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UPLOAD Filing

RenovoRx, Inc.
Date: July 10, 2025 · CIK: 0001574094 · Accession: 0000000000-25-007249

Internal Controls Financial Reporting Regulatory Compliance

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File numbers found in text: 001-40738

Date
July 10, 2025
Author
Division of
Form
UPLOAD
Company
RenovoRx, Inc.

Letter

Re: RenovoRx, Inc. Form 10-K for the fiscal year ended December 31, 2024 Form 10-Q for the quarterly period ended March 31, 2025 File No. 001-40738 Dear Ronald B. Kocak:

July 10, 2025

Ronald B. Kocak VP Controller and Principal Accounting Officer RenovoRx, Inc. 2570 West El Camino Real, Suite 320 Mountain View, California 94040

We have limited our review of your filing to the financial statements and related disclosures and have the following comments.

Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 10-K for the fiscal year ended December 31, 2024 Controls and Procedures, page 87

1. We note your annual report does not include a report of management s assessment regarding internal control over financial reporting ("ICFR") due to a transition period established by rules of the Securities and Exchange Commission for newly public companies. Since you were required to file or filed an annual report for the prior year, it appears you are required to report on your management s assessment of ICFR. Please confirm that you will revise your future filings to provide management's conclusion regarding the effectiveness of your internal control over financial reporting. Refer to Item 308(a) of Regulation S-K. Form 10-Q for the quarterly period ended March 31, 2025 Item 2: Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations July 10, 2025 Page 2

Research and Development, page 21

2. You disclose that you expect research and development expenses to increase during 2025 as you continue your commercialization activities for your RenovoCath device. Please tell us the extent to which the amounts reported as research and development expense during the recent periods related to commercialization activities, and explain how commercialization costs meet the definition of research and development expense under ASC 730-10-20. In closing, 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.

Please contact Jenn Do at 202-551-3743 or Vanessa Robertson at 202-551-3649 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Life
Sciences

Show Raw Text
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<TEXT>
 July 10, 2025

Ronald B. Kocak
VP Controller and Principal Accounting Officer
RenovoRx, Inc.
2570 West El Camino Real, Suite 320
Mountain View, California 94040

 Re: RenovoRx, Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 Form 10-Q for the quarterly period ended March 31, 2025
 File No. 001-40738
Dear Ronald B. Kocak:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the fiscal year ended December 31, 2024
Controls and Procedures, page 87

1. We note your annual report does not include a report of management s
assessment
 regarding internal control over financial reporting ("ICFR") due to a
transition period
 established by rules of the Securities and Exchange Commission for newly
public
 companies. Since you were required to file or filed an annual report for
the prior year,
 it appears you are required to report on your management s assessment
of ICFR.
 Please confirm that you will revise your future filings to provide
management's
 conclusion regarding the effectiveness of your internal control over
financial
 reporting. Refer to Item 308(a) of Regulation S-K.
Form 10-Q for the quarterly period ended March 31, 2025
Item 2: Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Results of Operations
 July 10, 2025
Page 2

Research and Development, page 21

2. You disclose that you expect research and development expenses to
increase during
 2025 as you continue your commercialization activities for your
RenovoCath device.
 Please tell us the extent to which the amounts reported as research and
development
 expense during the recent periods related to commercialization
activities, and explain
 how commercialization costs meet the definition of research and
development
 expense under ASC 730-10-20.
 In closing, 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.

 Please contact Jenn Do at 202-551-3743 or Vanessa Robertson at
202-551-3649 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
</TEXT>
</DOCUMENT>