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SEC Comment Letter for SUTRO BIOPHARMA, INC. (STRO) (CIK 0001382101) (STRO) — Aug 24, 2018

SUTRO BIOPHARMA, INC. (STRO) (CIK 0001382101)
Date: Aug. 24, 2018 · CIK: 0001382101 · Accession: 0000000000-18-026407

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
August 23, 2018
Author
/s/ John Reynolds
Form
UPLOAD
Company
SUTRO BIOPHARMA, INC. (STRO) (CIK 0001382101)

Letter

Mail Stop 4628 August 23, 2018 William J. Newell Chief Executive Officer Sutro Biopharma , Inc. 310 Utah Avenue, Suite 150 South San Francisco, CA 94080

Re: Sutro Biopharma, Inc. Amendment No. 1 to Draft Registration Statement on Form S -1 Response dated August 20 , 2018 CIK No. 0001382101

Dear Mr. Newell :

We have reviewed your response letter 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 providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. I f 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 the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments.

General

1. Please disclose the specific indication (s) for the Immuno -oncology Bispecific Antibody (bsAb) product candidate in your Celgene collaboration program or tell us why you are not able to do so.

2. While we do not object to a narrative discussion of your discovery and preclinical programs in the Prospectus Summary or the inclusion of your discovery program and preclinical program s as a gr aphic in the Business section, we believe that presenting these programs as a prominent graphic in the Prospectus Summary is not appropriate given that the product candidates have yet to be identified and these programs remain in the discovery or preclinic al development stage and may not reach any of the clinical stages . In addition, please expand this graphic to include additional colum ns reflecting the clinical stage phases to describe each program ’s progress toward clinical development .

William J. Newell Sutro Biopharma, Inc. August 23, 2018 Page 2

You may contact Wei Lu , Staff Accountant, at (202) 551 -3725 or Ethan Horowitz , Accounti ng Branch Chief, at 202 -551-3311 if you have questions regarding comments on the financial s tatements and related matters. Please contact Irene Barberena -Meissner, Staff Attorn ey, at (202) 551 -6548 or Kevin Dougherty, Staff Attorney, at (202) 551 -3271 with any other questions.

Sincerely,
/s/ John Reynolds

Show Raw Text
Mail Stop 4628
August  23, 2018

William J. Newell
Chief Executive Officer
Sutro Biopharma , Inc.
310 Utah Avenue, Suite 150
South San Francisco, CA 94080

Re: Sutro Biopharma, Inc.
Amendment No. 1 to Draft Registration Statement on Form S -1
Response dated August 20 , 2018
CIK No.  0001382101

Dear Mr. Newell :

We have reviewed  your response letter 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  I f 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 the information you provide in response to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

General

1. Please disclose  the specific indication (s) for the Immuno -oncology Bispecific Antibody
(bsAb) product candidate in your Celgene  collaboration program  or tell us why you are
not able to do  so.

2. While we do not object to a narrative discussion of your discovery and preclinical
programs in the Prospectus Summary or the inclusion of your discovery program  and
preclinical program s as a gr aphic in the Business section, we believe that presenting these
programs as a prominent graphic in the  Prospectus  Summary is not appropriate given that
the product candidates have yet to be identified and these programs remain in the
discovery or preclinic al development stage  and may not reach any of the clinical stages .
In addition, please expand  this graphic to include  additional colum ns reflecting  the
clinical stage phases to describe  each program ’s progress  toward clinical development .

William J. Newell
Sutro  Biopharma, Inc.
August  23, 2018
Page 2

   You may contact  Wei Lu , Staff Accountant, at (202) 551 -3725  or Ethan Horowitz ,
Accounti ng Branch Chief, at 202 -551-3311 if you have questions regarding comments on the
financial s tatements and related matters.  Please contact Irene Barberena -Meissner, Staff
Attorn ey, at (202) 551 -6548 or Kevin Dougherty, Staff Attorney, at (202) 551 -3271  with any
other questions.

Sincerely,

 /s/ John Reynolds

John Reynolds
Assistant Director
Office of Natural Resources

cc: Rob Freedman , Esq.
Fenwick & West  LLP