SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Company Response from Jaguar Health, Inc. (JAGX) (CIK 0001585608) (JAGX) — Jun 30, 2017

Jaguar Health, Inc. (JAGX) (CIK 0001585608)
Date: June 30, 2017 · CIK: 0001585608 · Accession: 0001104659-17-043051

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 333-217364

Referenced dates: June 30, 2017

Date
June 30, 2017
Author
/s/ Michael S. Lee
Form
CORRESP
Company
Jaguar Health, Inc. (JAGX) (CIK 0001585608)

Letter

VIA EDGAR U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attention: Suzanne Hayes Assistant Director Re: Jaguar Animal Health, Inc. Amendment No. 4 to Registration Statement on Form S-4 Filed June 28, 2017 File No. 333-217364

Dear Ms. Hayes:

On behalf of our client, Jaguar Animal Health, Inc., a Delaware corporation (the “Company”), we hereby provide a response to a comment (the “Comment”) of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) issued in its letter dated June 30, 2017 (the “Letter”) regarding the Company’s above-referenced Registration Statement on Form S-4 (the “Registration Statement”). Contemporaneous with this filing, the Company is filing on the EDGAR system an Amendment No. 5 to the Registration Statement on Form S-4 (the “S-4/A”) reflecting the response of the Company below.

The Company’s response is numbered to correspond to the Comment as numbered in the Letter. For your convenience, the Comment contained in the Letter has been restated in bold below in its entirety, with the Company’s corresponding response set forth immediately under such comment. In the response below, page number references are to the S-4/A.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Overview, page 153

1. Please refer to your response to comment four. Please revise your disclosure on pages 169 and F-39 to clarify that you also received $1,048,689 designated as reimbursement for past product development expense.

Response: The Company respectfully acknowledges the Staff’s Comment and has revised the disclosure on pages 169 and F-39 of the S-4/A to clarify that it also received $1,048,689 designated as reimbursement for past product development expense.

[remainder of page intentionally left blank]

NEW YORK · LONDON · HONG KONG · CHICAGO · WASHINGTON, D.C. · BEIJING · PARIS · LOS ANGELES · SAN FRANCISCO · PHILADELPHIA · SHANGHAI · PITTSBURGH · HOUSTON SINGAPORE · MUNICH · ABU DHABI · PRINCETON · NORTHERN VIRGINIA · WILMINGTON · SILICON VALLEY · DUBAI · CENTURY CITY · RICHMOND · GREECE ·KAZAKHSTAN

Should you have any questions concerning any of the foregoing, please contact me by telephone at (212) 530-5586.

Sincerely,
/s/ Michael S. Lee

Show Raw Text
CORRESP
1
filename1.htm

1510 Page Mill   Road, Suite 110
  Palo Alto, CA 94304

+1 650 352 0500

Fax +1 650 352 0699

reedsmith.com

June 30, 2017

VIA EDGAR

U.S. Securities and Exchange Commission
 100 F Street, N.E.
 Washington, D.C. 20549

Attention:                 Suzanne Hayes
 Assistant Director

Re:                             Jaguar Animal Health, Inc.
 Amendment No. 4 to Registration Statement on Form S-4
 Filed June 28, 2017
 File No. 333-217364

Dear Ms. Hayes:

On behalf of our client, Jaguar Animal Health, Inc., a Delaware corporation (the “Company”), we hereby provide a response to a comment (the “Comment”) of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) issued in its letter dated June 30, 2017 (the “Letter”) regarding the Company’s above-referenced Registration Statement on Form S-4 (the “Registration Statement”).  Contemporaneous with this filing, the Company is filing on the EDGAR system an Amendment No. 5 to the Registration Statement on Form S-4 (the “S-4/A”) reflecting the response of the Company below.

The Company’s response is numbered to correspond to the Comment as numbered in the Letter.  For your convenience, the Comment contained in the Letter has been restated in bold below in its entirety, with the Company’s corresponding response set forth immediately under such comment.  In the response below, page number references are to the S-4/A.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Overview, page 153

1.                                      Please refer to your response to comment four. Please revise your disclosure on pages 169 and F-39 to clarify that you also received $1,048,689 designated as reimbursement for past product development expense.

Response:  The Company respectfully acknowledges the Staff’s Comment and has revised the disclosure on pages 169 and F-39 of the S-4/A to clarify that it also received $1,048,689 designated as reimbursement for past product development expense.

[remainder of page intentionally left blank]

NEW YORK · LONDON · HONG KONG · CHICAGO · WASHINGTON, D.C. · BEIJING · PARIS · LOS ANGELES · SAN FRANCISCO · PHILADELPHIA · SHANGHAI · PITTSBURGH · HOUSTON SINGAPORE · MUNICH · ABU DHABI · PRINCETON · NORTHERN VIRGINIA · WILMINGTON · SILICON VALLEY · DUBAI · CENTURY CITY · RICHMOND · GREECE ·KAZAKHSTAN

Should you have any questions concerning any of the foregoing, please contact me by telephone at (212) 530-5586.

Sincerely,

/s/   Michael S. Lee

Michael   S. Lee

Reed   Smith LLP

Cc:          Lisa A. Conte, Jaguar Animal Health, Inc., by e-mail
 Karen Wright, Jaguar Animal Health, Inc., by e-mail
 Dan Harris, BDO USA, LLP, by e-mail
 Donald C. Reinke, Reed Smith LLP, by e-mail

2