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Correspondence 0001213900-23-000426 from Hoth Therapeutics, Inc. (HOTH) (CIK 0001711786) (HOTH)

Hoth Therapeutics, Inc. (HOTH) (CIK 0001711786)
Date: Jan. 3, 2023 · CIK: 0001711786 · Accession: 0001213900-23-000426

AI Filing Summary & Sentiment

File numbers found in text: 001-38803

Referenced dates: December 7, 2022

Date
December 31, 2021
Author
Hoth Therapeutics
Form
CORRESP
Company
Hoth Therapeutics, Inc. (HOTH) (CIK 0001711786)

Letter

VIA EDGAR United States Securities and Exchange Commission Attention: Re: Hoth Therapeutics, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed March 30, 2022 File No. 001-38803

Dear Ladies and Gentlemen:

This letter sets forth responses on behalf of Hoth Therapeutics, Inc., a Nevada corporation (the “Company”), to the comments received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in your letter dated December 7, 2022 (“Comment Letter”) regarding the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2021.

For the convenience of the Staff, each comment from the Comment Letter corresponds to the numbered paragraphs in this letter and is restated prior to the response to such comment.

Form 10-K for the Fiscal Year Ended December 31, 2021

Management's Discussion and Analysis of Financial Conditions and Results of Operations

Results of Operations

Research and Development Expenses, page 45

1. Please disclose the costs incurred during each period presented for each of your key research and development projects. If you do not track your research and development costs by project, please disclose that fact and explain why you do not maintain and evaluate research and development costs by project. Provide other quantitative or qualitative disclosure that provides 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 expense on the Statements of Operations.

Response:

The Company intends to include disclosure regarding the costs incurred for each of its key research and development projects, including such quantitative and/or qualitative disclosure that provides more transparency as to the type of research and development expenses incurred, during each of the fiscal years ended December 31, 2022 and 2021 in its Annual Report on Form 10-K for the fiscal year ending December 31, 2022 (the “2022 Annual Report”).

By way of example, the Company intends to include disclosure similar to the below in the 2022 Annual Report for the fiscal years ended December 31, 2022 and 2021.

For the year ended December 31, 2021, research and development expenses were approximately $7.5 million, of which approximately $0.2 million was related to licenses acquired and approximately $7.4 million was related to other research and development expenses. Specifically, during the year ended December 31, 2021, our research and development costs consisted primarily of the following costs for each of our key research and development projects: (i) BioLexa, approximately $1.7 million related to clinical trial costs; (ii) HT-001, approximately $4.1 million related to manufacturing, preclinical and clinical activities; (iii) HT-002, approximately $56,000 related to sponsored research; (iv) HT-003, approximately $0.4 million related to preclinical studies; (v) HT-004, approximately $17,000 related to sponsored research; (vi) HT-006, approximately $51,000 related to sponsored research; (vii) GW breath based diagnostic device, approximately $0.3 million related to research and development with respect to the design of device; and (viii) HT-KIT, approximately $0.4 million related to research and development manufacturing. In addition to the foregoing, we also incurred fees of approximately $0.2 million payable to members of our scientific advisory board for services.

Sincerely,
Hoth Therapeutics,
Inc.

Show Raw Text
CORRESP
1
filename1.htm

HOTH
THERAPEUTICS, INC.

1
Rockefeller Plaza, Suite 1039

New
York, New York 10020

January
3, 2023

VIA
EDGAR

United
States Securities and Exchange Commission

100
F. Street, NE

Washington,
DC 20549

    Attention:

    Vanessa
    Robertson

    Kevin
    W. Vaughn

    Re:
    Hoth Therapeutics, Inc.

    Form 10-K for the Fiscal
    Year Ended December 31, 2021

    Filed March 30, 2022

    File No. 001-38803

Dear
Ladies and Gentlemen:

This
letter sets forth responses on behalf of Hoth Therapeutics, Inc., a Nevada corporation (the “Company”), to the comments received
from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in your letter
dated December 7, 2022 (“Comment Letter”) regarding the Company’s Annual Report on Form 10-K for the fiscal year ended
December 31, 2021.

For
the convenience of the Staff, each comment from the Comment Letter corresponds to the numbered paragraphs in this letter and is restated
prior to the response to such comment.

Form
10-K for the Fiscal Year Ended December 31, 2021

Management's
Discussion and Analysis of Financial Conditions and Results of Operations

Results
of Operations

Research
and Development Expenses, page 45

 1. Please
                                            disclose the costs incurred during each period presented for each of your key research and
                                            development projects. If you do not track your research and development costs by project,
                                            please disclose that fact and explain why you do not maintain and evaluate research and development
                                            costs by project. Provide other quantitative or qualitative disclosure that provides 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 expense on the
                                            Statements of Operations.

Response:

The
Company intends to include disclosure regarding the costs incurred for each of its key research and development projects, including such
quantitative and/or qualitative disclosure that provides more transparency as to the type of research and development expenses incurred,
during each of the fiscal years ended December 31, 2022 and 2021 in its Annual Report on Form 10-K for the fiscal year ending December
31, 2022 (the “2022 Annual Report”).

By
way of example, the Company intends to include disclosure similar to the below in the 2022 Annual Report for the fiscal years ended December
31, 2022 and 2021.

For
the year ended December 31, 2021, research and development expenses were approximately $7.5 million, of which approximately $0.2 million
was related to licenses acquired and approximately $7.4 million was related to other research and development expenses. Specifically,
during the year ended December 31, 2021, our research and development costs consisted primarily of the following costs for each of our
key research and development projects: (i) BioLexa, approximately $1.7 million related to clinical trial costs; (ii) HT-001, approximately
$4.1 million related to manufacturing, preclinical and clinical activities; (iii) HT-002, approximately $56,000 related to sponsored
research; (iv) HT-003, approximately $0.4 million related to preclinical studies; (v) HT-004, approximately $17,000 related to sponsored
research; (vi) HT-006, approximately $51,000 related to sponsored research; (vii) GW breath based diagnostic device, approximately $0.3
million related to research and development with respect to the design of device; and (viii) HT-KIT, approximately $0.4 million related
to research and development manufacturing. In addition to the foregoing, we also incurred fees of approximately $0.2 million payable
to members of our scientific advisory board for services.

    Sincerely,

    Hoth Therapeutics,
    Inc.

    /s/
    Robb Knie

    By:
    Robb Knie

    Title:
    Chief Executive Officer