SEC Comment Letter for ONCOSEC MEDICAL Inc (ONCSQ) (CIK 0001444307) — Feb 13, 2020
ONCOSEC MEDICAL Inc (ONCSQ) (CIK 0001444307)
Date: Feb. 13, 2020 · CIK: 0001444307 · Accession: 0000000000-20-001392
AI Filing Summary & Sentiment
File numbers found in text: 000-54318
Letter
February 13, 2020 Robert J. Delaversano Principal Accounting Officer OncoSec Medical Inc 24 North Main Street Pennington, NJ 08534 Re:OncoSec Medical Inc Form 10-K for the fiscal year ended July 31, 2019 Filed October 28, 2019 Form 10-Q for the quarterly period ended October 31, 2019 Filed December 13, 2019 File No. 000-54318 Dear Mr. Delaversano: We have reviewed your filings and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-Q for the Quarterly Period Ended October 31, 2019 Financial Statements Notes to Financial Statements Note 8 - Commitments and Contingencies License Agreement and Services Agreement, page 23 1.You disclose "Whether or not Closing occurs, but subject to certain conditions on effectiveness described above, the Company (1) will grant CGP and its affiliates an exclusive license to develop, manufacture, commercialize, or otherwise exploit current and future products, including TAVO and the VLA in the Territory for which CGP will pay the Company up to 20% royalties on the net sales of such products in the Territory." Please disclose the royalty rate or a range that does not exceed a 10 point range. Also disclose the minimum royalty and termination provisions specified in the agreement.
FirstName LastNameRobert J. Delaversano Comapany NameOncoSec Medical Inc February 13, 2020 Page 2 FirstName LastName Robert J. Delaversano OncoSec Medical Inc February 13, 2020 Page 2 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. You may contact Lisa Vanjoske at (202) 551-3614 or Daniel Gordon at (202) 551-3486 if you have questions regarding the comment. Sincerely, Division of Corporation Finance Office of Life Sciences
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February 13, 2020
Robert J. Delaversano
Principal Accounting Officer
OncoSec Medical Inc
24 North Main Street
Pennington, NJ 08534
Re:OncoSec Medical Inc
Form 10-K for the fiscal year ended July 31, 2019
Filed October 28, 2019
Form 10-Q for the quarterly period ended October 31, 2019
Filed December 13, 2019
File No. 000-54318
Dear Mr. Delaversano:
We have reviewed your filings and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-Q for the Quarterly Period Ended October 31, 2019
Financial Statements
Notes to Financial Statements
Note 8 - Commitments and Contingencies
License Agreement and Services Agreement, page 23
1.You disclose "Whether or not Closing occurs, but subject to certain conditions on
effectiveness described above, the Company (1) will grant CGP and its affiliates an
exclusive license to develop, manufacture, commercialize, or otherwise exploit current
and future products, including TAVO and the VLA in the Territory for which CGP will
pay the Company up to 20% royalties on the net sales of such products in the Territory."
Please disclose the royalty rate or a range that does not exceed a 10 point range. Also
disclose the minimum royalty and termination provisions specified in the agreement.
FirstName LastNameRobert J. Delaversano
Comapany NameOncoSec Medical Inc
February 13, 2020 Page 2
FirstName LastName
Robert J. Delaversano
OncoSec Medical Inc
February 13, 2020
Page 2
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.
You may contact Lisa Vanjoske at (202) 551-3614 or Daniel Gordon at (202) 551-3486 if
you have questions regarding the comment.
Sincerely,
Division of Corporation Finance
Office of Life Sciences