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SEC Company Response from Inventiva S.A. (IVA, IVEVF) (CIK 0001756594) (IVA) — Jul 6, 2020

Inventiva S.A. (IVA, IVEVF) (CIK 0001756594)
Date: July 6, 2020 · CIK: 0001756594 · Accession: 0001104659-20-081016

AI Filing Summary & Sentiment

File numbers found in text: 333-239312

Referenced dates: June 25, 2020

Date
July 6, 2020
Author
Divakar Gupta
Form
CORRESP
Company
Inventiva S.A. (IVA, IVEVF) (CIK 0001756594)

Letter

Divakar Gupta

+ 1 212 479 6474

dgupta@cooley.com Via EDGAR

July 6, 2020

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Tara Harkins

Kevin Vaughn

Paul Fischer

Suzanne Hayes

Re: Inventiva S.A.

Registration Statement No. 333-239312 on Form F-1

Filed June 19, 2020

CIK No. 0001756594

Ladies and Gentlemen:

On behalf of our client, Inventiva S.A. (the “Company”), we are responding to the comment (the “Comment”) of the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter dated June 25, 2020, relating to the above referenced Registration Statement on Form F-1 (the “Registration Statement”). In response to the Comment, the Company has revised Registration Statement and is filing via EDGAR a revised version of the Registration Statement (the “Amended Registration Statement”) with this response letter. For the Staff’s reference, we are also delivering both a clean copy of the Amended Registration Statement and a copy marked to show all changes from the Registration Statement filed on Jun 19, 2020.

Supplemental Response dated July 6, 2020

Cover page

1. We note that your May 26, 2020 response letter indicates that you will revise your cover page to indicate that the offering price will be determined in reference to the price on the Euronext Paris market and will in no event reflect a discount of more than 15% below the volume weighted average closing price during the five trading days preceding the determination of the offering price. Please revise your cover page accordingly.

We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.

July 6, 2020

Page 2

Response to Comment 1: The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has indicated, on the cover page of the Amended Registration Statement and elsewhere as appropriate in the Amended Registration Statement, that the offering price will be determined in reference to the price on the Euronext Paris market and will in no event reflect a discount of more than 10% below the volume weighted average closing price during the three trading days preceding the appropriate reference date.

* * * *

Please direct any questions or comments concerning the Amended Registration Statement or this response letter to either the undersigned at +1 212 479 64742 or Richard Segal at + 1 617 937 2332.

Very
truly yours,
/s/
Divakar Gupta

Show Raw Text
CORRESP
1
filename1.htm

Divakar Gupta

+ 1 212 479 6474

dgupta@cooley.com
Via EDGAR

July 6, 2020

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Tara
    Harkins

    Kevin
    Vaughn

    Paul
    Fischer

    Suzanne
    Hayes

    Re:
    Inventiva
    S.A.

    Registration
    Statement No. 333-239312 on Form F-1

    Filed
    June 19, 2020

    CIK
    No. 0001756594

Ladies and Gentlemen:

On behalf of our client, Inventiva
S.A. (the “Company”), we are responding to the comment (the “Comment”) of the
staff (the “Staff”) of the Securities and Exchange Commission contained in its letter dated June 25,
2020, relating to the above referenced Registration Statement on Form F-1 (the “Registration Statement”).
In response to the Comment, the Company has revised Registration Statement and is filing via EDGAR a revised version of the Registration
Statement (the “Amended Registration Statement”) with this response letter. For the Staff’s reference,
we are also delivering both a clean copy of the Amended Registration Statement and a copy marked to show all changes from the Registration
Statement filed on Jun 19, 2020.

Supplemental Response dated July 6, 2020

Cover page

1. We note that your May 26, 2020 response letter indicates that you will revise your cover page to
indicate that the offering price will be determined in reference to the price on the Euronext Paris market and will in no event
reflect a discount of more than 15% below the volume weighted average closing price during the five trading days preceding the
determination of the offering price. Please revise your cover page accordingly.

We remind
you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any
review, comments, action or absence of action by the staff.

Refer to Rules 460 and 461
regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective
date of the registration statement.

July 6, 2020

Page 2

Response to Comment 1: The
Company respectfully acknowledges the Staff’s comment and advises the Staff that it has indicated, on the cover page of
the Amended Registration Statement and elsewhere as appropriate in the Amended Registration Statement, that the offering price
will be determined in reference to the price on the Euronext Paris market and will in no event reflect a discount of more than
10% below the volume weighted average closing price during the three trading days preceding the appropriate reference date.

* * * *

Please direct any questions or comments
concerning the Amended Registration Statement or this response letter to either the undersigned at +1 212 479 64742 or Richard
Segal at + 1 617 937 2332.

    Very
    truly yours,

    /s/
    Divakar Gupta

    Divakar
    Gupta, Esq.

cc:
Frédéric
Cren, Inventiva S.A.

Richard
Segal, Cooley LLP

Alison
Haggerty, Cooley LLP

Deanna
Kirkpatrick, Davis Polk & Wardwell LLP

Yasin
Keshvargar, Davis Polk & Wardwell LLP