SEC Comment Letter 0000000000-23-008812 to Cibus, Inc. (CBUS) (CIK 0001705843) (CBUS)
Cibus, Inc. (CBUS) (CIK 0001705843)
Date: Aug. 14, 2023 · CIK: 0001705843 · Accession: 0000000000-23-008812
AI Filing Summary & Sentiment
File numbers found in text: 001-38161
Letter
United States securities and exchange commission logo August 14, 2023 Rory Riggs Chief Executive Officer Cibus, Inc. 6455 Nancy Ridge Drive San Diego, CA 92121 Re:Cibus, Inc. Form 8-K/A filed June 29, 2023 File No. 001-38161 Dear Rory Riggs: We have reviewed your July 26, 2023 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 18, 2023 letter. Form 8-K/A filed June 29, 2023 Exhibit 99.7 Unaudited Pro Forma Combined Financial Information for Cibus Global, LLC and Calyxt, Inc. Introductory Note, page 1 1.We note your response to prior comment 1. You indicate that upon closing of the Transactions, Cibus Global met the definition of a variable interest entity (a "VIE"). Please tell us whether Cibus Global met the definition of a VIE prior to the closing of the Transactions. If so, please provide us with your analysis. You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 you have questions.
FirstName LastNameRory Riggs Comapany NameCibus, Inc. August 14, 2023 Page 2 FirstName LastName Rory Riggs Cibus, Inc. August 14, 2023 Page 2 Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
August 14, 2023
Rory Riggs
Chief Executive Officer
Cibus, Inc.
6455 Nancy Ridge Drive
San Diego, CA 92121
Re:Cibus, Inc.
Form 8-K/A filed June 29, 2023
File No. 001-38161
Dear Rory Riggs:
We have reviewed your July 26, 2023 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
July 18, 2023 letter.
Form 8-K/A filed June 29, 2023
Exhibit 99.7 Unaudited Pro Forma Combined Financial Information for Cibus Global, LLC and
Calyxt, Inc.
Introductory Note, page 1
1.We note your response to prior comment 1. You indicate that upon closing of the
Transactions, Cibus Global met the definition of a variable interest entity (a "VIE").
Please tell us whether Cibus Global met the definition of a VIE prior to the closing of the
Transactions. If so, please provide us with your analysis.
You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 you
have questions.
FirstName LastNameRory Riggs
Comapany NameCibus, Inc.
August 14, 2023 Page 2
FirstName LastName
Rory Riggs
Cibus, Inc.
August 14, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services