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Correspondence 0001193125-24-275538 from Cue Biopharma, Inc. (CUE)

Cue Biopharma, Inc.
Date: Dec. 11, 2024 · CIK: 0001645460 · Accession: 0001193125-24-275538

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File numbers found in text: 001-38327

Referenced dates: December 5, 2024

Date
December 11, 2024
Author
/s/ Daniel R. Passeri
Form
CORRESP
Company
Cue Biopharma, Inc.

Letter

December 11, 2024

By Electronic Submission

Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, DC 20549

Attention: Lynn Dicker and Eric Atallah

Re: Cue Biopharma, Inc.

Form 10-K for Fiscal Year Ended December 31, 2023

File No. 001-38327

Ladies and Gentlemen:

Cue Biopharma, Inc. (the “Company” or “we”) is responding to the comments of the staff (the “Staff”) of the Securities and Exchange Commission contained in the Staff’s letter dated December 5, 2024 (the “Comment Letter”), relating to the above referenced Form 10-K for the fiscal year ended December 31, 2023. For convenience, the heading and text of the Staff’s numbered comment from the Comment Letter is set forth below, followed by the Company’s response.

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.

Response: We respectfully acknowledge the Staff’s comments. We will include such information in our future filings.

Page 2

If you have any further questions or comments, or if you require any additional information, please contact the undersigned by telephone at (617) 949-2680. Thank you for your assistance.

Very truly yours,
/s/ Daniel R. Passeri

Show Raw Text
CORRESP
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filename1.htm

CORRESP

 December 11, 2024

By Electronic Submission

 Securities and Exchange
Commission

 Division of Corporation Finance

 Office of Life
Sciences

 100 F Street, N.E.

 Washington, DC 20549

Attention: Lynn Dicker and Eric Atallah

Re:
 Cue Biopharma, Inc.

Form 10-K for Fiscal Year Ended December 31, 2023

File No. 001-38327

Ladies and Gentlemen:

 Cue Biopharma, Inc. (the
“Company” or “we”) is responding to the comments of the staff (the “Staff”) of the Securities and Exchange Commission contained in the Staff’s letter dated December 5, 2024 (the
“Comment Letter”), relating to the above referenced Form 10-K for the fiscal year ended December 31, 2023. For convenience, the heading and text of the Staff’s numbered comment from
the Comment Letter is set forth below, followed by the Company’s response.

 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.

 Response: We respectfully acknowledge the Staff’s comments. We will include such information in our future
filings.

Page 2

 If you have any further questions or comments, or if you require any additional information, please contact
the undersigned by telephone at (617) 949-2680. Thank you for your assistance.

 Very truly yours,

/s/ Daniel R. Passeri

Daniel R. Passeri

Chief Executive Officer

 ___________________

cc:
 Kerri-Ann Millar, Chief Financial Officer, Cue Biopharma, Inc.

 Cynthia Mazareas, Wilmer Cutler Pickering Hale and Dorr LLP