SEC Comment Letter for Arcutis Biotherapeutics, Inc. (ARQT) (CIK 0001787306) (ARQT) — Oct 31, 2019
Arcutis Biotherapeutics, Inc. (ARQT) (CIK 0001787306)
Date: Oct. 31, 2019 · CIK: 0001787306 · Accession: 0000000000-19-015031
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Letter
October 31, 2019 Todd Franklin Watanabe Chief Executive Officer Arcutis, Inc. 2945 Townsgate Rd., Suite 110 Westlake Village CA 91361 Re:Arcutis, Inc. Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted October 21, 2019 CIK No. 0001787306 Dear Mr. Watanabe: We have reviewed your amended 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 amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our October 4, 2019 letter. Amendment No. 1 to Draft Registration Statement on Form S-1 Overview, page 1 1.We note your revised disclosure in response to comment 1. Please further revise your disclosure to more broadly acknowledge the widespread use of accepted treatments for the applications that you are considering. In addition, please remove references to the relative safety and efficacy of various treatments, as safety and efficacy are uniquely within the purview of the FDA.
FirstName LastNameTodd Franklin Watanabe Comapany NameArcutis, Inc. October 31, 2019 Page 2 FirstName LastName Todd Franklin Watanabe Arcutis, Inc. October 31, 2019 Page 2 You may contact Christine Torney at 202-551-3652 or Angela Connell at 202-551-3426 if you have questions regarding comments on the financial statements and related matters. Please contact Julia Griffith at 202-551-3267 or Dietrich King at 202-551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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October 31, 2019
Todd Franklin Watanabe
Chief Executive Officer
Arcutis, Inc.
2945 Townsgate Rd., Suite 110
Westlake Village
CA 91361
Re:Arcutis, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted October 21, 2019
CIK No. 0001787306
Dear Mr. Watanabe:
We have reviewed your amended 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 amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our October 4, 2019 letter.
Amendment No. 1 to Draft Registration Statement on Form S-1
Overview, page 1
1.We note your revised disclosure in response to comment 1. Please further revise your
disclosure to more broadly acknowledge the widespread use of accepted treatments for the
applications that you are considering. In addition, please remove references to the relative
safety and efficacy of various treatments, as safety and efficacy are uniquely within the
purview of the FDA.
FirstName LastNameTodd Franklin Watanabe
Comapany NameArcutis, Inc.
October 31, 2019 Page 2
FirstName LastName
Todd Franklin Watanabe
Arcutis, Inc.
October 31, 2019
Page 2
You may contact Christine Torney at 202-551-3652 or Angela Connell at 202-551-3426
if you have questions regarding comments on the financial statements and related
matters. Please contact Julia Griffith at 202-551-3267 or Dietrich King at 202-551-8071 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences