SEC Comment Letter for PALISADE BIO, INC. (PALI) (CIK 0001357459) (PALI) — Feb 27, 2020
PALISADE BIO, INC. (PALI) (CIK 0001357459)
Date: Feb. 27, 2020 · CIK: 0001357459 · Accession: 0000000000-20-001797
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-236543
Letter
February 27, 2020 Kenneth Carter, PhD Chief Executive Officer Seneca Biopharma, Inc. 20271 Goldenrod Lane Germantown, Maryland 20876 Re:Seneca Biopharma, Inc. Registration Statement on Form S-3 Filed February 20, 2020 File No. 333-236543 Dear Dr. Carter: We have limited our review of your registration statement to those issues we have addressed in our comment. In our comment, 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 comment applies 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 our comment, we may have additional comments. Registration Statement on Form S-3 filed February 20, 2020 General 1.We note that you filed this registration statement more than 45 days after the end of your fiscal year. As you do not appear to meet the age of financial statement requirements of Rule 8-08(b) of Regulation S-X, you will need to include your audited financial statements or file and incorporate by reference your Form 10-K for fiscal year ended December 31, 2019 before we will accelerate the effective date of your registration statement. For additional guidance, please refer to Section 1220.3 of the Division's Financial Reporting Manual. 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 LastNameKenneth Carter, PhD Comapany NameSeneca Biopharma, Inc. February 27, 2020 Page 2 FirstName LastName Kenneth Carter, PhD Seneca Biopharma, Inc. February 27, 2020 Page 2 Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Tim Buchmiller at (202) 551-3635 or Mary Beth Breslin at (202) 551- 3625 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Raul Silvestre, Esq.
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February 27, 2020
Kenneth Carter, PhD
Chief Executive Officer
Seneca Biopharma, Inc.
20271 Goldenrod Lane
Germantown, Maryland 20876
Re:Seneca Biopharma, Inc.
Registration Statement on Form S-3
Filed February 20, 2020
File No. 333-236543
Dear Dr. Carter:
We have limited our review of your registration statement to those issues we have
addressed in our comment. In our comment, 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 comment applies 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 our comment, we may have additional comments.
Registration Statement on Form S-3 filed February 20, 2020
General
1.We note that you filed this registration statement more than 45 days after the end of your
fiscal year. As you do not appear to meet the age of financial statement requirements of
Rule 8-08(b) of Regulation S-X, you will need to include your audited financial
statements or file and incorporate by reference your Form 10-K for fiscal year ended
December 31, 2019 before we will accelerate the effective date of your registration
statement. For additional guidance, please refer to Section 1220.3 of the Division's
Financial Reporting Manual.
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 LastNameKenneth Carter, PhD
Comapany NameSeneca Biopharma, Inc.
February 27, 2020 Page 2
FirstName LastName
Kenneth Carter, PhD
Seneca Biopharma, Inc.
February 27, 2020
Page 2
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Tim Buchmiller at (202) 551-3635 or Mary Beth Breslin at (202) 551-
3625 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Raul Silvestre, Esq.