SEC Comment Letter for Aditxt, Inc. (ADTX) (CIK 0001726711) (ADTX) — Feb 13, 2020
Aditxt, Inc. (ADTX) (CIK 0001726711)
Date: Feb. 13, 2020 · CIK: 0001726711 · Accession: 0000000000-20-001397
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-235933
Letter
February 13, 2020 Amro Albanna Chief Executive Officer ADiTx Therapeutics, Inc. 11161 Anderson Street, Suite 105-10014 Loma Linda, CA 92354 Re:ADiTx Therapeutics, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed February 7, 2020 File No. 333-235933 Dear Mr. Albanna: We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Registration Statement on Form S-1/A, filed on February 7, 2020 Use of Proceeds, page 27 1.We note that you entered into bridge loans with principal amounts of $50,000 and $80,000 in January 2020, which are due on the earlier of April 19, 2020 and April 29, 2020, respectively, or ten days after the close of the company's initial public offering. If you will be using the proceeds of this offering to discharge this indebtedness, please revise your disclosure in this section pursuant to Instruction 4 of Item 504 of Regulation S-K. Recent Developments, page 42 2.We note your entry into a patent and licensing agreement on February 3, 2020. Please revise to disclose the identity of the counter party to the agreement, the royalty term and the agreement's termination provisions.
FirstName LastNameAmro Albanna Comapany NameADiTx Therapeutics, Inc. February 13, 2020 Page 2 FirstName LastName Amro Albanna ADiTx Therapeutics, Inc. February 13, 2020 Page 2 You may contact Ameen Hamady at 202-551-3891 or Daniel Gordon at 202-551-3486 if you have questions regarding comments on the financial statements and related matters. Please contact Paul Fischer at 202-551-3415 or Irene Paik at 202-551-6553 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Richard Friedman, Esq.
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February 13, 2020
Amro Albanna
Chief Executive Officer
ADiTx Therapeutics, Inc.
11161 Anderson Street, Suite 105-10014
Loma Linda, CA 92354
Re:ADiTx Therapeutics, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed February 7, 2020
File No. 333-235933
Dear Mr. Albanna:
We have reviewed your amended registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-1/A, filed on February 7, 2020
Use of Proceeds, page 27
1.We note that you entered into bridge loans with principal amounts of $50,000 and $80,000
in January 2020, which are due on the earlier of April 19, 2020 and April 29, 2020,
respectively, or ten days after the close of the company's initial public offering. If you
will be using the proceeds of this offering to discharge this indebtedness, please revise
your disclosure in this section pursuant to Instruction 4 of Item 504 of Regulation S-K.
Recent Developments, page 42
2.We note your entry into a patent and licensing agreement on February 3, 2020. Please
revise to disclose the identity of the counter party to the agreement, the royalty term and
the agreement's termination provisions.
FirstName LastNameAmro Albanna
Comapany NameADiTx Therapeutics, Inc.
February 13, 2020 Page 2
FirstName LastName
Amro Albanna
ADiTx Therapeutics, Inc.
February 13, 2020
Page 2
You may contact Ameen Hamady at 202-551-3891 or Daniel Gordon at 202-551-3486 if
you have questions regarding comments on the financial statements and related matters. Please
contact Paul Fischer at 202-551-3415 or Irene Paik at 202-551-6553 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Richard Friedman, Esq.