SEC Comment Letter for CNBX Pharmaceuticals (CNBX) — Dec 1, 2015
CNBX Pharmaceuticals Inc.
Date: Dec. 1, 2015 · CIK: 0001343009 · Accession: 0000000000-15-055851
AI Filing Summary & Sentiment
File numbers found in text: 000-52403
Letter
Mail Stop 3561 November 30 , 2015 Via E -Mail Itamar Borochov Chief Executive Officer Cannabics Pharmaceuticals Inc. #3 Bethesda Metro Center Suite 700 Bethesda, MD 20814
Re: Cannabics Pharmaceuticals Inc. Amendment No. 1 to Form 10-K for the Fiscal Year Ended August 31 , 2014 Filed October 23, 2015 File No. 000-52403
Dear Mr. Borochov :
We have reviewed your October 2 0, 2015 response to our comment letter and have the following comments . In our comment s, 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 prov iding the requested information or advise us when you will respond . If you do not believe our comment s 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. Unless we note otherwise, our references to prior c omments are to comments in our September 1 5, 2015 letter.
Form 10 -K for the Fiscal Year Ended August 31, 2014
Item 1. Description of Business
Regulations, page 7
1. We note your response to comment 1 and we partially reissue. Please expand upon your statement that the company could be deemed to be at variance with the Federal Controlled Substances Act. Clarify the potential impact on the company as a result. In addition, as previously requested, please revise your disclosure to alert investors that your operations could be deemed to facilitate the selling or distribution of marijuana in violation of the federal Controlled Substances Act, or to constitute aiding or abetting, or being an accessory to, a violation of that Act.
Itamar Borochov Cannabics Pharmaceuticals Inc. November 30 , 2015 Page 2
2. We reissue comment 2. Please explain the basis for your belief that your product will not fall within the FDA review of medicine, as opposed to edible products, when you refer to your technology as medical cannabis capsules that will provide relief from various ailments. Signatures, page 21
3. We reissue comment 5. We note that you have not identified the principal accounting officer or controller. Refer to General Instruction D(2)(a). Please contact Hillary Daniels at (202) 551 -3959 or Pamela Howell at (202) 551 -3357 with any questions.
Sincerely,
/s/ Pamela Howell
for
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Mail Stop 3561 November 30 , 2015 Via E -Mail Itamar Borochov Chief Executive Officer Cannabics Pharmaceuticals Inc. #3 Bethesda Metro Center Suite 700 Bethesda, MD 20814 Re: Cannabics Pharmaceuticals Inc. Amendment No. 1 to Form 10-K for the Fiscal Year Ended August 31 , 2014 Filed October 23, 2015 File No. 000-52403 Dear Mr. Borochov : We have reviewed your October 2 0, 2015 response to our comment letter and have the following comments . In our comment s, 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 prov iding the requested information or advise us when you will respond . If you do not believe our comment s 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. Unless we note otherwise, our references to prior c omments are to comments in our September 1 5, 2015 letter. Form 10 -K for the Fiscal Year Ended August 31, 2014 Item 1. Description of Business Regulations, page 7 1. We note your response to comment 1 and we partially reissue. Please expand upon your statement that the company could be deemed to be at variance with the Federal Controlled Substances Act. Clarify the potential impact on the company as a result. In addition, as previously requested, please revise your disclosure to alert investors that your operations could be deemed to facilitate the selling or distribution of marijuana in violation of the federal Controlled Substances Act, or to constitute aiding or abetting, or being an accessory to, a violation of that Act. Itamar Borochov Cannabics Pharmaceuticals Inc. November 30 , 2015 Page 2 2. We reissue comment 2. Please explain the basis for your belief that your product will not fall within the FDA review of medicine, as opposed to edible products, when you refer to your technology as medical cannabis capsules that will provide relief from various ailments. Signatures, page 21 3. We reissue comment 5. We note that you have not identified the principal accounting officer or controller. Refer to General Instruction D(2)(a). Please contact Hillary Daniels at (202) 551 -3959 or Pamela Howell at (202) 551 -3357 with any questions. Sincerely, /s/ Pamela Howell for John Reynolds Assistant Director Office of Beverages, Apparel, and Mining