SEC Comment Letter for Atara Biotherapeutics, Inc. (ATRA) (CIK 0001604464) (ATRA) — Jul 2, 2015
Atara Biotherapeutics, Inc. (ATRA) (CIK 0001604464)
Date: July 2, 2015 · CIK: 0001604464 · Accession: 0000000000-15-034769
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File numbers found in text: 333-205347
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July 2, 2015 Via E -mail Isaac E. Ciechanover, M.D. Chief Executive Officer Atara Biotherapeutics, Inc. 701 Gateway Blvd., Suite 200 South San Francisco, California 94080 Re: Atara Biotherapeutics, Inc. Registration Statement on Form S-1 Filed June 29, 2015 File No. 333-205347 Dear Dr. Ciechanover : We have limited our review of your registration statement to the issue addressed in our comment. If you do not believe our comment appl ies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in a response. Exhibit Index 1. We note that you are submitting an application for confidential treatment for several of the exhibits include d with this registration statement. We will not be in a position to grant effectiveness to your filing until such time as comments to the confidential treatment application, if any, have been cleared. We urge all persons who are responsible for the accur acy 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 relatin g 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 pro vide 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 taking any action with respect to the filing; Isaac C. Ciechanover, M.D. Atara Biotherapeutics, Inc. July 2, 2015 Page 2 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 the disclosure in the filing; and 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 Secu rities 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 amendment prior to the requested eff ective date of the registration statement. Please contact S cot Foley at (202) 551 -3383, Daniel Greenspan at (202) 551 -3623 or me at (202) 551 -3715 with any other questions. Sincerely, /s/ Daniel Greenspan for Jeffrey P. Riedler Assistant Director cc: Kenneth L. Gue rnsey Jodie M. Bourdet Carlton Fleming Cooley LLP 101 California Street, 5th Floor San Francisco, California 94111