SEC Company Response from ADIAL PHARMACEUTICALS, INC. (ADIL) (CIK 0001513525) (AZR) — Jun 25, 2018
ADIAL PHARMACEUTICALS, INC. (ADIL) (CIK 0001513525)
Date: June 25, 2018 · CIK: 0001513525 · Accession: 0001213900-18-008189
AI Filing Summary & Sentiment
Reasoning
Letter
VIA EDGAR United States Securities Division of Corporation Finance Attention: Ms. Suzanne Hayes Adial Pharmaceuticals, Inc. Registration Statement on Form S-1 Submitted June 11, 2018 CIK No. 0001513525
Dear Ms. Hayes:
On behalf of our client, Adial Pharmaceuticals, Inc. (the “Company”), we submit this letter in response to the comment the Company received from the staff (the “Staff”) of the Securities and Exchange Commission in its June 21, 2018 letter to the Company relating to the above-referenced Registration Statement on Form S-1 (the “Registration Statement”).
Set forth below in bold is the comment the Company received from the Staff in its June 21, 2018 letter and immediately following the comment is the Company’s response to that comment.
1. Tell us your consideration of ASC 730-10-55-2i in recognizing costs associated with the validation of a patent within Research and development expenses. In your response, tell us the amount you have recorded as Research and development expenses related to patent validation.
Response: The Company respectfully acknowledges the Staff’s comment. After giving consideration to ASC 730-10-55-2i, the Company has revised its classification of expenses related to patent validation from Research and development expenses to General and administrative expenses. This reclassification is reflected in Amendment No. 6 to the Registration Statement on Form S-1, submitted with this letter. The Company will also exclude such expenses, if any, from Research and development expense classification in future filings.
Expenses related to patent validation in the three months ended March 31, 2018 total $112,597. Such costs commenced in Quarter 1, 2018 and there were no expenses related to patent validation incurred or recorded for the years ended December 31, 2016 or 2017.
* * *
If you have any questions or need additional information, please contact the undersigned at (516) 496-2223 or (212) 907-6457.
Sincerely,
/s/
Leslie Marlow
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filename1.htm
The
Chrysler Building
405
Lexington Avenue, 26th Floor
New
York, New York 10174
Telephone
(212) 907-6457
Facsimile:
(212) 208-4657
June
25, 2018
VIA
EDGAR
United
States Securities
and
Exchange Commission
Division of Corporation Finance
100
F Street, N.E.
Mail Stop 4720
Washington, D.C. 20549
Attention: Ms. Suzanne Hayes
Re:
Adial
Pharmaceuticals, Inc.
Registration
Statement on Form S-1
Submitted
June 11, 2018
CIK
No. 0001513525
Dear
Ms. Hayes:
On behalf of our client,
Adial Pharmaceuticals, Inc. (the “Company”), we submit this letter in response to the comment the Company received
from the staff (the “Staff”) of the Securities and Exchange Commission in its June 21, 2018 letter to the Company
relating to the above-referenced Registration Statement on Form S-1 (the “Registration Statement”).
Set
forth below in bold is the comment the Company received from the Staff in its June 21, 2018 letter and immediately following the
comment is the Company’s response to that comment.
1.
Tell
us your consideration of ASC 730-10-55-2i in recognizing costs associated with the validation of a patent within Research
and development expenses. In your response, tell us the amount you have recorded as Research and development expenses related
to patent validation.
Response:
The Company respectfully acknowledges the Staff’s comment. After giving consideration to ASC 730-10-55-2i, the Company has
revised its classification of expenses related to patent validation from Research and development expenses to General and administrative
expenses. This reclassification is reflected in Amendment No. 6 to the Registration Statement on Form S-1, submitted with this
letter. The Company will also exclude such expenses, if any, from Research and development expense classification in future filings.
Expenses
related to patent validation in the three months ended March 31, 2018 total $112,597. Such costs commenced in Quarter 1,
2018 and there were no expenses related to patent validation incurred or recorded for the years ended December 31, 2016 or
2017.
*
* *
If
you have any questions or need additional information, please contact the undersigned at (516) 496-2223 or (212) 907-6457.
Sincerely,
/s/
Leslie Marlow
Leslie
Marlow
cc:
William B.
Stilley
Chief Executive
Officer of ADial Pharmaceuticals, Inc.
Joseph Truluck
Chief Financial
Officer of ADial Pharmaceuticals, Inc.