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SEC Comment Letter 0000000000-23-006872 to Opus Genetics, Inc. (IRD)

Opus Genetics, Inc.
Date: June 28, 2023 · CIK: 0001228627 · Accession: 0000000000-23-006872

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File numbers found in text: 001-34079

Date
June 28, 2023
Author
Not clearly detected
Form
UPLOAD
Company
Opus Genetics, Inc.

Letter

United States securities and exchange commission logo June 28, 2023 Richard Rodgers Interim President and Chief Executive Officer Ocuphire Pharma, Inc. 37000 Grand River Avenue, Suite 120 Farmington Hills, MI 48335 Re:Ocuphire Pharma, Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Filed March 30, 2023 File No. 001-34079 Dear Richard Rodgers: We have reviewed your filings and have the following comment. 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 business days by providing the requested information or advise 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. Form 10-K for the Fiscal Year Ended December 31, 2022 Results of Operations Research and Development, page 111 1.We note the discussion on page 109 that your Nyxol and APX3330 will have higher development costs due to later-stage clinical trials and that you expect research and development costs to increase over the next several years. Please revise future filings to disclose the costs incurred during each period presented for each of your key research and development products/projects. If you do not track your research and development costs by project, disclose that fact and explain why you do not maintain and evaluate research and development costs by project. Provide other quantitative or qualitative disclosure that provides more transparency as to the type of research and development expenses incurred (i.e., by nature or type of expense) which should reconcile to total research and development expense on the Consolidated Statements of Operations.

FirstName LastNameRichard Rodgers Comapany NameOcuphire Pharma, Inc. June 28, 2023 Page 2 FirstName LastName Richard Rodgers Ocuphire Pharma, Inc. June 28, 2023 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Tara Harkins at (202) 551-3639 or Kevin Kuhar, Accounting Branch Chief, at (202) 551-3662 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences

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United States securities and exchange commission logo
June 28, 2023
Richard Rodgers
Interim President and Chief Executive Officer
Ocuphire Pharma, Inc.
37000 Grand River Avenue, Suite 120
Farmington Hills, MI 48335
Re:Ocuphire Pharma, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed March 30, 2023
File No. 001-34079
Dear Richard Rodgers:
            We have reviewed your filings and have the following comment.  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 business days by providing the requested
information or advise 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.
Form 10-K for the Fiscal Year Ended December 31, 2022
Results of Operations
Research and Development, page 111
1.We note the discussion on page 109 that your Nyxol and APX3330 will have higher
development costs due to later-stage clinical trials and that you expect research and
development costs to increase over the next several years.  Please revise future filings to
disclose the costs incurred during each period presented for each of your key research and
development products/projects. If you do not track your research and development costs
by project, disclose that fact and explain why you do not maintain and evaluate research
and development costs by project. Provide other quantitative or qualitative disclosure that
provides more transparency as to the type of research and development expenses incurred
(i.e., by nature or type of expense) which should reconcile to total research and
development expense on the Consolidated Statements of Operations.

 FirstName LastNameRichard Rodgers
 Comapany NameOcuphire Pharma, Inc.
 June 28, 2023 Page 2
 FirstName LastName
Richard Rodgers
Ocuphire Pharma, Inc.
June 28, 2023
Page 2
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Tara Harkins at (202) 551-3639 or Kevin Kuhar, Accounting Branch
Chief, at (202) 551-3662 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences