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SEC Comment Letter for Summit Therapeutics Inc. (SMMT) (CIK 0001599298) (SMMT) — Apr 2, 2026

Summit Therapeutics Inc. (SMMT) (CIK 0001599298)
Date: April 2, 2026 · CIK: 0001599298 · Accession: 0000000000-26-003340

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File numbers found in text: 001-36866

Date
April 2, 2026
Author
Division of
Form
UPLOAD
Company
Summit Therapeutics Inc. (SMMT) (CIK 0001599298)

Letter

Re: Summit Therapeutics Inc. Form 10-K for the fiscal year ended December 31, 2025 Filed February 23, 2026 File No. 001-36866 Dear Manmeet Soni:

April 2, 2026

Manmeet Soni Chief Operating Officer and Chief Financial Officer Summit Therapeutics Inc. 601 Brickell Key Drive, Suite 1000 Miami, FL 33131

We have limited our review of your filing to the financial statements and related disclosures and have the following comments.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 10-K for the fiscal year ended December 31, 2025 Product Pipeline, page 4

1. Regarding the disclosure on page 6 about collaborating with multiple institutions globally and your investigator-sponsored trials program across several disease areas, please tell us and revise your future filings, beginning with your March 31, 2026 Form 10-Q, to specifically address the collaborations entered into with GSK and Revolution Medicines and provide the significant related terms of each, including any consideration exchanged thus far. We note these collaborations were entered into prior to the filing of your Form 10-K and are highlighted in your fourth quarter of 2025 earnings release, earnings call and accompanying slides/presentation. Management s Discussion and Analysis of Financial Condition and Results of Operations, page Results of Operations, page 73

2. Your research and development (R&D) expenses increased more then 220% during 2025 and also made up half of your $1.08 billion net loss for the year ended December 31, April 2, 2026 Page 2

2025 and 75% of your $221.3 million net loss for the year ended December 31, 2024. For 2025, oncology clinical trial related costs made up half of your R&D expenses, yet the explanation provided for the 164% increase in these costs during the year appears limited, i.e., you attribute the large change primarily to new clinical trials added and current clinical trials expanded. Given: i) the significance of oncology clinical trial related costs to consolidated R&D and, in turn, the significance of consolidated R&D to your results of operations; ii) the multiple clinical trials which you are currently conducting; and iii) the multiple indications for which you are currently evaluating ivonescimab, please tell us whether your oncology clinical trial related costs can be further disaggregated by indication, trial or some other level and revise future filings as applicable. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Jenn Do at 202-551-3743 or Daniel Gordon at 202-551-3486 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Life
Sciences

Show Raw Text
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<TEXT>
 April 2, 2026

Manmeet Soni
Chief Operating Officer and Chief Financial Officer
Summit Therapeutics Inc.
601 Brickell Key Drive, Suite 1000
Miami, FL 33131

 Re: Summit Therapeutics Inc.
 Form 10-K for the fiscal year ended December 31, 2025
 Filed February 23, 2026
 File No. 001-36866
Dear Manmeet Soni:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the fiscal year ended December 31, 2025
Product Pipeline, page 4

1. Regarding the disclosure on page 6 about collaborating with multiple
institutions
 globally and your investigator-sponsored trials program across several
disease areas,
 please tell us and revise your future filings, beginning with your March
31, 2026 Form
 10-Q, to specifically address the collaborations entered into with GSK
and Revolution
 Medicines and provide the significant related terms of each, including
any consideration
 exchanged thus far. We note these collaborations were entered into prior
to the filing of
 your Form 10-K and are highlighted in your fourth quarter of 2025
earnings release,
 earnings call and accompanying slides/presentation.
Management s Discussion and Analysis of Financial Condition and Results of
Operations, page
70
Results of Operations, page 73

2. Your research and development (R&D) expenses increased more then 220%
during 2025
 and also made up half of your $1.08 billion net loss for the year ended
December 31,
 April 2, 2026
Page 2

 2025 and 75% of your $221.3 million net loss for the year ended December
31, 2024.
 For 2025, oncology clinical trial related costs made up half of your R&D
expenses, yet
 the explanation provided for the 164% increase in these costs during the
year appears
 limited, i.e., you attribute the large change primarily to new clinical
trials added and
 current clinical trials expanded. Given: i) the significance of oncology
clinical trial
 related costs to consolidated R&D and, in turn, the significance of
consolidated R&D to
 your results of operations; ii) the multiple clinical trials which you
are currently
 conducting; and iii) the multiple indications for which you are
currently evaluating
 ivonescimab, please tell us whether your oncology clinical trial related
costs can be
 further disaggregated by indication, trial or some other level and
revise future filings as
 applicable.
 In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

 Please contact Jenn Do at 202-551-3743 or Daniel Gordon at 202-551-3486
with any
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
</TEXT>
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