SEC Comment Letter for RELMADA THERAPEUTICS, INC. (RLMD) (CIK 0001553643) (RLMD) — Mar 1, 2013
RELMADA THERAPEUTICS, INC. (RLMD) (CIK 0001553643)
Date: March 1, 2013 · CIK: 0001553643 · Accession: 0000000000-13-011335
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-184881
Referenced dates: February 26, 2013, February 8, 2013
Letter
March 1 , 2013 Via E -mail Michael Garcia President and Chief Executive Officer Camp Nine, Inc. 1065 Kawaiahao St. Ste 2207 Honolulu, Hawaii 96814
Re: Camp Nine, Inc . Amendment No s. 2 and 3 to Registration Statement on Form S-1 Filed February 15 , 2013 and February 26, 2013 File No. 333-184881
Dear Mr. Garcia :
We have reviewed your responses to the comments in our letter dated February 8, 2013 and have the following additional comments.
While we believe that our three surfboard models to date perform well, page 7
1. Please revise to remove the first part of the heading or provide support for your belief. Also, please provide support for your st atement that you have not received any negative feedback from your buyers on existing models or revise to remove. Please also indicate in the revised risk factor that you have only manufactured a limited number of surfboards so far to date.
Because we ar e currently considered a “shell company”, page 12
2. We note that the revised language of this risk factor as indicated by your letter dated February 26, 2013 does not reconcile with the revised language on page 12. Please reinstate the first two sentences of the risk factor as included in the prior amendment, and as shown in your letter dated February 26, 2013, which attempts to show the risk factor as it should now read after the most recent changes were made to the disclosure.
Products and Pricing, page 20
3. We note your disclosure that you are currently designing another surfboard called the Classic. Please expand to discuss any material steps necessary in order for you to begin offering this surfboard for sale, if applicable. If any additional financin g will be need to continue to develop this surfboard for sale, also disclose that, if applicable. If any needed financing for this endeavor is not currently available, please make that clear as well.
Michael Garcia Camp Nine, Inc. March 1 , 2013 Page 2
We urge all persons who are responsible for the accur acy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 1933 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relatin g to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
You may contact Effie Simpson at (202) 551 -3346 or Linda Cvrkel at (202) 551 -3313 if you have questions regarding comments on the financia l statements and related matters. Please contact John Stickel at (202) 551 -3324 or me at (202) 551 -3210 with any other questions.
Sincerely,
/s/ Susan Block
Show Raw Text
March 1 , 2013
Via E -mail
Michael Garcia
President and Chief Executive Officer
Camp Nine, Inc.
1065 Kawaiahao St. Ste 2207
Honolulu, Hawaii 96814
Re: Camp Nine, Inc .
Amendment No s. 2 and 3 to Registration Statement on Form S-1
Filed February 15 , 2013 and February 26, 2013
File No. 333-184881
Dear Mr. Garcia :
We have reviewed your responses to the comments in our letter dated February 8, 2013
and have the following additional comments.
While we believe that our three surfboard models to date perform well, page 7
1. Please revise to remove the first part of the heading or provide support for your belief.
Also, please provide support for your st atement that you have not received any negative
feedback from your buyers on existing models or revise to remove. Please also indicate
in the revised risk factor that you have only manufactured a limited number of surfboards
so far to date.
Because we ar e currently considered a “shell company”, page 12
2. We note that the revised language of this risk factor as indicated by your letter dated
February 26, 2013 does not reconcile with the revised language on page 12. Please
reinstate the first two sentences of the risk factor as included in the prior amendment, and
as shown in your letter dated February 26, 2013, which attempts to show the risk factor as
it should now read after the most recent changes were made to the disclosure.
Products and Pricing, page 20
3. We note your disclosure that you are currently designing another surfboard called the
Classic. Please expand to discuss any material steps necessary in order for you to begin
offering this surfboard for sale, if applicable. If any additional financin g will be need to
continue to develop this surfboard for sale, also disclose that, if applicable. If any needed
financing for this endeavor is not currently available, please make that clear as well.
Michael Garcia
Camp Nine, Inc.
March 1 , 2013
Page 2
We urge all persons who are responsible for the accur acy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 1933 and
all applicable Securities Act rules require. Since the company and its management are in
possession of all facts relatin g to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
You may contact Effie Simpson at (202) 551 -3346 or Linda Cvrkel at (202) 551 -3313 if
you have questions regarding comments on the financia l statements and related matters. Please
contact John Stickel at (202) 551 -3324 or me at (202) 551 -3210 with any other questions.
Sincerely,
/s/ Susan Block
Susan Block
Attorney -Advisor
cc: Puoy Premsrirut , Esq.