SEC Comment Letter for SELLAS Life Sciences Group, Inc. (SLS) (CIK 0001390478) (SLS) — Jan 15, 2014
SELLAS Life Sciences Group, Inc. (SLS) (CIK 0001390478)
Date: Jan. 15, 2014 · CIK: 0001390478 · Accession: 0000000000-14-002172
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33958
Letter
January 14, 2014 Via E-mail Dr. Mark J. Ahn, PhD President and C hief Executive Officer Galena Biopharma, Inc. 4640 SW Macadam Avenue, Suite 270 Portland, Oregon 97239
Re: Galena Biopharma, Inc. Form 10-K for Fiscal Year Ended December 31, 201 2 Filed March 12 , 2013 Form 10 -Q for the Quarterly Period Ended September 30, 2013 Filed November 6, 2013 and amended on November 7, 2013 File No. 001-33958
Dear Dr. Ahn:
We have reviewed your December 26 , 2013 response to our December 13 , 2013 letter and have the following comment.
Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the req uested response. If you do not believe the comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comment.
After reviewing the information provided, we may raise additional comments and/or request that you amend your filings.
Form 10 -Q for the Quarterly Period Ended September 30, 2013 Notes to Condensed Consolidated Financial Statements (unaudited) 1. Business and Basis of Presentation Acquisitions and In -Licensing, page 9
1. Please refer to your response to comment one. As Abstral was an approved product when you licensed it , please provide us with an analysis supporting your conclusion that the license of Abstral was an a sset acquisition and not a business combination. Please refer to ASC - 805-10-55-4 to 9.
Dr. Mark J. Ahn Galena Biopharma, Inc. January 14, 2014 Page 2
Please contact Frank Wyman, Staff Accountant, at (202) 551 -3660 or Joel Parker, Accounting Branch Chief , at (202) 551 -3651 if you have any questions regarding th e comment. In this regard, do not hesitate to contact me at (202) 551 -3679.
Sincerely,
Jim B. Rosenberg
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January 14, 2014 Via E-mail Dr. Mark J. Ahn, PhD President and C hief Executive Officer Galena Biopharma, Inc. 4640 SW Macadam Avenue, Suite 270 Portland, Oregon 97239 Re: Galena Biopharma, Inc. Form 10-K for Fiscal Year Ended December 31, 201 2 Filed March 12 , 2013 Form 10 -Q for the Quarterly Period Ended September 30, 2013 Filed November 6, 2013 and amended on November 7, 2013 File No. 001-33958 Dear Dr. Ahn: We have reviewed your December 26 , 2013 response to our December 13 , 2013 letter and have the following comment. Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the req uested response. If you do not believe the comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comment. After reviewing the information provided, we may raise additional comments and/or request that you amend your filings. Form 10 -Q for the Quarterly Period Ended September 30, 2013 Notes to Condensed Consolidated Financial Statements (unaudited) 1. Business and Basis of Presentation Acquisitions and In -Licensing, page 9 1. Please refer to your response to comment one. As Abstral was an approved product when you licensed it , please provide us with an analysis supporting your conclusion that the license of Abstral was an a sset acquisition and not a business combination. Please refer to ASC - 805-10-55-4 to 9. Dr. Mark J. Ahn Galena Biopharma, Inc. January 14, 2014 Page 2 Please contact Frank Wyman, Staff Accountant, at (202) 551 -3660 or Joel Parker, Accounting Branch Chief , at (202) 551 -3651 if you have any questions regarding th e comment. In this regard, do not hesitate to contact me at (202) 551 -3679. Sincerely, Jim B. Rosenberg Jim B. Rosenberg Senior Assistant Chief Accountant