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SEC Comment Letter for ANAVEX LIFE SCIENCES CORP. (AVXL) (CIK 0001314052) (AVXL) — Aug 30, 2016

ANAVEX LIFE SCIENCES CORP. (AVXL) (CIK 0001314052)
Date: Aug. 30, 2016 · CIK: 0001314052 · Accession: 0000000000-16-090644

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
August 30, 2016
Author
/s/ Pamela Howell
Form
UPLOAD
Company
ANAVEX LIFE SCIENCES CORP. (AVXL) (CIK 0001314052)

Letter

Mail Stop 3561 August 30, 2016 Christopher Missling, PhD Chief Executive Officer Anavex Life Sciences Corp. 51 West 52nd Street, 7th Floor New York, NY 10019 -6163

Re: Anavex Life Sciences Corp. Amendment No. 2 to Registration Statement on Form S-3 Filed August 26, 2016 File No. 333 -207600

Dear Dr. Missling:

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 comm ents. Unless we note otherwise, our references to prior comments are to comments in our August 25 , 2016 letter.

The Lincoln Park Transaction, page 18

1. We reissue prior comment 3. Please disclose the impact of the 2013 Lincoln Park resales on the market price of the company’s stock. Please provide the basis for your statement that the sales did not have any discernable effect on the company’s stock pric e. It appears that the stock price decreased after the effectiveness of the Form S -1 registering the resale of the Lincoln Park shares.

Christopher Missling, PhD Anavex Life Sciences Corp. August 30, 2016 Page 2

Please contact Ronald E. Alper at (202) 551 -3329 or Pam Howell at (202) 551 -3357 with any questions.

Sincerely,
/s/ Pamela Howell
for

Show Raw Text
Mail Stop 3561

August 30, 2016

Christopher Missling, PhD
Chief Executive Officer
Anavex Life Sciences Corp.
51 West 52nd Street, 7th Floor
New York, NY 10019 -6163

Re: Anavex Life Sciences Corp.
  Amendment No. 2 to Registration Statement on Form S-3
Filed August 26, 2016
  File No. 333 -207600

Dear Dr. Missling:

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 comm ents.  Unless we note
otherwise, our references to prior comments are to comments in our August 25 , 2016 letter.

The Lincoln Park Transaction, page 18

1. We reissue prior comment 3.  Please disclose the impact of the 2013 Lincoln Park resales
on the market price of the company’s stock.  Please provide the basis for your statement
that the sales did not have any discernable effect on the company’s stock pric e.  It
appears that the stock price decreased after the effectiveness of the Form S -1 registering
the resale of the Lincoln Park shares.

Christopher Missling, PhD
Anavex Life Sciences Corp.
August 30, 2016
Page 2

 Please contact Ronald E. Alper at (202) 551 -3329 or Pam Howell  at (202) 551 -3357 with
any questions.

Sincerely,

 /s/ Pamela Howell
 for

 John Reynolds
Assistant Director
Office of Beverages, Apparel and
Mining

cc: Clayton Parker, Esq.
      K&L Gates LLP