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CORRESP Filing

Can-Fite BioPharma Ltd.
Date: July 17, 2025 · CIK: 0001536196 · Accession: 0001213900-25-065120

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File numbers found in text: 001-36203

Date
July 17, 2025
Author
/s/ Motti Farbstein
Form
CORRESP
Company
Can-Fite BioPharma Ltd.

Letter

Division of Corporation Finance Office of Life Sciences 100 F Street, N.E. Washington, D.C. 20549 Attention: Tracie Mariner Jenn Do Can-Fite BioPharma Ltd. Form 20-F for Fiscal Year Ended December 31, 2024 File No. 001-36203

Re:

Dear Ms. Mariner and Ms. Do:

On behalf of Can-Fite BioPharma Ltd. (the " Company "), we are writing to submit the Company's response to the comment of the staff (the " Staff ") of the Division of Corporation Finance of the Securities and Exchange Commission (the " Commission ") dated June 17, 2025, relating to the above referenced Annual Report on Form 20-F (File No. 001-36203) filed by the Company on April 14, 2025 (the " Form 20-F ").

For ease of review, we have set forth below the numbered comment of your letter and the Company's response thereto. Capitalized terms used herein but not defined herein have the meanings given to such terms in the Form 20-F.

Form 20-F for Fiscal Year Ended December 31, 2024

Operating and Financial Review and Prospects

Research and Development, page 97

1. We note from your pipeline chart, on page 47, that Piclidenoson and Namodenoson are each in clinical development for two or more indications. In future filings, please provide revised disclosure in your table of gross direct project costs to include, during each year presented, the costs incurred for each of your main projects by indication. If you do not track your research and development costs by indication, disclose that fact, and explain why not. Include draft disclosure with your response.

Response : In response to the Staff's comment, the Company confirms that, in future filings, it will provide revised disclosure in its table of gross direct project costs to include, during each year presented, the costs incurred for each of its main projects by indication. A draft of the revised pipeline chart that the Company plans to include in future filings is set forth below.

($ in thousands)

[Interim Period to be

Costs Since

Year Ended December 31,

Included

Project

if Applicable]

Inception

Piclidenoson

- Psoriasis

2,354

1,444

- Lowe syndrome

-

-

-

- Dogs osteoarthritis

-

-

-

- Pre clinical & API

2,790

1,471

Namodenoson

- Liver cancer

1,274

1,755

1,990

- Pancreatic cancer

-

-

- MASH

1,225

1,230

- Pre clinical & API

1,282

-

3,883

2,989

3,389

CF602 (erectile dysfunction)

-

-

Other projects

-

-

-

Total gross direct project costs (1)

6,179

4,460

3,949

(1) Does not include indirect project costs and overhead, such as payroll and related expenses (including stock-based compensation), facilities, depreciation and impairment of intellectual property, which are included in total research and development expenses in our financial statements.

Please contact me at +972 39241114 if you have any questions or require any additional information in connection with this letter or the Company's submission of its Form 20-F.

Sincerely,
/s/ Motti Farbstein

Show Raw Text
CORRESP
 1
 filename1.htm

 July 17, 2025

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Life Sciences
100 F Street, N.E.
Washington, D.C. 20549

 Attention:
 Tracie Mariner

 Jenn Do

 Re:

 Can-Fite BioPharma Ltd.
 Form 20-F for Fiscal Year Ended December 31, 2024
 File No. 001-36203

 Dear Ms. Mariner and Ms. Do:

 On behalf of Can-Fite BioPharma
Ltd. (the " Company "), we are writing to submit the Company's response to the comment of the staff (the " Staff ")
of the Division of Corporation Finance of the Securities and Exchange Commission (the " Commission ")
dated June 17, 2025, relating to the above referenced Annual Report on Form 20-F (File No. 001-36203) filed by the Company on April 14,
2025 (the " Form 20-F ").

 For ease of review, we have
set forth below the numbered comment of your letter and the Company's response thereto. Capitalized terms used herein but not defined
herein have the meanings given to such terms in the Form 20-F.

 Form 20-F for Fiscal Year Ended December 31, 2024

 Operating and Financial Review and Prospects

 Research and Development, page 97

 1. We note from your pipeline chart, on page
47, that Piclidenoson and Namodenoson are each in clinical development for two or more indications. In future filings, please provide
revised disclosure in your table of gross direct project costs to include, during each year presented, the costs incurred for each of
your main projects by indication. If you do not track your research and development costs by indication, disclose that fact, and explain
why not. Include draft disclosure with your response.

 Response : In response to the Staff's comment, the Company
confirms that, in future filings, it will provide revised disclosure in its table of gross direct project costs to include, during each
year presented, the costs incurred for each of its main projects by indication. A draft of the revised pipeline chart that the Company
plans to include in future filings is set forth below.

 ($ in thousands)

 [Interim Period to be

 Costs
Since

 Year Ended December 31,

 Included

 Project

 2022

 2023

 2024

 if Applicable]

 Inception

 Piclidenoson

 - Psoriasis

 2,354

 1,444

 550

 - Lowe syndrome

 -

 -

 -

 - Dogs osteoarthritis

 -

 -

 -

 - Pre clinical & API

 436

 27

 10

 2,790

 1,471

 560

 Namodenoson

 - Liver cancer

 1,274

 1,755

 1,990

 - Pancreatic cancer

 -

 -

 169

 - MASH

 827

 1,225

 1,230

 - Pre clinical & API

 1,282

 9

 -

 3,883

 2,989

 3,389

 CF602 (erectile dysfunction)

 6

 -

 -

 Other projects

 -

 -

 -

 Total gross direct project costs (1)

 6,179

 4,460

 3,949

 (1) Does not include indirect project
costs and overhead, such as payroll and related expenses (including stock-based compensation), facilities, depreciation and impairment
of intellectual property, which are included in total research and development expenses in our financial statements.

 Please contact me at +972
39241114 if you have any questions or require any additional information in connection with this letter or the Company's submission
of its Form 20-F.

 Sincerely,

 /s/ Motti Farbstein

 Chief Executive Officer and Chief Financial Officer