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SEC Comment Letter for Oric Pharmaceuticals, Inc. (ORIC) (CIK 0001796280) (ORIC) — Feb 3, 2020

Oric Pharmaceuticals, Inc. (ORIC) (CIK 0001796280)
Date: Feb. 3, 2020 · CIK: 0001796280 · Accession: 0000000000-20-001025

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
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Summary

Reasoning

Date
February 3, 2020
Author
Jacob Chacko, M.D.
Form
UPLOAD
Company
Oric Pharmaceuticals, Inc. (ORIC) (CIK 0001796280)

Letter

February 3, 2020 Jacob Chacko, M.D. President and Chief Executive Officer Oric Pharmaceuticals, Inc. 240 E. Grand Ave, 2nd Floor South San Francisco, CA 94080 Re:Oric Pharmaceuticals, Inc. Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted January 24, 2020 CIK No. 0001796280 Dear Dr. Chacko: We have reviewed your amended 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. Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted January 24, 2020 Prospectus summary Overview, page 1 1.We note your response to prior comment 2, and we reissue in part. We do not object to a discussion of these programs in the summary or in the business section, but discovery research programs that do not appear material to your business and the offering should not be prominently highlighted. To the extent that you believe one or more of the discovery research programs is material to your business and the offering, please revise to disclose the known information about these programs in your business section so that investors

FirstName LastNameJacob Chacko, M.D. Comapany NameOric Pharmaceuticals, Inc. February 3, 2020 Page 2 FirstName LastName Jacob Chacko, M.D. Oric Pharmaceuticals, Inc. February 3, 2020 Page 2 will have a basis to understand these programs and the market potential. Alternatively, please revise your presentation so that it does not prominently highlight these programs in the Summary. Background on cancer resistance, page 108 2.We note your response to prior comment 11. The disclosure implies that your product candidates that target innate resistance will be approved and that the process will be easier or faster than the approval process for other entities. Although other drugs targeting innate resistance have been approved, your product is still distinct from prior products approved by the FDA. While it is appropriate for you to discuss the successes of other drugs that have targeted innate resistance, please revise your disclosure to remove any implications that your product candidates will be approved, are more likely to receive FDA approval, or will be approved quickly. You may contact Ibolya Ignat at 202-551-3636 or Kevin Vaughn at 202-551-3494 if you have questions regarding comments on the financial statements and related matters. Please contact Jeffrey Gabor at 202-551-2544 or Celeste Murphy at 202-551-3257 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Melissa Rick, Esq.

Show Raw Text
February 3, 2020
Jacob Chacko, M.D.
President and Chief Executive Officer
Oric Pharmaceuticals, Inc.
240 E. Grand Ave, 2nd Floor
South San Francisco, CA 94080
Re:Oric Pharmaceuticals, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted January 24, 2020
CIK No. 0001796280
Dear Dr. Chacko:
            We have reviewed your amended 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.
Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted January 24, 2020
Prospectus summary
Overview, page 1
1.We note your response to prior comment 2, and we reissue in part.  We do not object to a
discussion of these programs in the summary or in the business section, but discovery
research programs that do not appear material to your business and the offering should not
be prominently highlighted.  To the extent that you believe one or more of the discovery
research programs is material to your business and the offering, please revise to disclose
the known information about these programs in your business section so that investors

 FirstName LastNameJacob Chacko, M.D.
 Comapany NameOric Pharmaceuticals, Inc.
 February 3, 2020 Page 2
 FirstName LastName
Jacob Chacko, M.D.
Oric Pharmaceuticals, Inc.
February 3, 2020
Page 2
will have a basis to understand these programs and the market potential.  Alternatively,
please revise your presentation so that it does not prominently highlight these programs in
the Summary.
Background on cancer resistance, page 108
2.We note your response to prior comment 11.  The disclosure implies that your product
candidates that target innate resistance will be approved and that the process will be easier
or faster than the approval process for other entities.  Although other drugs targeting
innate resistance have been approved, your product is still distinct from prior products
approved by the FDA.  While it is appropriate for you to discuss the successes of other
drugs that have targeted innate resistance, please revise your disclosure to remove any
implications that your product candidates will be approved, are more likely to receive
FDA approval, or will be approved quickly.
            You may contact Ibolya Ignat at 202-551-3636 or Kevin Vaughn at 202-551-3494 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jeffrey Gabor at 202-551-2544 or Celeste Murphy at 202-551-3257 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Melissa Rick, Esq.