SEC Comment Letter 0000000000-25-002356 to Omada Health, Inc. (OMDA)
Omada Health, Inc.
Date: March 3, 2025 · CIK: 0001611115 · Accession: 0000000000-25-002356
AI Filing Summary & Sentiment
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Letter
March 3, 2025 Sean Duffy Chief Executive Officer Omada Health, Inc. 500 Sansome Street, Suite 200 San Francisco, CA 94111 Re:Omada Health, Inc. Amendment No. 3 to Draft Registration Statement on Form S-1 Submitted February 14, 2025 CIK No. 0001611115 Dear Sean Duffy: We have reviewed your amended draft registration statement and have the following comments. 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 a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to this letter and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 3 to Draft Registration Statement on Form S-1 Business Omada GLP-1 Care Tracks, page 136 1.We note your disclosure that "[m]embers in the Enhanced GLP-1 Care Track reported a 12% average increase in self-efficacy at week 16 compared to the time of enrollment, using a brief weight loss self-efficacy scale developed and validated by an independent academic research team, reflecting improved self-confidence in members’ ability to lose weight and maintain healthy habits." Please revise to briefly discuss the weight loss self-efficacy scale, clarify the time period of the participation study and explain how it was validated by an independent academic research team. We note your disclosure on page 138 that "[f]rom late February through May 2024, all 2.
March 3, 2025 Page 2 members in Omada for Prevention & Weight Health and Omada for Hypertension that had enrolled at least two weeks prior and no more than six months prior were offered the opportunity to receive GLP-1 therapy discontinuation program support through the GLP-1 Care Track", and that "[t]his retrospective analysis reviewed data received directly through participation in the program from all such members that voluntarily opted into receiving GLP-1 discontinuation program support..." Please revise to disclose the number of participants that enrolled in the discontinuation program. Please contact Julie Sherman at 202-551-3640 or Li Xiao at 202-551-4391 if you have questions regarding comments on the financial statements and related matters. Please contact Juan Grana at 202-551-6034 or Lauren Nguyen at 202-551-3642 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc:Kathleen M. Wells, Esq.
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March 3, 2025
Sean Duffy
Chief Executive Officer
Omada Health, Inc.
500 Sansome Street, Suite 200
San Francisco, CA 94111
Re:Omada Health, Inc.
Amendment No. 3 to Draft Registration Statement on Form S-1
Submitted February 14, 2025
CIK No. 0001611115
Dear Sean Duffy:
We have reviewed your amended draft registration statement and have the following
comments.
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 a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 3 to Draft Registration Statement on Form S-1
Business
Omada GLP-1 Care Tracks, page 136
1.We note your disclosure that "[m]embers in the Enhanced GLP-1 Care Track reported
a 12% average increase in self-efficacy at week 16 compared to the time of
enrollment, using a brief weight loss self-efficacy scale developed and validated by an
independent academic research team, reflecting improved self-confidence in
members’ ability to lose weight and maintain healthy habits." Please revise to briefly
discuss the weight loss self-efficacy scale, clarify the time period of the participation
study and explain how it was validated by an independent academic research team.
We note your disclosure on page 138 that "[f]rom late February through May 2024, all 2.
March 3, 2025
Page 2
members in Omada for Prevention & Weight Health and Omada for Hypertension that
had enrolled at least two weeks prior and no more than six months prior were offered
the opportunity to receive GLP-1 therapy discontinuation program support through the
GLP-1 Care Track", and that "[t]his retrospective analysis reviewed data received
directly through participation in the program from all such members that voluntarily
opted into receiving GLP-1 discontinuation program support..." Please revise to
disclose the number of participants that enrolled in the discontinuation program.
Please contact Julie Sherman at 202-551-3640 or Li Xiao at 202-551-4391 if you have
questions regarding comments on the financial statements and related matters. Please contact
Juan Grana at 202-551-6034 or Lauren Nguyen at 202-551-3642 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Kathleen M. Wells, Esq.