SEC Company Response from Enlivex Ltd. (ENLV) (CIK 0001596812) (ENLV) — Apr 7, 2014
Enlivex Ltd. (ENLV) (CIK 0001596812)
Date: April 7, 2014 · CIK: 0001596812 · Accession: 0001144204-14-021279
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-193824
Letter
Via EDGAR Securities and Exchange Commission Division of Corporation Finance Re: Bio Blast Pharma Ltd. Amendment No. 1 to Registration Statement on Form F-1 Filed March 17, 2014 File No. 333-193824
Dear Mr. Riedler:
The purpose of this letter is to respond to your letter of March 27, 2014 regarding the above amended registration statement. For your convenience, your comments appear in italics, followed by our responses. We are concurrently filing via EDGAR Amendment No. 2 to the Form F-1. Page references in our response are to Amendment No. 2.
General
1. We note your response to our prior comment 4. For the first graphic on the page after the prospectus cover page, we do not find the context you provided to make the map sufficiently clear to an investor. Specifically, while most of the pinpoints on the map reference a specific institution, the pinpoints for Germany and China are much more general. Without further context, it is unclear why “Absorption Systems” and “Protein labs” would be considered “centers of excellence.” In addition, you have not described your “operation mode” or the nature of collaboration. Please remove this graphic.
We have removed the first graphic on the page after the prospectus cover page.
2. For the second graphic on the page before the table of contents, we note your reference to a Phase 2 clinical trial for SCA3 anticipated in Q3 2014. Please be advised that including reference in a pipeline table to anticipated clinical trials is inappropriate. We also note you have not provided any context or definitions for the terms used in the graphic. Please eliminate the product pipeline table in its entirety. In this regard, we note a similar chart appears on page 2 with context and definitions to enable a prospective investor to understand the presentation.
We have removed the second graphic on the page before the table of contents.
3. We note your response to our prior comment 5. However, we do not find all of the images in your registration statement to be easily readable. Specifically, all of the images on page 66 appear to contain writing that is illegible in their current format. Please remove the images contained on page 66.
We have removed the images contained on page 66.
Business
Product Candidates – Disease background, rationale for treatment…, page 62
4. We note your response to our prior comment 21. However, although you reference the prevalence of many diseases in several different geographic locations, you have not provided a numerical estimate of the number of people for each geographic location that are affected by such disease. For example, you state on page 64 that OPMD “is more prevalent among people of French Canadian origin residing in Canada and in the U.S.,” but you do not include a numerical estimate of the number of people in Canada who are affected by the disease. Please revise your discussion of market potential for each disease to include an estimated number of people affected for each geographical location mentioned.
We have revised our disclosure on pages 62-69 of Amendment No. 2 to include for each disease an estimated number of people affected for each geographical location.
* * *
We appreciate your comments and welcome the opportunity to discuss with you our responses provided above. Please call our attorney, Shy Baranov (617) 338-2932 of Zysman, Aharoni, Gayer and Sullivan & Worcester LLP, if you have any questions or require additional information.
Sincerely,
Bio Blast Pharma Ltd.
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BIO BLAST PHARMA LTD.
35 Ahad Ha’am Street
Tel Aviv 6520206 Israel
April 7, 2014
Via EDGAR
Jeffrey P. Riedler, Assistant Director
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Re: Bio Blast Pharma Ltd.
Amendment No. 1 to Registration Statement on
Form F-1
Filed March 17, 2014
File No. 333-193824
Dear Mr. Riedler:
The purpose of this letter is to respond to your letter of March
27, 2014 regarding the above amended registration statement. For your convenience, your comments appear in italics, followed by
our responses. We are concurrently filing via EDGAR Amendment No. 2 to the Form F-1. Page references in our response are to Amendment
No. 2.
General
1. We note your response to our prior comment 4. For the
first graphic on the page after the prospectus cover page, we do not find the context you provided to make the map sufficiently
clear to an investor. Specifically, while most of the pinpoints on the map reference a specific institution, the pinpoints for
Germany and China are much more general. Without further context, it is unclear why “Absorption Systems” and “Protein
labs” would be considered “centers of excellence.” In addition, you have not described your “operation
mode” or the nature of collaboration. Please remove this graphic.
We have removed the first graphic on the page after the prospectus
cover page.
2. For the second graphic on the page before the table of
contents, we note your reference to a Phase 2 clinical trial for SCA3 anticipated in Q3 2014. Please be advised that including
reference in a pipeline table to anticipated clinical trials is inappropriate. We also note you have not provided any context or
definitions for the terms used in the graphic. Please eliminate the product pipeline table in its entirety. In this regard, we
note a similar chart appears on page 2 with context and definitions to enable a prospective investor to understand the presentation.
We have removed the second graphic on the page before the table
of contents.
3. We note your response to our prior comment 5. However,
we do not find all of the images in your registration statement to be easily readable. Specifically, all of the images on page
66 appear to contain writing that is illegible in their current format. Please remove the images contained on page 66.
We have removed the images contained on page 66.
Business
Product Candidates – Disease background, rationale for treatment…, page 62
4. We note your response to our prior comment 21. However,
although you reference the prevalence of many diseases in several different geographic locations, you have not provided a numerical
estimate of the number of people for each geographic location that are affected by such disease. For example, you state on page
64 that OPMD “is more prevalent among people of French Canadian origin residing in Canada and in the U.S.,” but you
do not include a numerical estimate of the number of people in Canada who are affected by the disease. Please revise your discussion
of market potential for each disease to include an estimated number of people affected for each geographical location mentioned.
We have revised our disclosure on pages 62-69 of Amendment No.
2 to include for each disease an estimated number of people affected for each geographical location.
* * *
We appreciate your comments and welcome
the opportunity to discuss with you our responses provided above. Please call our attorney, Shy Baranov (617) 338-2932 of Zysman,
Aharoni, Gayer and Sullivan & Worcester LLP, if you have any questions or require additional information.
Sincerely,
Bio Blast Pharma Ltd.
By: /s/ Udi Gilboa
Name: Udi Gilboa
Title: Chief Financial Officer
cc, with a marked copy of Amendment No. 2:
Christina De Rosa
Shy Baranov, Zysman, Aharoni, Gayer and Sullivan & Worcester
LLP
Oded Har-Even, Zysman, Aharoni, Gayer and Sullivan & Worcester
LLP
Joseph Walsh, Troutman Sanders LLP