SEC Company Response from ADIAL PHARMACEUTICALS, INC. (ADIL) (CIK 0001513525) (AZR) — Jul 3, 2018
ADIAL PHARMACEUTICALS, INC. (ADIL) (CIK 0001513525)
Date: July 3, 2018 · CIK: 0001513525 · Accession: 0001213900-18-008647
AI Filing Summary & Sentiment
File numbers found in text: 333-220368
Referenced dates: July 2, 2018
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CORRESP
1
filename1.htm
HANK
GRACIN†† | PARTNER
LESLIE MARLOW† | PARTNER PATRICK J. EGAN† | PARTNER
† Admitted in New York only
†† Admitted in New York, Florida & Colorado
GRACIN
& MARLOW, LLP
COUNSELLORS
AT LAW
THE CHRYSLER BUILDING
26th FLOOR
405
LEXINGTON AVENUE
NEW
YORK, NEW YORK 10174
(212)
907-6457
FAX (212) 208-4657
www.gracinmarlow.com
IN
BOCA RATON
1825 NW CORPORATE BLVD.
SUITE 110
BOCA RATON, FLORIDA 33431
(561) 237-0804
FAX
(561) 237-0803
WRITER
E-MAIL: lmarlow@gracinmarlow.com
July
3, 2018
VIA
EDGAR
United
States Securities
and Exchange Commission
Division of Corporation Finance
100
F Street, N.E.
Mail Stop 4546
Washington, D.C. 20549
Attention: Suzanne
Hayes, Assistant Director
Office
of Healthcare & Insurance
Re: Adial
Pharmaceuticals, Inc.
Amendment
No. 6 to Registration Statement on Form S-1
Filed
June 26, 2018
File
No. 333-220368
Dear
Ms. Hayes:
On behalf of our client,
Adial Pharmaceuticals, Inc. (the “Company”), we submit this letter in response to a comment from the staff (the
“Staff”) of the United States Securities and Exchange Commission (the “Commission”) contained
in its letter dated July 2, 2018 (the “Comment Letter”), relating to the above-referenced Amendment No. 6 to
Registration Statement on Form S-1. We are concurrently submitting via EDGAR this letter and filing a revised Amendment No. 7 to
Registration Statement on Form S-1 (“Amendment No. 7 Registration Statement”).
Set forth below is the
comment from the Comment Letter, which is immediately followed by the Company’s response in bold and italics font to that
comment, including a cross-reference to the location of changes made in the Amendment No. 7 Registration Statement in response
to the Staff’s comment.
Notes
to Financial Statements
Research
and Development, page F-9
1. Please
revise your accounting policy disclosure here and on page F-30 to reflect your accounting
treatment for patent related costs.
Response:
The Company has revised the accounting policy related to research and development expenses on pages F-9 and F-30.
*
* *
If you have any questions
or need additional information, please contact the undersigned, the Company’s securities counsel, at (516) 496-2223 or (212)
907-6457.
Sincerely,
GRACIN & MARLOW, LLP
/s/ Leslie Marlow
Leslie Marlow
cc: William B. Stilley
Chief Executive Officer, Adial Pharmaceuticals,
Inc.
Joseph Truluck
Chief Financial Officer, Adial Pharmaceuticals,
Inc.