SEC Comment Letter for PALVELLA THERAPEUTICS, INC. (PVLA) (CIK 0001583648) (PVLA) — Jan 6, 2014
PALVELLA THERAPEUTICS, INC. (PVLA) (CIK 0001583648)
Date: Jan. 6, 2014 · CIK: 0001583648 · Accession: 0000000000-14-000600
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 6, 2013
Letter
January 6, 2014 Via E -mail Aleksandrs Sviks Marika Inc. Chief Executive Officer 2360 C orporate Circle , Suite 400 Henderson, NV 89074
Re: Marika Inc. Amendment No. 3 to Registration Statement on Form S -1 Filed December 11 , 2013 File No. 333 -190728
Dear Mr. Sviks:
We have reviewed your registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so that we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe a n amendment is appropriate, please tell us why in your response.
Dilution, page 14
1. We note that you have updated your dilution table to utilize the September 30, 2013 financial statements. However, you do not appear to have updated the net tangible book value per common share before the offering. Please show us your calculations for all amounts in this table.
Exhibit 23.2
2. We note your response to comment 2 from our letter dated December 6, 2013 and your updated auditors’ consent. We note that your au ditor consent s to the use of his opinion dated July 19, 2013 on the financial statements as of September 30, 2013 and for the period from inception May 24, 2013 to September 30, 2013 . The auditors’ opinion dated July 19, 2013 was on the financial statements as of June 30, 2013 and for the period from inception May 24, 2013 to June 30, 2013. Please revise.
Aleksandrs Sviks Marika Inc. January 6, 2014 Page 2
Please contact Elizabeth Sellars , Staff Accountant , at (202) 551 -3348 or Jason Niethamer, Assistant Chief Accountant at (202) 551 -3855 if you have any questions regarding comments on the financial statements and related matters. Please contact Scott Anderegg, Staff Attorney , at (202) 551 -3342, or me at (202) 551 -3720 with any other questions.
Sincerely,
/s/ Mara L. Ransom
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January 6, 2014 Via E -mail Aleksandrs Sviks Marika Inc. Chief Executive Officer 2360 C orporate Circle , Suite 400 Henderson, NV 89074 Re: Marika Inc. Amendment No. 3 to Registration Statement on Form S -1 Filed December 11 , 2013 File No. 333 -190728 Dear Mr. Sviks: We have reviewed your registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so that we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe a n amendment is appropriate, please tell us why in your response. Dilution, page 14 1. We note that you have updated your dilution table to utilize the September 30, 2013 financial statements. However, you do not appear to have updated the net tangible book value per common share before the offering. Please show us your calculations for all amounts in this table. Exhibit 23.2 2. We note your response to comment 2 from our letter dated December 6, 2013 and your updated auditors’ consent. We note that your au ditor consent s to the use of his opinion dated July 19, 2013 on the financial statements as of September 30, 2013 and for the period from inception May 24, 2013 to September 30, 2013 . The auditors’ opinion dated July 19, 2013 was on the financial statements as of June 30, 2013 and for the period from inception May 24, 2013 to June 30, 2013. Please revise. Aleksandrs Sviks Marika Inc. January 6, 2014 Page 2 Please contact Elizabeth Sellars , Staff Accountant , at (202) 551 -3348 or Jason Niethamer, Assistant Chief Accountant at (202) 551 -3855 if you have any questions regarding comments on the financial statements and related matters. Please contact Scott Anderegg, Staff Attorney , at (202) 551 -3342, or me at (202) 551 -3720 with any other questions. Sincerely, /s/ Mara L. Ransom Mara L. Ransom Assistant Director