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Correspondence 0001193125-24-060721 from Boundless Bio, Inc. (BOLD)

Boundless Bio, Inc.
Date: March 6, 2024 · CIK: 0001782303 · Accession: 0001193125-24-060721

AI Filing Summary & Sentiment

Referenced dates: January 29, 2024

Date
March 6, 2024
Author
/s/ Matthew T. Bush
Form
CORRESP
Company
Boundless Bio, Inc.

Letter

VIA EDGAR Office of Life Sciences Division of Corporation Finance Re: Boundless Bio, Inc. Amendment No. 2 to Draft Registration Statement on Form S-1 Submitted January 23, 2024 CIK No. 0001782303

Dear Mr. Crawford:

We are in receipt of the Staff’s letter dated January 29, 2024 with respect to the above-referenced confidential draft Amendment No. 2 to Draft Registration Statement on Form S-1. We are responding to the Staff’s comments on behalf of Boundless Bio, Inc. (“Boundless” or the “Company”) as set forth below. Simultaneously with the submission of this letter, the Company is publicly filing via EDGAR a Registration Statement on Form S-1 (the “Registration Statement”) responding to the Staff’s comments and updating the Company’s disclosures in the Registration Statement.

The Company’s responses set forth in this letter are numbered to correspond to the numbered comments in the Staff’s letter. All terms used but not defined herein have the meanings assigned to such terms in the Registration Statement. For ease of reference, we have set forth the Staff’s comments and the Company’s response for each item below.

Amendment No. 2 to Draft Registration Statement on Form S-1

Prospectus Summary

Our Pipeline and Platform, page 3

1. Please revise your pipeline table here and elsewhere in the registration statement so that it contains no more than two preclinical columns that show a progress bar.

Boundless’ Response: The Company has revised the pipeline table on pages 3, 102 and 121 of the Registration Statement in response to the Staff’s comment.

March 6, 2024

Page 2

*********

Any comments or questions regarding the foregoing should be directed to the undersigned at (858) 523-3962. Thank you in advance for your cooperation in connection with this matter.

Very truly yours,
/s/ Matthew T. Bush

Show Raw Text
CORRESP
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CORRESP

12670 High Bluff Drive

San Diego, California 92130

Tel: +1.858.523.5400 Fax: +1.858.523.5450

www.lw.com

FIRM / AFFILIATE OFFICES

Austin

Milan

Beijing

Munich

Boston

New York

Brussels

Orange County

Century City

Paris

Chicago

Riyadh

March 6, 2024

Dubai

San Diego

Düsseldorf

San Francisco

Frankfurt

Seoul

VIA EDGAR

Hamburg

Silicon Valley

Hong Kong

Singapore

Houston

Tel Aviv

London

Tokyo

Daniel Crawford

Los Angeles

Washington, D.C.

Office of Life Sciences

Madrid

 Division of Corporation Finance

U.S. Securities and Exchange Commission

 100 F Street N.E.

Washington, D.C. 20549

Re:
 Boundless Bio, Inc.

Amendment No. 2 to Draft Registration Statement on Form S-1

Submitted January 23, 2024

CIK No. 0001782303

 Dear
Mr. Crawford:

 We are in receipt of the Staff’s letter dated January 29, 2024 with respect to the above-referenced
confidential draft Amendment No. 2 to Draft Registration Statement on Form S-1. We are responding to the Staff’s comments on behalf of Boundless Bio, Inc. (“Boundless” or the
“Company”) as set forth below. Simultaneously with the submission of this letter, the Company is publicly filing via EDGAR a Registration Statement on Form S-1 (the
“Registration Statement”) responding to the Staff’s comments and updating the Company’s disclosures in the Registration Statement.

The Company’s responses set forth in this letter are numbered to correspond to the numbered comments in the Staff’s letter. All
terms used but not defined herein have the meanings assigned to such terms in the Registration Statement. For ease of reference, we have set forth the Staff’s comments and the Company’s response for each item below.

Amendment No. 2 to Draft Registration Statement on Form S-1

Prospectus Summary

 Our Pipeline and
Platform, page 3

1.
 Please revise your pipeline table here and elsewhere in the registration statement so that it contains no
more than two preclinical columns that show a progress bar.

 Boundless’ Response: The Company has revised the
pipeline table on pages 3, 102 and 121 of the Registration Statement in response to the Staff’s comment.

 March 6, 2024

Page 2

 *********

Any comments or questions regarding the foregoing should be directed to the undersigned at (858)
523-3962. Thank you in advance for your cooperation in connection with this matter.

Very truly yours,

/s/ Matthew T. Bush

 Matthew T. Bush

 of LATHAM & WATKINS
LLP

cc:
 Zachary Hornby, Boundless Bio, Inc.

Jami Rubin, Boundless Bio, Inc.

Jessica Oien, Boundless Bio, Inc.

Cheston J. Larson, Latham & Watkins LLP

Charles S. Kim, Cooley LLP

Denny Won, Cooley LLP