SEC Comment Letter 0000000000-23-001771 to Zura Bio Ltd (ZURA)
Zura Bio Ltd
Date: Feb. 22, 2023 · CIK: 0001855644 · Accession: 0000000000-23-001771
AI Filing Summary & Sentiment
File numbers found in text: 333-267005
Letter
United States securities and exchange commission logo February 22, 2023 Verender Badial Chief Financial Officer JATT Acquisition Corp c/o Maples Corporate Services Limited PO Box 309, Ugland House Grand Cayman, KY1-1104, Cayman Islands Re:JATT Acquisition Corp Amendment No. 7 to Registration Statement on Form S-4 Filed on February 17, 2023 File No. 333-267005 Dear Verender Badial: 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. Amendment No. 7 to Form S-4 License Agreements, page 244 1.We note your disclosure relating to the Lilly License on page 245 of royalties ranging from mid-single to low-double digit percentages. Please revise your disclosure to give investors a reasonable idea of the amount of the royalty rates that does not exceed ten percentage points. Financial Statements , page F-1 2.Please update the financial statements of Jatt Acquisition Corp and Zura Bio Limited to December 31, 2022 in accordance with Rule 3-12 of Regulation S-X or tell us the reason(s) that you believe you are not required to do so.
FirstName LastNameVerender Badial Comapany NameJATT Acquisition Corp February 22, 2023 Page 2 FirstName LastName Verender Badial JATT Acquisition Corp February 22, 2023 Page 2 You may contact Christie Wong at 202-551-3684 or Lynn Dicker at 202-551-3616 if you have questions regarding comments on the financial statements and related matters. Please contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Giovanni Caruso, Esq.
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United States securities and exchange commission logo
February 22, 2023
Verender Badial
Chief Financial Officer
JATT Acquisition Corp
c/o Maples Corporate Services Limited
PO Box 309, Ugland House
Grand Cayman, KY1-1104, Cayman Islands
Re:JATT Acquisition Corp
Amendment No. 7 to Registration Statement on Form S-4
Filed on February 17, 2023
File No. 333-267005
Dear Verender Badial:
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.
Amendment No. 7 to Form S-4
License Agreements, page 244
1.We note your disclosure relating to the Lilly License on page 245 of royalties ranging
from mid-single to low-double digit percentages. Please revise your disclosure to give
investors a reasonable idea of the amount of the royalty rates that does not exceed ten
percentage points.
Financial Statements , page F-1
2.Please update the financial statements of Jatt Acquisition Corp and Zura Bio Limited to
December 31, 2022 in accordance with Rule 3-12 of Regulation S-X or tell us the
reason(s) that you believe you are not required to do so.
FirstName LastNameVerender Badial
Comapany NameJATT Acquisition Corp
February 22, 2023 Page 2
FirstName LastName
Verender Badial
JATT Acquisition Corp
February 22, 2023
Page 2
You may contact Christie Wong at 202-551-3684 or Lynn Dicker at 202-551-3616 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Giovanni Caruso, Esq.