SEC Comment Letter for CREATIVE MEDICAL TECHNOLOGY HOLDINGS, INC. (CELZ) (CIK 0001187953) (CELZ) — Nov 3, 2016
CREATIVE MEDICAL TECHNOLOGY HOLDINGS, INC. (CELZ) (CIK 0001187953)
Date: Nov. 3, 2016 · CIK: 0001187953 · Accession: 0000000000-16-099584
AI Filing Summary & Sentiment
Letter
Mail Stop 4546 November 2 , 2016 Timothy Warbington Chief Executive Officer Creative Medical Technology Holdings, Inc. 2017 W Peoria Avenue Phoenix, AZ 85029
Re: Creative Medical Technology Holdings, Inc. Amendment No. 2 to Draft Registration Statement on Form S -1 Submitted October 12, 2016 CIK No. 0001187953
Dear Mr. Warbington :
We have reviewed your amended draft 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 providing the requested information and either submitting an amended draft registration statement or publicly fili ng your registration statement on EDGAR. 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 the information you provide in respons e to these comments and your amended draft registration statement or filed registration statement, we may have additional comments.
Intellectual Property, page 19
1. We note your response to our prior comment 7. Please note that although a request for confidential treatment has been made, you should include a description of the material terms of the agreement. Please revise to disclose the material terms of the licen se agreement with the University of California.
Exhibit Index
2. We note you are seeking confidential treatment of portions of an agreement filed as an exhibit. Please note we will provide any comments on your application separately.
Timothy Warbington Creative Medical Technology Holdings, Inc. November 2 , 2016 Page 2
You may contact Jame s Peklenk at (202) 551 -3661 or Sharon Blume at (202) 551 -3474 if you have questions regarding comments on the financial statements and related matters. Please contact Michael Gershon at (202) 551 -6598 or Mary Beth Breslin at (202) 551 -3625 with any other q uestions.
Sincerely,
/s/ Mary Beth Breslin for
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Mail Stop 4546
November 2 , 2016
Timothy Warbington
Chief Executive Officer
Creative Medical Technology Holdings, Inc.
2017 W Peoria Avenue
Phoenix, AZ 85029
Re: Creative Medical Technology Holdings, Inc.
Amendment No. 2 to Draft Registration Statement on Form S -1
Submitted October 12, 2016
CIK No. 0001187953
Dear Mr. Warbington :
We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly fili ng your registration statement on
EDGAR. 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 the information you provide in respons e to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Intellectual Property, page 19
1. We note your response to our prior comment 7. Please note that although a request for
confidential treatment has been made, you should include a description of the material
terms of the agreement. Please revise to disclose the material terms of the licen se
agreement with the University of California.
Exhibit Index
2. We note you are seeking confidential treatment of portions of an agreement filed as an
exhibit. Please note we will provide any comments on your application separately.
Timothy Warbington
Creative Medical Technology Holdings, Inc.
November 2 , 2016
Page 2
You may contact Jame s Peklenk at (202) 551 -3661 or Sharon Blume at (202) 551 -3474 if
you have questions regarding comments on the financial statements and related matters. Please
contact Michael Gershon at (202) 551 -6598 or Mary Beth Breslin at (202) 551 -3625 with any
other q uestions.
Sincerely,
/s/ Mary Beth Breslin for
Suzanne Hayes
Assistant Director
Office of Healthcare and Insurance
cc: Ronald N. Vance, Esq.