SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

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

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 001-38738

Referenced dates: May 5, 2020

Date
December 31, 2019
Author
Croke
Form
CORRESP
Company
Eton Pharmaceuticals, Inc. (ETON) (CIK 0001710340)

Letter

Division of Corporation Finance Office of Life Sciences Securities and Exchange Commission 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

Show Raw Text
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