SEC Comment Letter for CollPlant Biotechnologies Ltd (CLGN) (CIK 0001631487) (CLGN) — Nov 1, 2016
CollPlant Biotechnologies Ltd (CLGN) (CIK 0001631487)
Date: Nov. 1, 2016 · CIK: 0001631487 · Accession: 0000000000-16-099242
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3030 November 1, 2016 Yehiel Tal Chief Executive Officer CollPlant Holdings Ltd. 3 Sapir Street, Weizmann Science Park Ness -Ziona 74140, Israel
Re: CollPlant Holdings Ltd. Registration Statement on Form F -1 Filed October 21, 2016 File No. 333 -214188
Dear Mr. Tal :
We have reviewed your 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 information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is a ppropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments.
Market for Bone Repair Products, page 97
1. We not e that you have included in this section disclosure regarding Bioventus’ estimate of the market size for the bone repair products. Please tell us whether you commissioned this market data from Bioventus and provide us your analysis of whether Rule 436 requires that you file the consent of Bioventus with regard to this disclosure.
Corporate Governance Practices, page 119
2. Please tell us why you removed the disclosure that appeared in this section under the headings “Nomination of our directors,” “Compensation of officers” and “Independent directors.” in your amendment filed on July 27, 2016.
Yehiel Tal CollPlant Holdings Ltd. November 1 , 2016 Page 2
You may contact Kristin Lochhead at (202) 551 - 3664 or Gary Todd, Senior Accountant, at (202) 551 -3605 if you have ques tions regarding comments on the financial statements and related matters. Please contact Tim Buchmiller at (202) 551 -3635 or Daniel Morris, Special Counsel, at (202) 551 -3314 with any other questions.
Sincerely,
/s/ Daniel Morris for
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Mail Stop 3030 November 1, 2016 Yehiel Tal Chief Executive Officer CollPlant Holdings Ltd. 3 Sapir Street, Weizmann Science Park Ness -Ziona 74140, Israel Re: CollPlant Holdings Ltd. Registration Statement on Form F -1 Filed October 21, 2016 File No. 333 -214188 Dear Mr. Tal : We have reviewed your 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 information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is a ppropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Market for Bone Repair Products, page 97 1. We not e that you have included in this section disclosure regarding Bioventus’ estimate of the market size for the bone repair products. Please tell us whether you commissioned this market data from Bioventus and provide us your analysis of whether Rule 436 requires that you file the consent of Bioventus with regard to this disclosure. Corporate Governance Practices, page 119 2. Please tell us why you removed the disclosure that appeared in this section under the headings “Nomination of our directors,” “Compensation of officers” and “Independent directors.” in your amendment filed on July 27, 2016. Yehiel Tal CollPlant Holdings Ltd. November 1 , 2016 Page 2 You may contact Kristin Lochhead at (202) 551 - 3664 or Gary Todd, Senior Accountant, at (202) 551 -3605 if you have ques tions regarding comments on the financial statements and related matters. Please contact Tim Buchmiller at (202) 551 -3635 or Daniel Morris, Special Counsel, at (202) 551 -3314 with any other questions. Sincerely, /s/ Daniel Morris for Amanda Ravitz Assistant Director Office of Electronics and Machinery cc: Gary M. Emmanuel, Esq. McDermott Will & Emery LLP