SEC Comment Letter 0000000000-24-007602 to Oruka Therapeutics, Inc. (ORKA)
Oruka Therapeutics, Inc.
Date: July 3, 2024 · CIK: 0000907654 · Accession: 0000000000-24-007602
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-279387
Letter
July 3, 2024 Thomas A. Keuer President and Chief Operating Officer ARCA biopharma, Inc. 10170 Church Ranch Way, Suite 100 Westminster, CO 80021 Re:ARCA biopharma, Inc. Amendment No. 1 to Registration Statement on Form S-4 Filed June 18, 2024 File No. 333-279387 Dear Thomas A. Keuer: We have reviewed your amended registration statement and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a 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 registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our June 11, 2024 letter. Amendment No. 1 to Registration Statement on Form S-4 Oruka's Pipeline, page 214 1.We note your response to prior comment 11 and your revised disclosure on page 214. We note that the pipeline table does not provide an indication for ORKA-003 or "Combinations." Given the status of development and limited disclosure regarding the programs for ORKA-003 and "Combinations," it does not appear appropriate to highlight these programs in your pipeline table. If these programs are material to your business to warrant inclusion in your pipeline table, please expand your disclosure in your Business section to provide a more fulsome discussion of these programs, including descriptions of preclinical studies or other development activities conducted. Alternatively, please remove these programs from the pipeline table or advise. 2.Please revise your pipeline table to include columns of equal width for each of Phase 1, Phase 2 and Phase 3 of clinical testing.
July 3, 2024 Page 2 Please contact Jenn Do at 202-551-3743 or Kevin Kuhar at 202-551-3662 if you have questions regarding comments on the financial statements and related matters. Please contact Tamika Sheppard at 202-551-8346 or Joshua Gorsky at 202-551-7836 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc:Brent D. Fassett
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July 3, 2024
Thomas A. Keuer
President and Chief Operating Officer
ARCA biopharma, Inc.
10170 Church Ranch Way, Suite 100
Westminster, CO 80021
Re:ARCA biopharma, Inc.
Amendment No. 1 to Registration Statement on Form S-4
Filed June 18, 2024
File No. 333-279387
Dear Thomas A. Keuer:
We have reviewed your amended registration statement and have the following
comments.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a 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 registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our June 11, 2024 letter.
Amendment No. 1 to Registration Statement on Form S-4
Oruka's Pipeline, page 214
1.We note your response to prior comment 11 and your revised disclosure on page 214. We
note that the pipeline table does not provide an indication for ORKA-003 or
"Combinations." Given the status of development and limited disclosure regarding the
programs for ORKA-003 and "Combinations," it does not appear appropriate to highlight
these programs in your pipeline table. If these programs are material to your business to
warrant inclusion in your pipeline table, please expand your disclosure in your Business
section to provide a more fulsome discussion of these programs, including descriptions of
preclinical studies or other development activities conducted. Alternatively, please
remove these programs from the pipeline table or advise.
2.Please revise your pipeline table to include columns of equal width for each of Phase 1,
Phase 2 and Phase 3 of clinical testing.
July 3, 2024
Page 2
Please contact Jenn Do at 202-551-3743 or Kevin Kuhar at 202-551-3662 if you have
questions regarding comments on the financial statements and related matters. Please contact
Tamika Sheppard at 202-551-8346 or Joshua Gorsky at 202-551-7836 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Brent D. Fassett