SEC Comment Letter for KAZIA THERAPEUTICS LTD (KZIA) (CIK 0001075880) (KZIA) — Apr 29, 2010
KAZIA THERAPEUTICS LTD (KZIA) (CIK 0001075880)
Date: April 29, 2010 · CIK: 0001075880 · Accession: 0000000000-10-023495
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-29962
Letter
Via Facsimile and U.S. Mail Mail Stop 4720 April 29, 2010 David Seaton Acting Chief Executive Officer and Chief Financial Officer Novogen Limited 140 Wicks Road North Ryde, New South Wales 2113 Australia Re: Novogen Limited Form 20-F for the Fiscal Year Ended June 30, 2009 Filed December 15, 2009 File Number: 000-29962
Dear Mr. Seaton: We have reviewed your April 15, 2010 res ponse to our April 8, 2010 letter and have the following comments. We have considered your request to include the proposed revised disclosures in your June 30, 2010 Form 20-F; however, we reque st that you amend the June 30, 2009 Form 20-F to comply with the below comments because that filing does not satisfy the requirement to incl ude an unreserved and explicit statement of compliance with IFRS as issued by the IASB.
Income Statements, page 81
1. Please refer to your response to comme nt one and your proposed revised disclosures. Please revise your disclosure to state that cost of sales includes only costs associated with the sa le of goods and, as indicat ed in your response, the reason the percentage decrease in cost of sales is higher than the percentage decrease in revenues for 2007 compared to 2008. Notes to the Financial Statements
Note 1. Summary of Significant Accounting Policies Statement of Compliance, page 85 2. Please refer to your response to comment two. Please revise the wording since you have not satisfied the requirement of Item 17(c) of Form 20-F to include an unreserved and explicit statement of co mpliance with IFRS as issued by the
David Seaton Novogen Limited April 29, 2010 Page 2 IASB. A US GAAP reconciliati on is required if this stat ement is not included in the notes to the financial statements. In addition, please remove the disclosure on page 3 regarding compliance with AIFRS a nd revise the disclosu re to state that the financial statements do comply w ith IFRS as issued by the IASB.
* * * *
Please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a re sponse. Please furnish a cover letter with your amendment that keys your response to our comments and pr ovides any requested information. Detailed cover lette rs greatly facilitate our revi ew. Please furnish the letter on EDGAR under the form type label CORRESP . Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
You may contact Vanessa Robe rtson, Staff Accountant, at (202) 551-3649 or Lisa Vanjoske, Assistant Chief Accountant, at (202) 551-3614 if you have any questions regarding the comments. In th is regard, do not hesitate to contact me, at (202) 551-3679.
S i n c e r e l y , J i m B . R o s e n b e r g Senior Assistant Chief Accountant
Show Raw Text
Via Facsimile and U.S. Mail
Mail Stop 4720 April 29, 2010 David Seaton Acting Chief Executive Officer and Chief Financial Officer Novogen Limited 140 Wicks Road North Ryde, New South Wales 2113 Australia
Re: Novogen Limited
Form 20-F for the Fiscal Year Ended June 30, 2009
Filed December 15, 2009
File Number: 000-29962
Dear Mr. Seaton:
We have reviewed your April 15, 2010 res ponse to our April 8, 2010 letter and have
the following comments. We have considered your request to include the proposed revised
disclosures in your June 30, 2010 Form 20-F; however, we reque st that you amend the June
30, 2009 Form 20-F to comply with the below comments because that filing does not satisfy the requirement to incl ude an unreserved and explicit statement of compliance with
IFRS as issued by the IASB.
Income Statements, page 81
1. Please refer to your response to comme nt one and your proposed revised
disclosures. Please revise your disclosure to state that cost of sales includes only
costs associated with the sa le of goods and, as indicat ed in your response, the
reason the percentage decrease in cost of sales is higher than the percentage
decrease in revenues for 2007 compared to 2008.
Notes to the Financial Statements
Note 1. Summary of Significant Accounting Policies
Statement of Compliance, page 85
2. Please refer to your response to comment two. Please revise the wording since
you have not satisfied the requirement of Item 17(c) of Form 20-F to include an
unreserved and explicit statement of co mpliance with IFRS as issued by the
David Seaton
Novogen Limited April 29, 2010 Page 2
IASB. A US GAAP reconciliati on is required if this stat ement is not included in
the notes to the financial statements. In addition, please remove the disclosure on
page 3 regarding compliance with AIFRS a nd revise the disclosu re to state that
the financial statements do comply w ith IFRS as issued by the IASB.
* * * *
Please amend your filing and respond to these comments within 10 business days
or tell us when you will provide us with a re sponse. Please furnish a cover letter with
your amendment that keys your response to our comments and pr ovides any requested
information. Detailed cover lette rs greatly facilitate our revi ew. Please furnish the letter
on EDGAR under the form type label CORRESP . Please understand that we may have
additional comments after reviewing your amendment and responses to our comments.
You may contact Vanessa Robe rtson, Staff Accountant, at (202) 551-3649 or Lisa
Vanjoske, Assistant Chief Accountant, at (202) 551-3614 if you have any questions
regarding the comments. In th is regard, do not hesitate to contact me, at (202) 551-3679.
S i n c e r e l y , J i m B . R o s e n b e r g
Senior Assistant Chief Accountant