SEC Comment Letter 0000000000-24-013392 to Cue Biopharma, Inc. (CUE)
Cue Biopharma, Inc.
Date: Dec. 5, 2024 · CIK: 0001645460 · Accession: 0000000000-24-013392
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File numbers found in text: 001-38327
Letter
December 5, 2024 Kerri-Ann Millar Chief Financial Officer Cue Biopharma, Inc. 40 Guest Street Boston, MA 02135 Re:Cue Biopharma, Inc. Form 10-K for Fiscal Year Ended December 31, 2023 File No. 001-38327 Dear Kerri-Ann Millar: We have limited our review of your filings to the financial statements and related disclosures and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2023 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Research and Development, page 99 1.We note from the disclosures on page 5 that you have two oncology drug product candidates, CUE-101 and CUE-102. Please revise future filings to disclose the costs incurred during each period presented for each of your key research and development product candidates. If you do not track your research and development costs by project, disclose that fact and explain why you do not maintain and evaluate research and development costs by project. Also, revise to provide other quantitative and qualitative disclosures that give more transparency as to the type of research and development expenses incurred (i.e., by nature or type of expense) which should reconcile to total research and development expenses on your Statements of Operations.
December 5, 2024 Page 2 In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Lynn Dicker at 202-551-3616 or Eric Atallah at 202-551-3663 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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December 5, 2024
Kerri-Ann Millar
Chief Financial Officer
Cue Biopharma, Inc.
40 Guest Street
Boston, MA 02135
Re:Cue Biopharma, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-38327
Dear Kerri-Ann Millar:
We have limited our review of your filings to the financial statements and related
disclosures and have the following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations
Research and Development, page 99
1.We note from the disclosures on page 5 that you have two oncology drug product
candidates, CUE-101 and CUE-102. Please revise future filings to disclose the costs
incurred during each period presented for each of your key research and development
product candidates. If you do not track your research and development costs by
project, disclose that fact and explain why you do not maintain and evaluate research
and development costs by project. Also, revise to provide other quantitative and
qualitative disclosures that give more transparency as to the type of research and
development expenses incurred (i.e., by nature or type of expense) which should
reconcile to total research and development expenses on your Statements of
Operations.
December 5, 2024
Page 2
In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.
Please contact Lynn Dicker at 202-551-3616 or Eric Atallah at 202-551-3663 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences