SEC Comment Letter 0000000000-23-008344 to Valneva SE (VALN)
Valneva SE
Date: Aug. 3, 2023 · CIK: 0001836564 · Accession: 0000000000-23-008344
AI Filing Summary & Sentiment
File numbers found in text: 001-40377
Letter
United States securities and exchange commission logo August 3, 2023 Peter Bühler Chief Financial Officer Valneva SE 6 rue Alain Bombard 44800 Saint-Herblain, France Re:Valneva SE Form 20-F for the Fiscal Year Ended December 31, 2022 Filed March 30, 2023 File No. 001-40377 Dear Peter Bühler: We have limited our review of your filing to the financial statements and related disclosures 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 comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 20-F for the Fiscal Year Ended December 31, 2022 Item 19. Exhibits Exhibit 12.1 and 12.2, page 182 1.We note the certifications provided in Exhibits 12.1 and 12.2 do not include paragraph 4(b) and the introductory language in paragraph 4 referring to internal control over financial reporting after the end of the transition period that allows these omissions. Please file an amendment that is limited to the cover page, explanatory note, signature page, and paragraphs 1, 2, 4 and 5 of the certifications. Refer to Instruction 12 to the Form 20-F Exhibits and Question 246.13 of the Compliance and Disclosure Interpretations of Regulation S-K. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNamePeter Bühler Comapany NameValneva SE August 3, 2023 Page 2 FirstName LastName Peter Bühler Valneva SE August 3, 2023 Page 2 You may contact Eric Atallah at (202) 551-3663 or Lynn Dicker, Senior Accountant, at (202) 551-3616 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
August 3, 2023
Peter Bühler
Chief Financial Officer
Valneva SE
6 rue Alain Bombard
44800 Saint-Herblain, France
Re:Valneva SE
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed March 30, 2023
File No. 001-40377
Dear Peter Bühler:
We have limited our review of your filing to the financial statements and related
disclosures 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 comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 19. Exhibits
Exhibit 12.1 and 12.2, page 182
1.We note the certifications provided in Exhibits 12.1 and 12.2 do not include paragraph
4(b) and the introductory language in paragraph 4 referring to internal control over
financial reporting after the end of the transition period that allows these omissions.
Please file an amendment that is limited to the cover page, explanatory note, signature
page, and paragraphs 1, 2, 4 and 5 of the certifications. Refer to Instruction 12 to the
Form 20-F Exhibits and Question 246.13 of the Compliance and Disclosure
Interpretations of Regulation S-K.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
FirstName LastNamePeter Bühler
Comapany NameValneva SE
August 3, 2023 Page 2
FirstName LastName
Peter Bühler
Valneva SE
August 3, 2023
Page 2
You may contact Eric Atallah at (202) 551-3663 or Lynn Dicker, Senior Accountant, at
(202) 551-3616 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences