SEC Comment Letter 0000000000-23-007220 to Sagimet Biosciences Inc. (SGMT)
Sagimet Biosciences Inc.
Date: July 6, 2023 · CIK: 0001400118 · Accession: 0000000000-23-007220
AI Filing Summary & Sentiment
File numbers found in text: 333-272901
Letter
United States securities and exchange commission logo July 6, 2023 David Happel President and Chief Executive Officer Sagimet Biosciences Inc. 155 Bovet Road, Suite 303 San Mateo, California 94402 Re:Sagimet Biosciences Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed July 3, 2023 Registration Statement on Form S-1 Filed June 23, 2023 File No. 333-272901 Dear David Happel: We have reviewed your amended registration statement 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 amending your registration statement and providing the requested information. If 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Amendment No. 1 to Registration Statement on Form S-1 Business Data for selected competitor product candidates, page 120 1.We note your revised disclosure on pages 120-121 which presents data from multiple other clinical drug candidates for the treatment of NASH. Given that you do not appear to have conducted head-to-head trials of your product candidate against any of the product candidates included in this disclosure, the inclusion of this information does not appear to be appropriate. Please remove this disclosure from the prospectus. You may cite competitor product candidates without presenting data from competitor clinical trials.
FirstName LastNameDavid Happel Comapany NameSagimet Biosciences Inc. July 6, 2023 Page 2 FirstName LastName David Happel Sagimet Biosciences Inc. July 6, 2023 Page 2 License agreement with Ascletis, page 121 2.We note your disclosure indicating that in July 2023 you assigned additional patents and patent applications to Gannex. Please revise your disclosure to disclose the subject matter of the additional patents and patent applications assigned to Gannex. Exhibits 3.We note that Exhibit 10.24 appears to contain redactions. Please revise your exhibit index to disclose that this exhibit contains redactions. Please also file the July 2023 Assignment and Assumption Agreement referenced on page 122 as an exhibit to your registration statement. Alternatively, please tell us why this agreement is not required to be filed. You may contact Gary Newberry at 202-551-3761 or Angela Connell at 202-551-3426 if you have questions regarding comments on the financial statements and related matters. Please contact Cindy Polynice at 202-551-8707 or Alan Campbell at 202-551-4224 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Alicia Tschirhart
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United States securities and exchange commission logo
July 6, 2023
David Happel
President and Chief Executive Officer
Sagimet Biosciences Inc.
155 Bovet Road, Suite 303
San Mateo, California 94402
Re:Sagimet Biosciences Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed July 3, 2023
Registration Statement on Form S-1
Filed June 23, 2023
File No. 333-272901
Dear David Happel:
We have reviewed your amended registration statement 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 amending your registration statement and providing the
requested information. If 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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 1 to Registration Statement on Form S-1
Business
Data for selected competitor product candidates, page 120
1.We note your revised disclosure on pages 120-121 which presents data from multiple
other clinical drug candidates for the treatment of NASH. Given that you do not appear to
have conducted head-to-head trials of your product candidate against any of the product
candidates included in this disclosure, the inclusion of this information does not appear to
be appropriate. Please remove this disclosure from the prospectus. You may cite
competitor product candidates without presenting data from competitor clinical trials.
FirstName LastNameDavid Happel
Comapany NameSagimet Biosciences Inc.
July 6, 2023 Page 2
FirstName LastName
David Happel
Sagimet Biosciences Inc.
July 6, 2023
Page 2
License agreement with Ascletis, page 121
2.We note your disclosure indicating that in July 2023 you assigned additional patents and
patent applications to Gannex. Please revise your disclosure to disclose the subject matter
of the additional patents and patent applications assigned to Gannex.
Exhibits
3.We note that Exhibit 10.24 appears to contain redactions. Please revise your exhibit index
to disclose that this exhibit contains redactions. Please also file the July 2023 Assignment
and Assumption Agreement referenced on page 122 as an exhibit to your registration
statement. Alternatively, please tell us why this agreement is not required to be filed.
You may contact Gary Newberry at 202-551-3761 or Angela Connell at 202-551-3426 if
you have questions regarding comments on the financial statements and related matters. Please
contact Cindy Polynice at 202-551-8707 or Alan Campbell at 202-551-4224 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Alicia Tschirhart