SEC Company Response from Corbus Pharmaceuticals Holdings, Inc. (CRBP) (CIK 0001595097) (CRBP) — Sep 30, 2014
Corbus Pharmaceuticals Holdings, Inc. (CRBP) (CIK 0001595097)
Date: Sept. 30, 2014 · CIK: 0001595097 · Accession: 0001144204-14-058614
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File numbers found in text: 333-198563
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CORRESP
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Steven M. Skolnick
Partner
1251 Avenue of the Americas
New York, NY 10020
T 973 597 2476
F 973 597 2477
sskolnick@lowenstein.com
September 30, 2014
U.S. Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Re:
Corbus Pharmaceuticals Holdings, Inc.
Registration Statement on Form S-1
Filed September 3, 2014
File No. 333-198563
Ladies and Gentlemen:
On behalf of Corbus Pharmaceuticals
Holdings, Inc. (the “Company”), we are hereby responding to the letter, dated September 23, 2014 (the “Comment
Letter”), from Jeffrey P. Riedler, Assistant Director of the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”), regarding the Company’s Registration Statement on Form S-1, submitted on September
3, 2014 (the “Registration Statement”). In response to the Comment Letter and to update certain information in the
Registration Statement, the Company is submitting the Amendment No. 1 to the Registration Statement with the Commission (the “Amendment”).
For ease of reference,
set forth below are the comments of the Staff with respect to the Registration Statement, as reflected in the Comment Letter. The
Company’s response is set forth below each comment. Capitalized terms used herein have the meanings set forth in the Registration
Statement unless defined herein.
The Company has authorized
us to respond to the Comment Letter as follows:
Prospectus Summary
Our Pipeline, page 3
1. We note your response to our prior comment 1. Please disclose the information contained in your
response in your prospectus. Specifically, please disclose that you believe you are able rely on all prior non-clinical and Phase
1 clinical data generated by the prior licensee based on the pre-IND meeting you held with the FDA on October 26, 2012, and disclose
that the FDA first required you to conduct a rat chronic toxicology study, which you have completed. If that toxicology study is
one of the studies referenced on page 47, please clarify disclosure to indicate this fact.
Response: The
Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 3 and 47 in response
to the Staff’s comment.
Any questions regarding
the contents of this letter, the Registration Statement, or the Amendment should be addressed to the undersigned at (973) 597-2476.
Very truly yours,
/s/ Steven M. Skolnick
Steven M. Skolnick
Enclosures
cc: Sean Moran
Mark Tepper