SEC Company Response from Addex Therapeutics Ltd. (ADXN) (CIK 0001574232) (ADXN) — Jan 13, 2020
Addex Therapeutics Ltd. (ADXN) (CIK 0001574232)
Date: Jan. 13, 2020 · CIK: 0001574232 · Accession: 0001104659-20-003569
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-235554
Referenced dates: December 31, 2019
Letter
Joshua A. Kaufman
+1 212 479 6495
josh.kaufman@cooley.com
Via EDGAR
January 13, 2020
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences
100 F Street, N.E.
Washington, D.C. 20549
Attention: Vanessa Robertson
Lisa Vanjoske
Ada D. Sarmento
Mary Beth Breslin
Re: Addex Therapeutics Ltd Registration Statement on Form F-1 Filed on December 17, 2019 and amended on January 13, 2020 No. 333-235554
Ladies and Gentlemen:
On behalf of Addex Therapeutics Ltd (the “Company”), we are providing this letter in response to the comment (the “Comment”) received from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) by letter dated December 31, 2019 with respect to the Company’s Registration Statement on Form F-1 (No. 333-235554), as filed with the Commission on December 17, 2019 (the “Filed Registration Statement”). The Company is concurrently publicly filing Amendment No. 1 to the Filed Registration Statement (“Amendment No. 1”), which includes changes that reflect the Company’s response to the Comment as well as certain other updates. Set forth below is the Company’s response to the Comment. For your convenience, we have incorporated into this response letter the Comment in italics. The page reference in the text of the Company’s response corresponds to the page number in Amendment No. 1.
Registration Statement on Form F-1
Collaboration Agreement with Indivior, page 83
1. We note your revised disclosure in response to our prior comment 5 that you are eligible for a royalty on net sales of applicable products on a country-by-country basis. Please revise your disclosure in this section to provide the royalty term.
Response: In response to the Comment, the Company has revised the disclosure on page 83 of Amendment No. 1 to disclose the royalty term of the Company’s agreement with Indivior.
* * *
Cooley LLP 55 Hudson Yards New York, NY 10001 t: (212) 479-6000 f: (212) 479-6275 cooley.com
Please contact me at (212) 479 6495 with any questions or further comments regarding our responses to the Comment.
Sincerely,
/s/ Joshua A. Kaufman
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CORRESP 1 filename1.htm Joshua A. Kaufman +1 212 479 6495 josh.kaufman@cooley.com Via EDGAR January 13, 2020 U.S. Securities and Exchange Commission Division of Corporation Finance Office of Life Sciences 100 F Street, N.E. Washington, D.C. 20549 Attention: Vanessa Robertson Lisa Vanjoske Ada D. Sarmento Mary Beth Breslin Re: Addex Therapeutics Ltd Registration Statement on Form F-1 Filed on December 17, 2019 and amended on January 13, 2020 No. 333-235554 Ladies and Gentlemen: On behalf of Addex Therapeutics Ltd (the “Company”), we are providing this letter in response to the comment (the “Comment”) received from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) by letter dated December 31, 2019 with respect to the Company’s Registration Statement on Form F-1 (No. 333-235554), as filed with the Commission on December 17, 2019 (the “Filed Registration Statement”). The Company is concurrently publicly filing Amendment No. 1 to the Filed Registration Statement (“Amendment No. 1”), which includes changes that reflect the Company’s response to the Comment as well as certain other updates. Set forth below is the Company’s response to the Comment. For your convenience, we have incorporated into this response letter the Comment in italics. The page reference in the text of the Company’s response corresponds to the page number in Amendment No. 1. Registration Statement on Form F-1 Collaboration Agreement with Indivior, page 83 1. We note your revised disclosure in response to our prior comment 5 that you are eligible for a royalty on net sales of applicable products on a country-by-country basis. Please revise your disclosure in this section to provide the royalty term. Response: In response to the Comment, the Company has revised the disclosure on page 83 of Amendment No. 1 to disclose the royalty term of the Company’s agreement with Indivior. * * * Cooley LLP 55 Hudson Yards New York, NY 10001 t: (212) 479-6000 f: (212) 479-6275 cooley.com Please contact me at (212) 479 6495 with any questions or further comments regarding our responses to the Comment. Sincerely, /s/ Joshua A. Kaufman Joshua A. Kaufman cc: Timothy Dyer, Addex Therapeutics Ltd 2