SEC Company Response from Eton Pharmaceuticals, Inc. (ETON) (CIK 0001710340) (ETON) — May 15, 2020
Eton Pharmaceuticals, Inc. (ETON) (CIK 0001710340)
Date: May 15, 2020 · CIK: 0001710340 · Accession: 0001493152-20-009223
AI Filing Summary & Sentiment
File numbers found in text: 001-38738
Referenced dates: May 5, 2020
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CORRESP
1
filename1.htm
Croke
Fairchild Morgan & Beres LLC
180
North La Salle Street, Suite 2750
Chicago,
Illinois 60601
May
15, 2020
Iboyla
Ignat
Division
of Corporation Finance
Office
of Life Sciences
Securities
and Exchange Commission
Via
email to ignati@sec.gov
Re:
Eton
Pharmaceuticals, Inc.
Form
10-K for the fiscal year ended December 31, 2019
Filed
March 5, 2020
File
No. 001-38738
Dear
Ms. Ignat:
We
are counsel to Eton Pharmaceuticals, Inc. (the “Company”) and have received your letter dated May 5, 2020 regarding
the two comments referred to below to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2019.
The Company’s responses are also below.
Item1.
Business
Licensing
Arrangements, page 6.
1.
The
Company will provide disclosure of the requested royalty rates in an amendment to the Form 10-K.
Exhibits
31.1 and 31.2, page 87.
2.
The
Company will update the Section 302 Certifications to include the introductory language in paragraph 4 referring to its internal
control over financial reporting as well as paragraph 4(b) regarding design of the Company’s internal control over financial
reporting.
Pursuant
to your request, the Company will prepare and file an abbreviated amendment to the Form 10-K consisting of a cover page, explanatory
note, signature page and updated Section 302 Certifications. The Company will file the Amendment on or before May 21, 2020.
Please
contact the undersigned with any questions.
Sincerely,
Croke
Fairchild Morgan & Beres LLC
/s/
Geoffrey R. Morgan
gmorgan@crokefairchild.com
cc:
W. Wilson Troutman