SEC Comment Letter for Protalix BioTherapeutics, Inc. (PLX) (CIK 0001006281) (PLX) — Jan 17, 2007
Protalix BioTherapeutics, Inc. (PLX) (CIK 0001006281)
Date: Jan. 17, 2007 · CIK: 0001006281 · Accession: 0000000000-07-002451
AI Filing Summary & Sentiment
Reasoning
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-0303 DIVISION OF CORPORATION FINANCE January 12, 2007 Via Facsimile (212.336.4263) and U.S. Mail Joshua Goldstein, Esq. Morrison & Foerster LLP 1290 Avenue of the Americas New York, NY 10104
RE: Orthodontix, Inc. Schedule 14F-1 filed on December 18, 2006 File No. 005-50118
Dear Mr. Goldstein:
We have reviewed your filing and have th e following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why a comment is inapplicable or a revision is unnecessary. Please be as detailed as necessa ry in your explanation. In some of our comments, we may ask you to provide us with supplemental informati on so we may better understand your disclosure. After reviewing this information, we ma y or may not raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requir ements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel fr ee to call us at the telephone numbers listed at th e end of this letter.
The Merger, page 2 1. We note your response to prior comment 1. Pl ease provide your analysis as to why you believe Orthodontix should not be considered a party to the merger, particularly in light of the fact that Orthodontix is a party to the Merger Agreement and Plan of Reorganization (Exhibit 10.10 to the Form 8-K filed January 8, 2007) and the fact that Orthodontix is also providing the merger consideration in the form of Orthodontix common stock.
Please direct any questions to me at ( 202) 551-3636 or, in may absence, to Pam Carmody, Special Counsel, at (202) 551-3265. You may also contact me via facsimile at (202)
Joshua Goldstein, Esq. Morrison & Foerster LLP January 12, 2007 Page 2
772-9203. Please send all correspo ndence to us at the following ZIP code: 20549-3628.
Very truly yours,
Adé K. Heyliger
Attorney-Advisor
Office of Mergers and Acquisitions
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0303
DIVISION OF
CORPORATION FINANCE
January 12, 2007
Via Facsimile (212.336.4263) and U.S. Mail
Joshua Goldstein, Esq.
Morrison & Foerster LLP
1290 Avenue of the Americas
New York, NY 10104
RE: Orthodontix, Inc.
Schedule 14F-1 filed on December 18, 2006
File No. 005-50118
Dear Mr. Goldstein:
We have reviewed your filing and have th e following comments. Where indicated, we
think you should revise your document in response to these comments. If you disagree, we will
consider your explanation as to why a comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessa ry in your explanation. In some of our comments, we may ask
you to provide us with supplemental informati on so we may better understand your disclosure.
After reviewing this information, we ma y or may not raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filing. We look forward to working with you in these respects. We welcome any questions
you may have about our comments or any other aspect of our review. Feel fr ee to call us at the
telephone numbers listed at th e end of this letter.
The Merger, page 2
1. We note your response to prior comment 1. Pl ease provide your analysis as to why you
believe Orthodontix should not be considered a party to the merger, particularly in light
of the fact that Orthodontix is a party to the Merger Agreement and Plan of
Reorganization (Exhibit 10.10 to the Form 8-K filed January 8, 2007) and the fact that
Orthodontix is also providing the merger consideration in the form of Orthodontix
common stock.
Please direct any questions to me at ( 202) 551-3636 or, in may absence, to Pam
Carmody, Special Counsel, at (202) 551-3265. You may also contact me via facsimile at (202)
Joshua Goldstein, Esq.
Morrison & Foerster LLP
January 12, 2007 Page 2
772-9203. Please send all correspo ndence to us at the following ZIP code: 20549-3628.
Very truly yours,
Adé K. Heyliger
Attorney-Advisor
Office of Mergers and Acquisitions