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SEC Company Response from ADC Therapeutics SA (ADCT) (CIK 0001771910) (ADCT) — Sep 30, 2019

ADC Therapeutics SA (ADCT) (CIK 0001771910)
Date: Sept. 30, 2019 · CIK: 0001771910 · Accession: 0001140361-19-017558

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File numbers found in text: 333-233659

Date
September 30, 2019
Author
ADC Therapeutics SA
Form
CORRESP
Company
ADC Therapeutics SA (ADCT) (CIK 0001771910)

Letter

VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Attention: Ms. Tonya K. Aldave ADC Therapeutics SA Registration Statement on Form F-1 Registration No. 333-233659

Re:

Dear Ms. Aldave:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned registrant hereby requests that the effective date for the Registration Statement referred to above be accelerated so that it will be declared effective at 3:30 p.m. Eastern Time on October 2, 2019 or as soon thereafter as is practicable. By separate letter, the underwriters of the issuance of the securities being registered join in this request for acceleration.

We hereby acknowledge that:

•

should the Securities and Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please do not hesitate to contact Deanna L. Kirkpatrick of Davis Polk & Wardwell LLP at (212) 450-4135 or Yasin Keshvargar of Davis Polk & Wardwell LLP at (212) 450-4839 with any questions or comments with respect to this letter.

[Signature Page Follows]

Sincerely,
ADC Therapeutics SA

Show Raw Text
CORRESP
1
filename1.htm

              September 30, 2019

              VIA EDGAR

    Securities and Exchange Commission

      Division of Corporation Finance

      100 F Street, N.E.

      Washington, D.C. 20549

      Attention: Ms. Tonya K. Aldave

            Re:

            ADC Therapeutics SA

              Registration Statement on Form F-1

              Registration No. 333-233659

    Dear Ms. Aldave:

    Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned registrant hereby requests that the effective date for the Registration Statement referred to above be accelerated so that it will be declared effective at 3:30
      p.m. Eastern Time on October 2, 2019 or as soon thereafter as is practicable. By separate letter, the underwriters of the issuance of the securities being registered join in this request for acceleration.

    We hereby acknowledge that:

              •

              should the Securities and Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

              •

              the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the
                filing; and

              •

              the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

    Please do not hesitate to contact Deanna L. Kirkpatrick of Davis Polk & Wardwell LLP at (212) 450-4135 or Yasin Keshvargar of Davis Polk & Wardwell LLP at (212) 450-4839 with any questions or comments with respect to this letter.

    [Signature Page Follows]

    Sincerely,

            ADC Therapeutics SA

            By:

            /s/ Dominique Graz

           Name:
          Dominique Graz

           Title:
          General Counsel