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SEC Comment Letter 0000000000-24-001505 to Contineum Therapeutics, Inc. (CTNM)

Contineum Therapeutics, Inc.
Date: Feb. 7, 2024 · CIK: 0001855175 · Accession: 0000000000-24-001505

AI Filing Summary & Sentiment

Date
February 7, 2024
Author
Not clearly detected
Form
UPLOAD
Company
Contineum Therapeutics, Inc.

Letter

United States securities and exchange commission logo February 7, 2024 Carmine Stengone Chief Executive Officer and President Contineum Therapeutics, Inc. 10578 Science Center Drive, Suite 200 San Diego, California 92121 Re:Contineum Therapeutics, Inc. Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted January 29, 2024 CIK No. 0001855175 Dear Carmine Stengone: We have reviewed your amended draft registration statement and have the following comments. 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 a comment applies 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 this letter and your amended draft registration statement or filed registration statement, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our January 11, 2024 letter. Amendment No. 1 to Draft Registration Statement on Form S-1 Prospectus Summary Company Overview, page 1 1.We note your response to our prior comment 3 and reissue in part. You continue to reference PIPE-791 as a "highly differentiated" therapeutic for both IPF and Progressive MS throughout the prospectus. Please revise your disclosure to explain why you believe this is the case, providing support for the use of this term as necessary. In addition, please revise your statement that the company has "demonstrated" the ability to develop selective compounds targeting challenging molecular pathways, as the statement appears premature given the company has not received approval for or commercialized any of its product candidates.

FirstName LastNameCarmine Stengone Comapany NameContineum Therapeutics, Inc. February 7, 2024 Page 2 FirstName LastName Carmine Stengone Contineum Therapeutics, Inc. February 7, 2024 Page 2 PIPE-791 for the Potential Treatment of IPF, page 2 2.We note the revisions made in response to our prior comment 4 on pages 2, 5, 114 and 117. Please revise your statement that you believe PIPE-791 "has the potential to be the first FDA-approved once-daily drug to treat IPF," which appears equivalent to claiming it is a first-in-class therapeutic, and is speculative given your current stage of development. Our Strategy, page 5 3.Please revise to remove your statements here and on page 117 that you intend to "[r]apidly pursue clinical development of PIPE-791" as it is speculative that you may control the pace of clinical development of your product candidates. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 4.We note your response to our prior comment 9 and reissue in part. Please revise to disclose the exact period of time the J&J License Agreement may expire "after the first commercial sale of such licensed product in such country." Please contact Ibolya Ignat at 202-551-3636 or Kevin Kuhar at 202-551-3662 if you have questions regarding comments on the financial statements and related matters. Please contact Daniel Crawford at 202-551-7767 or Laura Crotty at 202-551-7614 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Jeffrey Thacker, Esq.

Show Raw Text
United States securities and exchange commission logo
February 7, 2024
Carmine Stengone
Chief Executive Officer and President
Contineum Therapeutics, Inc.
10578 Science Center Drive, Suite 200
San Diego, California 92121
Re:Contineum Therapeutics, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted January 29, 2024
CIK No. 0001855175
Dear Carmine Stengone:
            We have reviewed your amended draft registration statement and have the following
comments.
            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 a comment applies 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 this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
January 11, 2024 letter.
Amendment No. 1 to Draft Registration Statement on Form S-1
Prospectus Summary
Company Overview, page 1
1.We note your response to our prior comment 3 and reissue in part. You continue to
reference PIPE-791 as a "highly differentiated" therapeutic for both IPF and Progressive
MS throughout the prospectus. Please revise your disclosure to explain why you believe
this is the case, providing support for the use of this term as necessary. In addition, please
revise your statement that the company has "demonstrated" the ability to develop selective
compounds targeting challenging molecular pathways, as the statement appears premature
given the company has not received approval for or commercialized any of its product
candidates.

 FirstName LastNameCarmine  Stengone
 Comapany NameContineum Therapeutics, Inc.
 February 7, 2024 Page 2
 FirstName LastName
Carmine  Stengone
Contineum Therapeutics, Inc.
February 7, 2024
Page 2
PIPE-791 for the Potential Treatment of IPF, page 2
2.We note the revisions made in response to our prior comment 4 on pages 2, 5, 114 and
117. Please revise your statement that you believe PIPE-791 "has the potential to be the
first FDA-approved once-daily drug to treat IPF," which appears equivalent to claiming it
is a first-in-class therapeutic, and is speculative given your current stage of development.
Our Strategy, page 5
3.Please revise to remove your statements here and on page 117 that you intend to "[r]apidly
pursue clinical development of PIPE-791" as it is speculative that you may control the
pace of clinical development of your product candidates.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
93
4.We note your response to our prior comment 9 and reissue in part. Please revise to
disclose the exact period of time the J&J License Agreement may expire "after the first
commercial sale of such licensed product in such country."
            Please contact Ibolya Ignat at 202-551-3636 or Kevin Kuhar at 202-551-3662 if you have
questions regarding comments on the financial statements and related matters. Please contact
Daniel Crawford at 202-551-7767 or Laura Crotty at 202-551-7614 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Jeffrey Thacker, Esq.