SEC Comment Letter for CollPlant Biotechnologies Ltd (CLGN) (CIK 0001631487) (CLGN) — Dec 19, 2017
CollPlant Biotechnologies Ltd (CLGN) (CIK 0001631487)
Date: Dec. 19, 2017 · CIK: 0001631487 · Accession: 0000000000-17-044248
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3030 December 19, 2017 Yehiel Tal Chief Executive Officer CollPlant Holdings Ltd. 3 Sapir Street, Weizmann Science Park Ness -Ziona 74140, Israel
Re: CollPlant Holdings Ltd. Amendment No. 3 to Registration Statement on Form F -1 Filed November 22, 2017 File No. 333 -214188
Dear Mr. Tal :
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 information . 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 to your registration statement and the information you provide in response to these comments, we may have additional comments.
Results of Opera tions
Revenues, page 77 and page 78
1. We note your disclosure that your revenues increased during the periods presented. Please provide additional detail addressing the reasons for this increase. For example, clarify how your product offerings have changed since the prior period, discuss price and/or volume changes, changes to your distribution, and any other material factors affecting your revenues.
Yehiel Tal CollPlant Holdings Ltd. December 19, 2017 Page 2
You may contact Kristin Lochhead at (202) 551 - 3664 or Gary Todd, Senior Accountant, at (202) 551 -3605 if you have questions 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 December 19, 2017 Yehiel Tal Chief Executive Officer CollPlant Holdings Ltd. 3 Sapir Street, Weizmann Science Park Ness -Ziona 74140, Israel Re: CollPlant Holdings Ltd. Amendment No. 3 to Registration Statement on Form F -1 Filed November 22, 2017 File No. 333 -214188 Dear Mr. Tal : 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 information . 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 to your registration statement and the information you provide in response to these comments, we may have additional comments. Results of Opera tions Revenues, page 77 and page 78 1. We note your disclosure that your revenues increased during the periods presented. Please provide additional detail addressing the reasons for this increase. For example, clarify how your product offerings have changed since the prior period, discuss price and/or volume changes, changes to your distribution, and any other material factors affecting your revenues. Yehiel Tal CollPlant Holdings Ltd. December 19, 2017 Page 2 You may contact Kristin Lochhead at (202) 551 - 3664 or Gary Todd, Senior Accountant, at (202) 551 -3605 if you have questions 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