SEC Comment Letter for KAZIA THERAPEUTICS LTD (KZIA) (CIK 0001075880) (KZIA) — May 23, 2013
KAZIA THERAPEUTICS LTD (KZIA) (CIK 0001075880)
Date: May 23, 2013 · CIK: 0001075880 · Accession: 0000000000-13-028500
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-29962
Letter
May 23, 201 3 Via E -mail Graham Kelly Chief Executive Officer Novogen Limited 1-7 Waterloo Road, Level 1 North Ryde, New South Wales 2113 Australia
Re: Novogen Limited Form 20-F for the Fiscal Year Ended June 30, 201 2 Filed Octob er 29, 201 2 File No. 000-29962
Dear Dr. Kelly :
We have reviewed your April 26 , 201 3 response to our March 29, 201 3 letter and have the following comment .
Please respond to this letter within 10 business days by amending your filing or by advising us when you will provide the requested response. Please furnish us a letter on EDGAR under the form type label CORRESP that key s your response to our comment.
After reviewin g any amendment to your filing and information you provide in respon se to this comment, we may have additional comments.
Report of Independent Registered Public Accounting Firm , page 75
1. We have evaluated your April 26, 2013 response and reconsidered your previous responses. We are unable to agree with your assertion that the report of Grant Thornton is appropriate. Because it is necessary to conduct an audit in order to be able to express an opinion, there must be consistency between the description of the periods audited by the independent auditor and the periods co vered by the independent auditor’s opinion. In your circumstances, such consistency d oes not exist. Grant Thornton’ s report indicates that they audited one year (the year ended June 30, 2012), but opined on three years (i.e. the three years ended June 3 0, 2012). In these circumstances, we believe that you must obtain a revised report from Grant Thornton that rectifies this inconsistency and, with their consent, include the revised report in an amendment of Novogen’s Form 20 -F for the year ended June 30 , 2012 that removes the opinion currently included in Novogen’s Form 20 -F.
Graham Kelly Novogen Limited May 23, 201 3 Page 2
You may contact Vanessa Robertson, Staff Accountant, at (202) 551 -3649 or Lisa Vanjoske, Assistant Chief Accountant, at (202) 551 -3614 if you have any questions regarding the co mment. In this regard, do not hesitate to contact me at (202) 551 -3679 .
Sincerely,
/s/ Jim B. Rosenberg
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May 23, 201 3 Via E -mail Graham Kelly Chief Executive Officer Novogen Limited 1-7 Waterloo Road, Level 1 North Ryde, New South Wales 2113 Australia Re: Novogen Limited Form 20-F for the Fiscal Year Ended June 30, 201 2 Filed Octob er 29, 201 2 File No. 000-29962 Dear Dr. Kelly : We have reviewed your April 26 , 201 3 response to our March 29, 201 3 letter and have the following comment . Please respond to this letter within 10 business days by amending your filing or by advising us when you will provide the requested response. Please furnish us a letter on EDGAR under the form type label CORRESP that key s your response to our comment. After reviewin g any amendment to your filing and information you provide in respon se to this comment, we may have additional comments. Report of Independent Registered Public Accounting Firm , page 75 1. We have evaluated your April 26, 2013 response and reconsidered your previous responses. We are unable to agree with your assertion that the report of Grant Thornton is appropriate. Because it is necessary to conduct an audit in order to be able to express an opinion, there must be consistency between the description of the periods audited by the independent auditor and the periods co vered by the independent auditor’s opinion. In your circumstances, such consistency d oes not exist. Grant Thornton’ s report indicates that they audited one year (the year ended June 30, 2012), but opined on three years (i.e. the three years ended June 3 0, 2012). In these circumstances, we believe that you must obtain a revised report from Grant Thornton that rectifies this inconsistency and, with their consent, include the revised report in an amendment of Novogen’s Form 20 -F for the year ended June 30 , 2012 that removes the opinion currently included in Novogen’s Form 20 -F. Graham Kelly Novogen Limited May 23, 201 3 Page 2 You may contact Vanessa Robertson, Staff Accountant, at (202) 551 -3649 or Lisa Vanjoske, Assistant Chief Accountant, at (202) 551 -3614 if you have any questions regarding the co mment. In this regard, do not hesitate to contact me at (202) 551 -3679 . Sincerely, /s/ Jim B. Rosenberg Jim B. Rosenberg Senior Assistant Chief Accountant