SEC Comment Letter for Quoin Pharmaceuticals, Ltd. (QNRX) (CIK 0001671502) (QNRX) — Jun 17, 2016
Quoin Pharmaceuticals, Ltd. (QNRX) (CIK 0001671502)
Date: June 17, 2016 · CIK: 0001671502 · Accession: 0000000000-16-080812
AI Filing Summary & Sentiment
Reasoning
Letter
June 16, 2016 Via E -mail Dr. Shai Yarkoni Chief Executive Officer Cellect Biomed Ltd. 23 Hata’as Street Kfar Saba, Israel 44425
Re: Cellect Biomed Ltd. Amendment No. 1 Draft Registration Statement on Form F -1 Submitted May 25 , 2016 CIK No. 0001671502
Dear Dr. Yarkoni :
We have reviewed your amended draft registration statement and have the following comment. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, ple ase tell us why in your response.
After reviewing the information you provide in response to this comment and your amended draft registration statement or filed registration statement, we may have additional comments.
Business Raw Materials and Supp liers, page 6 6
1. We note your response to prior comment 7. Given your statements that the number of third party suppliers with the necessary manufacturing and regulatory expertise is limited; a significant delay in the supply of key materials for a preclin ical or clinical trial could considerably delay completion of your clinical trials, testing and potential approval of your product candidate; and your stated strategy of achieving a relatively quick validation, it appears that the identity of your supplier may be material information. Please identify the supplier or provide us with additional support for your determination that the identity is not material.
Dr. Shai Yarkoni Cellect Biomed Ltd. June 16, 2016 Page 2
You may contact Keira Nakada at (202) 551 -3659 or Lisa Vanjoske at (202) 551 -3614 if you have qu estions regarding comments on the financial statements and related matters. Please contact Scot Foley at (202) 551 -3383 or me at (202) 551 -3675 with any other questions.
Sincerely,
Suzanne Hayes
Assistant Director
Show Raw Text
June 16, 2016
Via E -mail
Dr. Shai Yarkoni
Chief Executive Officer
Cellect Biomed Ltd.
23 Hata’as Street
Kfar Saba, Israel 44425
Re: Cellect Biomed Ltd.
Amendment No. 1
Draft Registration Statement on Form F -1
Submitted May 25 , 2016
CIK No. 0001671502
Dear Dr. Yarkoni :
We have reviewed your amended draft registration statement and have the following
comment. Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration statement
on EDGAR. If you do not believe our comment applies to your facts and circumstances or do
not believe an amendment is appropriate, ple ase tell us why in your response.
After reviewing the information you provide in response to this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Business
Raw Materials and Supp liers, page 6 6
1. We note your response to prior comment 7. Given your statements that the number of third
party suppliers with the necessary manufacturing and regulatory expertise is limited; a
significant delay in the supply of key materials for a preclin ical or clinical trial could
considerably delay completion of your clinical trials, testing and potential approval of your
product candidate; and your stated strategy of achieving a relatively quick validation, it
appears that the identity of your supplier may be material information. Please identify the
supplier or provide us with additional support for your determination that the identity is not
material.
Dr. Shai Yarkoni
Cellect Biomed Ltd.
June 16, 2016
Page 2
You may contact Keira Nakada at (202) 551 -3659 or Lisa Vanjoske at (202) 551 -3614 if you
have qu estions regarding comments on the financial statements and related matters. Please contact
Scot Foley at (202) 551 -3383 or me at (202) 551 -3675 with any other questions.
Sincerely,
Suzanne Hayes
Assistant Director
cc: Oded Har -Even, Esq.
Zysman, Aharoni, Gayer and Sullivan & Worcester LLP