Jim Rosenberg Senior Assistant Chief Accountant