SEC Comment Letter for Autolus Therapeutics plc (AUTL) (CIK 0001730463) (AUTL) — Apr 9, 2018
Autolus Therapeutics plc (AUTL) (CIK 0001730463)
Date: April 9, 2018 · CIK: 0001730463 · Accession: 0000000000-18-010616
AI Filing Summary & Sentiment
Reasoning
Letter
April 9, 2018 Christian Itin, Ph.D. Chief Executive Officer Autolus Therapeutics Ltd Forest House 58 Wood Lane White City London W12 7RZ United Kingdom Re:Autolus Therapeutics Ltd Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted March 23, 2018 CIK No. 0001730463 Dear Dr. Itin: We have reviewed your amended draft 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 providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. 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 the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 1 to Draft Registration Statement on Form F-1 submitted March 23, 2018 Business Our License Agreement with UCL Business plc, page 135 1.We note your revised disclosure that the sublicensing income payable to UCLB ranges from low-double-digits to mid-single digits in response to our prior comment 9. Please revise your description of the high end of the range to provide a range within ten
FirstName LastNameChristian Itin, Ph.D. Comapany NameAutolus Therapeutics Ltd June 16, 2017 Page 2 FirstName LastName Christian Itin, Ph.D. Autolus Therapeutics Ltd April 9, 2018 Page 2 percentage points. We also note your response that the duration of the royalty term will be subject to a confidential treatment request. Confidential treatment is generally not appropriate for material information such as the royalty term of material contracts. Please revise your disclosure to provide the royalty term of your license agreement with UCLB, or tell us why you believe this information is not material to investors. You may contact Mark Brunhofer at 202-551-3638 or Mary Mast at 202-551-3613 if you have questions regarding comments on the financial statements and related matters. Please contact Irene Paik at 202-551-6553 or Mary Beth Breslin at 202-551-3625 with any other questions. Division of Corporation Finance Office of Healthcare & Insurance cc: Darren DeStefano - Cooley LLP
Show Raw Text
April 9, 2018
Christian Itin, Ph.D.
Chief Executive Officer
Autolus Therapeutics Ltd
Forest House
58 Wood Lane
White City
London W12 7RZ
United Kingdom
Re:Autolus Therapeutics Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted March 23, 2018
CIK No. 0001730463
Dear Dr. Itin:
We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. 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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form F-1 submitted March 23, 2018
Business
Our License Agreement with UCL Business plc, page 135
1.We note your revised disclosure that the sublicensing income payable to UCLB ranges
from low-double-digits to mid-single digits in response to our prior comment 9. Please
revise your description of the high end of the range to provide a range within ten
FirstName LastNameChristian Itin, Ph.D.
Comapany NameAutolus Therapeutics Ltd
June 16, 2017 Page 2
FirstName LastName
Christian Itin, Ph.D.
Autolus Therapeutics Ltd
April 9, 2018
Page 2
percentage points. We also note your response that the duration of the royalty term will
be subject to a confidential treatment request. Confidential treatment is generally not
appropriate for material information such as the royalty term of material contracts. Please
revise your disclosure to provide the royalty term of your license agreement with UCLB,
or tell us why you believe this information is not material to investors.
You may contact Mark Brunhofer at 202-551-3638 or Mary Mast at 202-551-3613 if you
have questions regarding comments on the financial statements and related matters. Please
contact Irene Paik at 202-551-6553 or Mary Beth Breslin at 202-551-3625 with any other
questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Darren DeStefano - Cooley LLP