SEC Comment Letter for Summit Therapeutics Inc. (SMMT) (CIK 0001599298) (SMMT) — Jan 23, 2015
Summit Therapeutics Inc. (SMMT) (CIK 0001599298)
Date: Jan. 23, 2015 · CIK: 0001599298 · Accession: 0000000000-15-003357
AI Filing Summary & Sentiment
Letter
January 22, 2015 Via E -Mail Erik Ostrowski Chief Financial Officer Summit Corporation plc 85b Park Drive Milton Park, Abingdon Oxfordshire OX14 4RY United Kingdom
Re: Summit Corporation plc Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted January 13, 2015 CIK No. 0001599298
Dear Mr. Ostrowski:
We have reviewed your amended draft registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumst ances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may hav e additional comments.
Principal Shareholders, page 135
1. Please include a statement that provides the number of record holders in the United States and the corresponding percentage of your outstanding stock currently held in the United States. See Item 7.A.2 of Form 20 -F.
Erik Ostrowski Summit Corporation plc January 22, 2015 Page 2
Description of Share Capital, page 137
2. To the extent practicable, please replace your qualifying references to the Companies Act of 2006 and “Uncertificated Securities Regulations 2001” with substantive disclosure. Your use of the term “subject to” often implies additional rights, privileges, or restrictions that are not explained in your descriptions.
Please contact Corey Jennings in the Office of International Corporate Finance at (202) 551-3258 with any questions regardin g the above comments. You may contact Vanessa Robertson at (202) 551 -3649 or Mark Brunhofer at (202) 551 -3638 if you have questions regarding comments on the financial statements and related matters. Please contact Preston Brewer at (202) 551 -3969 or me at (202) 551 -3715 with any other questions.
Sincerely,
/s/ Jeffrey P. Riedler
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January 22, 2015 Via E -Mail Erik Ostrowski Chief Financial Officer Summit Corporation plc 85b Park Drive Milton Park, Abingdon Oxfordshire OX14 4RY United Kingdom Re: Summit Corporation plc Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted January 13, 2015 CIK No. 0001599298 Dear Mr. Ostrowski: We have reviewed your amended draft registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumst ances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may hav e additional comments. Principal Shareholders, page 135 1. Please include a statement that provides the number of record holders in the United States and the corresponding percentage of your outstanding stock currently held in the United States. See Item 7.A.2 of Form 20 -F. Erik Ostrowski Summit Corporation plc January 22, 2015 Page 2 Description of Share Capital, page 137 2. To the extent practicable, please replace your qualifying references to the Companies Act of 2006 and “Uncertificated Securities Regulations 2001” with substantive disclosure. Your use of the term “subject to” often implies additional rights, privileges, or restrictions that are not explained in your descriptions. Please contact Corey Jennings in the Office of International Corporate Finance at (202) 551-3258 with any questions regardin g the above comments. You may contact Vanessa Robertson at (202) 551 -3649 or Mark Brunhofer at (202) 551 -3638 if you have questions regarding comments on the financial statements and related matters. Please contact Preston Brewer at (202) 551 -3969 or me at (202) 551 -3715 with any other questions. Sincerely, /s/ Jeffrey P. Riedler Jeffrey P. Riedler Assistant Director cc: Via E -Mail Brian A. Johnson, Esq. David E. Redlick, Esq. Wilmer Cutler Pickering Hale and Dorr LLP