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SEC Company Response from Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) (GRCE) — Oct 12, 2018

Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Date: Oct. 12, 2018 · CIK: 0001444192 · Accession: 0001171843-18-006964

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File numbers found in text: 333-220755

Referenced dates: October 1, 2018

Date
October 12, 2018
Author
/s/ Jason Comerford
Form
CORRESP
Company
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)

Letter

Osler, Hoskin & Harcourt llp

620 8th Avenue – 36th Floor

New York, N.Y. 10018

212.867.5800 main

212.867.5802 facsimile

New York

Toronto

Montréal

Calgary

Ottawa

Vancouver

October 12, 2018

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street N.E.

Washington, D.C. 20549

Attention: Dorrie Yale and Erin Jaskot

Re:

Acasti Pharma Inc.

Post-Effective Amendment No. 1 to Registration Statement on Form F-1

Filed September 21, 2018

File No. 333-220755

Ladies and Gentlemen:

On behalf of Acasti Pharma Inc. (the “Company”), we are today filing with the U.S. Securities and Exchange Commission (the “Commission”) the Amendment No. 1 to Post-Effective Amendment No. 1 (the “Amendment No. 1”) to the Company’s registration statement on Form F-1, first filed on September 29, 2017 and declared effective by the Commission on December 19, 2017. This Amendment No. 1 is filed with the Commission in response to the comment received from the staff’s letter dated October 1, 2018.

For ease of review, the staff’s comment has been reproduced below in italics, followed by the Company’s response.

Post-effective Amendment to Form F-1

General

1. We note that you have omitted substantially all of the disclosure required by Part I of Form F-1 in this post-effective amendment to your registration statement on Form F-1. Please amend to include all of the disclosures required by Part I. Refer to Rule 472(b) of the Securities Act of 1933, as amended.

Response: Concurrently herewith, the Company has filed Amendment No. 1, which includes disclosures required by Part I of Form F-1. Pursuant to General Instruction VI of Form F-1, the Company has elected to incorporate by reference reports filed by the Company under the Securities Exchange Act of 1934, as amended, to provide the information required by Item 3 and Item 4 of Form F-1 in accordance with Item 4A and Item 5 of Form F-1.

Should you have any questions, please contact the undersigned at 212-991-2533.

Sincerely,
/s/ Jason Comerford

Show Raw Text
CORRESP
1
filename1.htm

Osler, Hoskin & Harcourt llp

620 8th Avenue – 36th Floor

New York, N.Y.  10018

212.867.5800  main

212.867.5802  facsimile

New York

Toronto

Montréal

Calgary

Ottawa

Vancouver

October 12, 2018

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street N.E.

Washington, D.C. 20549

Attention: Dorrie Yale and Erin Jaskot

    Re:

    Acasti Pharma Inc.

                           Post-Effective Amendment No. 1 to Registration Statement
                           on Form F-1

                           Filed September 21, 2018

                           File No. 333-220755

    Ladies and Gentlemen:

On behalf of Acasti Pharma Inc. (the “Company”),
we are today filing with the U.S. Securities and Exchange Commission (the “Commission”) the Amendment No. 1
to Post-Effective Amendment No. 1 (the “Amendment No. 1”) to the Company’s registration statement on Form
F-1, first filed on September 29, 2017 and declared effective by the Commission on December 19, 2017. This Amendment No. 1 is filed
with the Commission in response to the comment received from the staff’s letter dated October 1, 2018.

For ease of review, the staff’s comment has been reproduced
below in italics, followed by the Company’s response.

Post-effective Amendment to Form F-1

General

    1.
    We note that you have omitted substantially all of the disclosure required by Part I of Form F-1 in this post-effective amendment to your registration statement on Form F-1. Please amend to include all of the disclosures required by Part I. Refer to Rule 472(b) of the Securities Act of 1933, as amended.

        Response: Concurrently herewith, the Company has filed Amendment No. 1, which includes disclosures required by Part I of Form F-1. Pursuant to General Instruction VI of Form F-1, the Company
has elected to incorporate by reference reports filed by the Company under the Securities Exchange Act of 1934, as amended, to
provide the information required by Item 3 and Item 4 of Form F-1 in accordance with Item 4A and Item 5 of Form F-1.

    Should you have any questions, please contact
the undersigned at 212-991-2533.

                    Sincerely,

/s/ Jason Comerford

    cc:
    Janelle D’Alvise, Acasti Pharma Inc.

        Linda O’Keefe, Acasti Pharma Inc.

        Jean-François Boily, Acasti Pharma Inc.

osler.com