SEC Comment Letter 0000000000-23-002277 to BriaCell Therapeutics Corp. (BCTX)
BriaCell Therapeutics Corp.
Date: March 8, 2023 · CIK: 0001610820 · Accession: 0000000000-23-002277
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File numbers found in text: 001-40101
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United States securities and exchange commission logo
March 8, 2023
Gadi Levin
Chief Financial Officer
BriaCell Therapeutics Corp.
Suite 300 - 235 15th Street
West Vancouver, BC V7T2X1
Re:BriaCell Therapeutics Corp.
Form 10-K for the Fiscal Year Ended July 31, 2022
Filed October 28, 2022
File No. 001-40101
Dear Gadi Levin:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to the comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to the comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended July 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Research Costs, page 64
1.Please disclose the costs incurred during each period presented for each of your key
research and development projects. If you do not track your research and development
costs by project, please disclose that fact and explain why you do not maintain and
evaluate research and development costs by project. Provide other quantitative or
qualitative disclosure that provides more transparency as to the type of research and
development expenses incurred (i.e. by nature or type of expense) which should reconcile
to total research and development expense on the Statements of Operations.
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
FirstName LastNameGadi Levin
Comapany NameBriaCell Therapeutics Corp.
March 8, 2023 Page 2
FirstName LastName
Gadi Levin
BriaCell Therapeutics Corp.
March 8, 2023
Page 2
absence of action by the staff.
You may contact Christine Torney at (202) 551-3652 or Vanessa Robertson at (202) 551-
3649 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences