SEC Comment Letter for ARTELO BIOSCIENCES, INC. (ARTL) (CIK 0001621221) (ARTL) — May 1, 2018
ARTELO BIOSCIENCES, INC. (ARTL) (CIK 0001621221)
Date: May 1, 2018 · CIK: 0001621221 · Accession: 0000000000-18-013497
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-222756
Letter
Mail Stop 3561 May 1 , 2018 Gregory Gorgas Chief Executive Officer Artelo Biosciences, Inc. 888 Prospect Street, Suite 210 La Jolla, CA 92037
Re: Artelo Biosciences, Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed April 17 , 2018 File No. 333-222756
Dear Mr. Gorgas:
We have reviewed your amended registration statement and have the following comments. In some of our comments, 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 providing the requested inform ation. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment s to your filings and the information you provide in respon se to these comments, we may have additional comments.
Exhibit 10.20
1. We note you entered into a contract effective January 18, 2018 which requires you to reimburse the Foundation for all patent costs incurred pursuant to Section 6.1 of the Stony Brook Agreement, including certain accrued patent costs in the amount of $170,109.93 as per Section 6.2 of such agreement . Please tell us and disclose how you accounted for your obligation for these accrued patent costs in your February 28, 2018 financial state ments , including where you recorded the offsetting entry. Please also tell us how you will account for future patent costs under this agreement. Please provide your basis in GAAP for your accounting.
Gregory Gorgas Artelo Biosciences, Inc. May 1 , 2018 Page 2
You may contact Courtney Haseley, Staff Attorney, a t 202 -551-7689, or me at 202 -551- 3720 with any questions.
Sincerely,
/s/ Mara L. R ansom
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Mail Stop 3561 May 1 , 2018 Gregory Gorgas Chief Executive Officer Artelo Biosciences, Inc. 888 Prospect Street, Suite 210 La Jolla, CA 92037 Re: Artelo Biosciences, Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed April 17 , 2018 File No. 333-222756 Dear Mr. Gorgas: We have reviewed your amended registration statement and have the following comments. In some of our comments, 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 providing the requested inform ation. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment s to your filings and the information you provide in respon se to these comments, we may have additional comments. Exhibit 10.20 1. We note you entered into a contract effective January 18, 2018 which requires you to reimburse the Foundation for all patent costs incurred pursuant to Section 6.1 of the Stony Brook Agreement, including certain accrued patent costs in the amount of $170,109.93 as per Section 6.2 of such agreement . Please tell us and disclose how you accounted for your obligation for these accrued patent costs in your February 28, 2018 financial state ments , including where you recorded the offsetting entry. Please also tell us how you will account for future patent costs under this agreement. Please provide your basis in GAAP for your accounting. Gregory Gorgas Artelo Biosciences, Inc. May 1 , 2018 Page 2 You may contact Courtney Haseley, Staff Attorney, a t 202 -551-7689, or me at 202 -551- 3720 with any questions. Sincerely, /s/ Mara L. R ansom Mara L. Ransom Assistant Director Office of Consumer Products cc: Marty Waters, Esq. Wilson Sonsini Goodrich & Rosati PC