SEC Comment Letter for ADC Therapeutics SA (ADCT) (CIK 0001771910) (ADCT) — Mar 25, 2020
ADC Therapeutics SA (ADCT) (CIK 0001771910)
Date: March 25, 2020 · CIK: 0001771910 · Accession: 0000000000-20-002607
AI Filing Summary & Sentiment
Reasoning
Letter
March 25, 2020 Christopher Martin Chief Executive Officer ADC Therapeutics SA Biopôle, Route de la Corniche 3B 1066 Epalinges Switzeland Re:ADC Therapeutics SA Draft Registration Statement on Form F-1 Submitted March 2, 2020 CIK No. 0001771910 Dear Mr. Martin: We have reviewed your 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. Draft Registration Statement on Form F-1 Management's Discussion and Analysis of Financial Condition and Results of Operations Critical Accounting Policies and Significant Judgments and Estimates Employee Benefits Share-Based Compensation Expense, page 95 1.Once you have an estimated offering price range, please explain to us the reasons for any differences between recent valuations of your common shares leading up to the planned offering and the midpoint of your estimated offering price range. This information will help facilitate our review of your accounting for equity issuances, including stock compensation.
FirstName LastNameChristopher Martin Comapany NameADC Therapeutics SA March 25, 2020 Page 2 FirstName LastName Christopher Martin ADC Therapeutics SA March 25, 2020 Page 2 You may contact Franklin Wyman at (202) 551-3660 or Lisa Vanjoske at (202) 551- 3614 if you have questions regarding comments on the financial statements and related matters. Please contact Tonya K. Aldave at (202) 551-3601 or Dietrich King at (202) 551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Yasin Keshvargar, Esq.
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March 25, 2020
Christopher Martin
Chief Executive Officer
ADC Therapeutics SA
Biopôle, Route de la Corniche 3B
1066 Epalinges
Switzeland
Re:ADC Therapeutics SA
Draft Registration Statement on Form F-1
Submitted March 2, 2020
CIK No. 0001771910
Dear Mr. Martin:
We have reviewed your 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.
Draft Registration Statement on Form F-1
Management's Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies and Significant Judgments and Estimates
Employee Benefits
Share-Based Compensation Expense, page 95
1.Once you have an estimated offering price range, please explain to us the reasons for any
differences between recent valuations of your common shares leading up to the planned
offering and the midpoint of your estimated offering price range. This information will
help facilitate our review of your accounting for equity issuances, including stock
compensation.
FirstName LastNameChristopher Martin
Comapany NameADC Therapeutics SA
March 25, 2020 Page 2
FirstName LastName
Christopher Martin
ADC Therapeutics SA
March 25, 2020
Page 2
You may contact Franklin Wyman at (202) 551-3660 or Lisa Vanjoske at (202) 551-
3614 if you have questions regarding comments on the financial statements and related matters.
Please contact Tonya K. Aldave at (202) 551-3601 or Dietrich King at (202) 551-8071 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Yasin Keshvargar, Esq.