SEC Comment Letter for Cyclacel Pharmaceuticals, Inc. (BGMS, BGMSP) (CIK 0001130166) (BGMS) — Jul 6, 2017
Cyclacel Pharmaceuticals, Inc. (BGMS, BGMSP) (CIK 0001130166)
Date: July 6, 2017 · CIK: 0001130166 · Accession: 0000000000-17-023561
AI Filing Summary & Sentiment
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Letter
July 6, 2017 Spiro Rombotis Chief Executive Officer Cyclacel Pharmaceuticals, Inc. 200 Connell Drive, Suite 1500 Berkeley Heights, NJ Cyclacel Pharmaceuticals, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed June 30, 2017 File No. 333-218305Re: Dear Mr. Rombotis: We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our June 9, 2017 letter. Amendment No. 1 to Registration Statement on Form S-1 Exhibits, page II-3 Please have counsel revise the legal opinion to opine on the Class A Units and Class B Units that are included in the registration statement. For guidance, please refer to Section II.B.1.h. of Staff Legal Bulletin No. 19.1.
Spiro Rombotis Cyclacel Pharmaceuticals, Inc. 2 PageJuly 6, 2017 Please contact Johnny Gharab at 202-551-3570 or Erin Jaskot, Special Counsel, at 202-551-3442 with any other questions. Division of Corporation Finance Office of Healthcare & Insurance
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July 6, 2017
Spiro Rombotis
Chief Executive Officer
Cyclacel Pharmaceuticals, Inc.
200 Connell Drive, Suite 1500
Berkeley Heights, NJ
07922
Cyclacel Pharmaceuticals, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed June 30, 2017
File No. 333-218305Re:
Dear Mr. Rombotis:
We have reviewed your amended registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our June 9, 2017 letter.
Amendment No. 1 to Registration Statement on Form S-1
Exhibits, page II-3
Please have counsel revise the legal opinion to opine on the Class A Units and Class B
Units that are included in the registration statement. For guidance, please refer to Section
II.B.1.h. of Staff Legal Bulletin No. 19.1.
Spiro Rombotis
Cyclacel Pharmaceuticals, Inc.
2 PageJuly 6, 2017
Please contact Johnny Gharab at 202-551-3570 or Erin Jaskot, Special Counsel, at
202-551-3442 with any other questions.
Division of Corporation Finance
Office of Healthcare & Insurance