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SEC Comment Letter for aTYR PHARMA INC (ATYR) (CIK 0001339970) (ATYR) — Feb 18, 2015

aTYR PHARMA INC (ATYR) (CIK 0001339970)
Date: Feb. 18, 2015 · CIK: 0001339970 · Accession: 0000000000-15-010065

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
February 18, 2015
Author
/s/ Bryan J. Pitko for
Form
UPLOAD
Company
aTYR PHARMA INC (ATYR) (CIK 0001339970)

Letter

February 18, 2015 Via E -mail John D. Mendlein, Ph.D. Chief Executive Officer and Executive Chairman aTyr Pharma, Inc. 3545 John Hopkins Court, Suite #250 San Diego, CA 92121

Re: aTyr Pharma, Inc. Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted February 2, 2015 CIK No. 0001339970

Dear Dr. Mendlein :

We have reviewed your amended draft registration statement and have the following comment.

Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comment applies 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 response to this comment and your amended draft registration statement or filed registration statement, we may have additional comments.

Prospectus Summary, page 1

1. We note on page 95 that you believe data from your Fc fusion experiments may produce data that will provide iModFc molecules for you to explore. We also note on page 96 that you are continuing to investigate potential therapeutic Physiocrines that may hav e the potential to inhibit inflammation in both the lung and the liver. As you do not have a drug candidate for your programs identified by the arrows labeled “iModFc non -RMIC,” “Liver,” or “Lung.” Please eliminate these programs from the pipeline table on pages 2 and 80.

John D. Mendlein, Ph.D. aTyr Pharma, Inc. February 18, 2015 Page 2

You may contact Mark Brunhofer at (202) 551 -3638 if you have questions regarding comments on the financial statements and related matters. Please contact Matthew Jones at (202) 551 -3786, Bryan Pitko at (202) 551 -3203 or me at (202) 551 -3715 with any other questions.

Sincerely,
/s/ Bryan J. Pitko for

Show Raw Text
February 18, 2015

Via E -mail
John D. Mendlein, Ph.D.
Chief Executive Officer and Executive Chairman
aTyr Pharma, Inc.
3545 John Hopkins Court, Suite #250
San Diego, CA 92121

Re: aTyr Pharma, Inc.
Amendment No. 1 to Draft Registration Statement on Form  S-1
Submitted February 2, 2015
  CIK No. 0001339970

Dear Dr. Mendlein :

We have reviewed your amended draft registration statement  and have the following
comment.

Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or  publicly  filing your registration statement on
EDGAR.  If  you do not believe our comment applies  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 response to this comment  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

Prospectus Summary, page 1

1. We note on page 95 that you believe data from your Fc fusion experiments may produce
data that will provide iModFc molecules for you to explore.  We also note on page 96
that you are continuing to investigate potential therapeutic Physiocrines that may hav e the
potential to inhibit inflammation in both the lung and the liver. As you do not have a drug
candidate for your programs identified by the arrows labeled “iModFc non -RMIC,”
“Liver,” or “Lung.” Please eliminate these programs from the pipeline table on  pages 2
and 80.

John D. Mendlein, Ph.D.
aTyr Pharma, Inc.
February 18, 2015
Page 2

 You may contact Mark Brunhofer at (202) 551 -3638 if you have questions regarding
comments on the financial statements and related matters.  Please contact Matthew Jones at
(202) 551 -3786, Bryan Pitko at (202) 551 -3203 or me at (202) 551 -3715 with any other
questions.

Sincerely,

 /s/ Bryan J. Pitko for

Jeffrey P. Riedler
Assistant Director

cc:  Kingsley L. Taft
Maggie L. Wong
Mitzi Chang
Goodwin Procter LLP
3 Embarcadero Center, 24th Floor
San Francisco, CA 94111