SEC Comment Letter for ROCKET PHARMACEUTICALS, INC. (RCKT, RCKTW) (CIK 0001281895) (RCKT) — Nov 29, 2017
ROCKET PHARMACEUTICALS, INC. (RCKT, RCKTW) (CIK 0001281895)
Date: Nov. 29, 2017 · CIK: 0001281895 · Accession: 0000000000-17-041869
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-36829
Letter
November 28, 2017 David P. Southwell President and Chief Executive Officer Inotek Pharmaceuticals Corporation 91 Hartwell Avenue Lexington, Massachusetts 02421 Re:Inotek Pharmaceuticals Corporation Revised Preliminary Proxy Statement on Schedule 14A Filed November 20, 2017 File No. 001-36829 Dear Mr. Southwell: We have reviewed your filing and have the following comment. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. From PRER14A Filed November 20, 2017 Notes to Financial Statements Audited Financial Statements of Rocket Pharmaceuticals, Ltd. for the Year Ended December 31, Agreements Related to Intellectual Property, page F-17 1.Please clarify your response to prior comment 17 by telling us whether you expense the intellectual properties acquired, under which you obtained the right to both develop and sublicense the acquired intellectual properties. If so, also tell us your basis for determining that no alternative future use exists. Refer to ASC 730-10-25-2c. 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.
FirstName LastNameDavid P. Southwell Comapany NameInotek Pharmaceuticals Corporation June 16, 2017 Page 2 FirstName LastName David P. Southwell Inotek Pharmaceuticals Corporation November 28, 2017 Page 2 You may contact Keira Nakada at 202-551-3659 or Sharon Blume at 202-551-3474 if you have questions regarding comments on the financial statements and related matters. Please contact Christine Westbrook at 202-551-5019 or Mary Beth Breslin at 202-551-3625 with any other questions. Division of Corporation Finance Office of Healthcare & Insurance cc: Andrew H. Goodman, Esq.
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November 28, 2017
David P. Southwell
President and Chief Executive Officer
Inotek Pharmaceuticals Corporation
91 Hartwell Avenue
Lexington, Massachusetts 02421
Re:Inotek Pharmaceuticals Corporation
Revised Preliminary Proxy Statement on Schedule 14A
Filed November 20, 2017
File No. 001-36829
Dear Mr. Southwell:
We have reviewed your filing and have the following comment.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
From PRER14A Filed November 20, 2017
Notes to Financial Statements
Audited Financial Statements of Rocket Pharmaceuticals, Ltd. for the Year Ended December 31,
2016
Agreements Related to Intellectual Property, page F-17
1.Please clarify your response to prior comment 17 by telling us whether you expense the
intellectual properties acquired, under which you obtained the right to both develop and
sublicense the acquired intellectual properties. If so, also tell us your basis for
determining that no alternative future use exists. Refer to ASC 730-10-25-2c.
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.
FirstName LastNameDavid P. Southwell
Comapany NameInotek Pharmaceuticals Corporation
June 16, 2017 Page 2
FirstName LastName
David P. Southwell
Inotek Pharmaceuticals Corporation
November 28, 2017
Page 2
You may contact Keira Nakada at 202-551-3659 or Sharon Blume at 202-551-3474 if
you have questions regarding comments on the financial statements and related matters. Please
contact Christine Westbrook at 202-551-5019 or Mary Beth Breslin at 202-551-3625 with any
other questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Andrew H. Goodman, Esq.