SEC Comment Letter for Pluri Inc. (PLUR) (CIK 0001158780) (PLUR) — Feb 27, 2017
Pluri Inc. (PLUR) (CIK 0001158780)
Date: Feb. 27, 2017 · CIK: 0001158780 · Accession: 0000000000-17-006542
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-31392
Letter
Mail Stop 4546 February 27, 2017 Yaky Yanay Chief Financial Officer, Chief Operating Officer and President Pluristem Therapeutics Inc. Matam Advanced Technology Park Building No. 5 Haifa, Israel, 31905
Re: Pluristem Therapeutics Inc. Form 10-K for the Fiscal Year Ended June 30, 2016 Filed September 7, 2016 File No. 001-31392
Dear Mr. Aberman :
We have reviewed your filing an d 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
General
1. In future filings, please include all material terms for your material collaboration and license agreements. Please also file these agreements as exhibits to your next Exchange Act report. We note, for example, your collaborative research agreement with the Berlin - Brandenburg Center for Regenerative Therapies at Charité, your license agreement with TES Holdings Co., Ltd., and your collaboration with Fukushima Medical University. Please ensure that your disclosure includes all material terms including, as appropriate, the duration of the agreement, termination provisions, material payment provi sions, future milestone payments to be paid or received, and royalty rates and royalty terms. In the alternative, please tell us why you do not believe these agreements are material.
We remind you that the company and its management are responsible for t he accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Yaky Yanay Pluristem Therapeutics Inc. February 27, 2017 Page 2
Please contact Chris Edwards at (202) 551 -6761 or Erin Jaskot at (202) 551 -3442 with any questions.
Sincerely,
/s/ Erin K. Jaskot
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Mail Stop 4546 February 27, 2017 Yaky Yanay Chief Financial Officer, Chief Operating Officer and President Pluristem Therapeutics Inc. Matam Advanced Technology Park Building No. 5 Haifa, Israel, 31905 Re: Pluristem Therapeutics Inc. Form 10-K for the Fiscal Year Ended June 30, 2016 Filed September 7, 2016 File No. 001-31392 Dear Mr. Aberman : We have reviewed your filing an d 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response. After reviewing your response to these comments, we may have additional comments. General 1. In future filings, please include all material terms for your material collaboration and license agreements. Please also file these agreements as exhibits to your next Exchange Act report. We note, for example, your collaborative research agreement with the Berlin - Brandenburg Center for Regenerative Therapies at Charité, your license agreement with TES Holdings Co., Ltd., and your collaboration with Fukushima Medical University. Please ensure that your disclosure includes all material terms including, as appropriate, the duration of the agreement, termination provisions, material payment provi sions, future milestone payments to be paid or received, and royalty rates and royalty terms. In the alternative, please tell us why you do not believe these agreements are material. We remind you that the company and its management are responsible for t he accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Yaky Yanay Pluristem Therapeutics Inc. February 27, 2017 Page 2 Please contact Chris Edwards at (202) 551 -6761 or Erin Jaskot at (202) 551 -3442 with any questions. Sincerely, /s/ Erin K. Jaskot Suzanne Hayes Assistant Director Office of Healthcare and Insurance