SEC Comment Letter for Galmed Pharmaceuticals Ltd. (GLMD) (CIK 0001595353) (EOCN) — Apr 3, 2015
Galmed Pharmaceuticals Ltd. (GLMD) (CIK 0001595353)
Date: April 3, 2015 · CIK: 0001595353 · Accession: 0000000000-15-019532
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-203133
Letter
April 3 , 2015 Via U.S. Mail Josh Blacher Chief Financial Officer Galmed Pharmaceuticals Ltd. 8 Shaul Hamelech Blvd. Amot Mishpat Bldg. Tel Aviv, Israel 64733
Re: Galmed Pharmaceuticals Ltd. Registration Statement on Form F -3 Filed March 31, 2015 File No. 333-203133
Dear Mr. Blacher :
We have limited our review of your registra tion statement to the issue we have addressed in the comment below.
1. We are currently processing your pending request for confidential treatment . Please be advised that we will not be in a position to declare this registration statement effective until we re solve all issues concerning the confidential treatment request.
We urge all person s who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Notwithstanding our comment , in the event you request acceleration of the effective date of the pending registration statement , please provide a written statement from the company acknowledging that:
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from tak ing any action with respect to the filing;
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of th e disclosure in the filing; and
Josh Blacher Galmed Pharmaceuticals Ltd. April 3, 2015 Page 2
the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please refer to Rules 460 and 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in the above registration statement. Please allow adequate time for us to review any amend ment prior to the requested effective date of the registration statement.
You may contact P reston Brewer at (202) 551 -3969 , Bryan Pitko at (202) 551 -3203 or me at (202) 551 -3715 with any questions.
Sincerely,
/s/ Bryan J. Pitko for
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April 3 , 2015 Via U.S. Mail Josh Blacher Chief Financial Officer Galmed Pharmaceuticals Ltd. 8 Shaul Hamelech Blvd. Amot Mishpat Bldg. Tel Aviv, Israel 64733 Re: Galmed Pharmaceuticals Ltd. Registration Statement on Form F -3 Filed March 31, 2015 File No. 333-203133 Dear Mr. Blacher : We have limited our review of your registra tion statement to the issue we have addressed in the comment below. 1. We are currently processing your pending request for confidential treatment . Please be advised that we will not be in a position to declare this registration statement effective until we re solve all issues concerning the confidential treatment request. We urge all person s who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Notwithstanding our comment , in the event you request acceleration of the effective date of the pending registration statement , please provide a written statement from the company acknowledging that: should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from tak ing any action with respect to the filing; the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of th e disclosure in the filing; and Josh Blacher Galmed Pharmaceuticals Ltd. April 3, 2015 Page 2 the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please refer to Rules 460 and 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in the above registration statement. Please allow adequate time for us to review any amend ment prior to the requested effective date of the registration statement. You may contact P reston Brewer at (202) 551 -3969 , Bryan Pitko at (202) 551 -3203 or me at (202) 551 -3715 with any questions. Sincerely, /s/ Bryan J. Pitko for Jeffrey P. Riedler Assistant Director cc: Via E -Mail Andrew P. Gilbert, Esq. DLA Piper LLP (US)