SEC Comment Letter for SciSparc Ltd. (SPRC) (CIK 0001611746) (SPRC) — Jul 9, 2018
SciSparc Ltd. (SPRC) (CIK 0001611746)
Date: July 9, 2018 · CIK: 0001611746 · Accession: 0000000000-18-020884
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-225745
Letter
July 9, 2018 Ascher Shmulewitz Chief Executive Officer Therapix Biosciences Ltd. 4 Ariel Sharon Street HaShahar Tower, 16th Floor Givatayim 5320047, Israel Re:Therapix Biosciences Ltd. Registration Statement on Form F-3 Response dated June 20, 2018 File No. 333-225745 Dear Dr. Shmulewitz: We have reviewed your response dated July 3, 2018 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 this letter by amending your registration statement and/or providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and/or the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our June 30, 2018 letter. Registration Statement on Form F-3 filed July 3, 2018 Description of Securities, page 8 1.We note your response to our comment that the arbitration provision does not "alter, restrict, limit or effect, prima facie, the rights of an ADS holder or ordinary shareholder of the Company in any way." Please clarify in your analysis whether the provision can result in the board of directors referring a shareholder action under the United States securities laws to arbitration and the procedural protections and substantive remedies that ADS holders and/or ordinary shareholders may have in such event.
FirstName LastNameAscher Shmulewitz Comapany NameTherapix Biosciences Ltd. July 9, 2018 Page 2 FirstName LastName Ascher Shmulewitz Therapix Biosciences Ltd. July 9, 2018 Page 2 Please contact Irene Paik at 202-551-6553 or Erin Jaskot at 202-551-3442 with any questions. Division of Corporation Finance Office of Healthcare & Insurance cc: Jeffrey Schultz
Show Raw Text
July 9, 2018
Ascher Shmulewitz
Chief Executive Officer
Therapix Biosciences Ltd.
4 Ariel Sharon Street
HaShahar Tower, 16th Floor
Givatayim 5320047, Israel
Re:Therapix Biosciences Ltd.
Registration Statement on Form F-3
Response dated June 20, 2018
File No. 333-225745
Dear Dr. Shmulewitz:
We have reviewed your response dated July 3, 2018 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 this letter by amending your registration statement and/or providing the
requested information. If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and/or the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our June 30, 2018 letter.
Registration Statement on Form F-3 filed July 3, 2018
Description of Securities, page 8
1.We note your response to our comment that the arbitration provision does not "alter,
restrict, limit or effect, prima facie, the rights of an ADS holder or ordinary shareholder of
the Company in any way." Please clarify in your analysis whether the provision can result
in the board of directors referring a shareholder action under the United States securities
laws to arbitration and the procedural protections and substantive remedies that ADS
holders and/or ordinary shareholders may have in such event.
FirstName LastNameAscher Shmulewitz
Comapany NameTherapix Biosciences Ltd.
July 9, 2018 Page 2
FirstName LastName
Ascher Shmulewitz
Therapix Biosciences Ltd.
July 9, 2018
Page 2
Please contact Irene Paik at 202-551-6553 or Erin Jaskot at 202-551-3442 with any
questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Jeffrey Schultz