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SEC Comment Letter for CASSAVA SCIENCES INC (FLNA) (CIK 0001069530) (FLNA) — Dec 14, 2009

CASSAVA SCIENCES INC (FLNA) (CIK 0001069530)
Date: Dec. 14, 2009 · CIK: 0001069530 · Accession: 0000000000-09-070488

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File numbers found in text: 000-29959

Date
December 14, 2009
Author
Jeffrey P. Riedler
Form
UPLOAD
Company
CASSAVA SCIENCES INC (FLNA) (CIK 0001069530)

Letter

Via Facsimile and U.S. Mail Mail Stop 4720 December 14, 2009 Peter S. Roddy Vice President and Chief Financial Officer 2211 Bridgepointe Parkway Suite 500 San Mateo, CA

Re: Pain Therapeutics, Inc. Form 10-K for the Year Ended December 30, 2009 Filed February 13, 2009 File Number: 000-29959

Dear Mr. Roddy:

We have reviewed your response dated December 4, 2009 to our November 9, 2009 letter and have the following comments. In our comments, we may ask you to provide us with information to better unde rstand your disclosure. Where a comment requests you to revise disclosure, the info rmation you provide should show us what the revised disclosure will look like. Please identify the annual or quarterly filing, as applicable, in which you intend to first incl ude it. If you do not believe that revised disclosure is necessary, e xplain the reason in your res ponse. After reviewing the information provided, we may raise additiona l comments and/or request that you amend the above filings.

Form 10-K Intellectual Property, page 5

1. We note your response to comment 1. Pl ease confirm that you intend to provide this information in your “I ntellectual Property” disc ussion in your next 10-K. Schedule 14A

Compensation Discussion and Analysis, page 11

2. To the extent you continue to state th at you use purchased surveys and / or internally generated surveys for determ ining compensation, please confirm that you will identify the purchased surveys a nd identify the companies included in

Peter S. Roddy Pain Therapeutics, Inc. December 14, 2009 Page 2 your internally generated surveys and e xplain how you used the data generated from these surveys.

* * * *

Please provide us the information request ed within 10 busine ss days or tell us when you will provide us with a response. Pl ease furnish a cover le tter with your response that keys your response to our comment. De tailed cover letters gr eatly facilitate our review. Please furnish your letter on EDGAR under the form type label CORRESP.

Please contact Suzanne Hayes Legal Bran ch Chief, at (202) 551-3675 or me at (202) 551-3715 with any questions. S i n c e r e l y , J e f f r e y P . R i e d l e r A s s i s t a n t D i r e c t o r

Show Raw Text
Via Facsimile and U.S. Mail
Mail Stop 4720

         December 14, 2009

Peter S. Roddy
Vice President and Chief Financial Officer
2211 Bridgepointe Parkway
Suite 500
San Mateo, CA

Re:   Pain Therapeutics, Inc.
 Form 10-K for the Year Ended December 30, 2009
 Filed February 13, 2009
 File Number:  000-29959

Dear Mr. Roddy:

We have reviewed your response dated December 4, 2009 to our November 9,
2009 letter and have the following comments.   In our comments, we may ask you to
provide us with information to better unde rstand your disclosure.  Where a comment
requests you to revise disclosure, the info rmation you provide should show us what the
revised disclosure will look like.  Please  identify the annual or  quarterly filing, as
applicable, in which you intend to first incl ude it.  If you do not believe that revised
disclosure is necessary, e xplain the reason in your res ponse.  After reviewing the
information provided, we may raise additiona l comments and/or request that you amend
the above filings.

Form 10-K
 Intellectual Property, page 5

1. We note your response to comment 1.  Pl ease confirm that you intend to provide
this information in your “I ntellectual Property” disc ussion in your next 10-K.
 Schedule 14A

 Compensation Discussion and Analysis, page 11

2. To the extent you continue to state th at you use purchased surveys and / or
internally generated surveys for determ ining compensation, please confirm that
you will identify the purchased surveys a nd identify the companies included in

Peter S. Roddy
Pain Therapeutics, Inc. December 14, 2009 Page 2
your internally generated surveys and e xplain how you used the data generated
from these surveys.

* * * *

 Please provide us the information request ed within 10 busine ss days or tell us
when you will provide us with a response.  Pl ease furnish a cover le tter with your response
that keys your response to our comment.  De tailed cover letters gr eatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.

Please contact Suzanne Hayes Legal Bran ch Chief, at (202) 551-3675 or me at
(202) 551-3715 with any questions.          S i n c e r e l y ,             J e f f r e y  P .  R i e d l e r          A s s i s t a n t  D i r e c t o r