Correspondence 0001104659-24-092000 from Journey Medical Corp (DERM)
Journey Medical Corp
Date: Aug. 22, 2024 · CIK: 0001867066 · Accession: 0001104659-24-092000
AI Filing Summary & Sentiment
File numbers found in text: 001-41063
Referenced dates: August 21, 2024
Letter
August 22, 2024
VIA EDGAR
Doris Stacey Gama and Suzanne Hayes
Division of Corporation Finance
Office of Life Sciences
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Journey Medical Corporation
Form 10-K for Fiscal Year Ended December 31,
Filed March 29, 2024
File No. 001-41063
Ladies and Gentlemen:
We are writing to respond to the comment provided by the Staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission in your letter dated August 21, 2024, relating to the Journey Medical Corporation (“we”, “Journey”, or the “Company”) Annual Report on Form 10-K for the fiscal year ended December 31, 2023, filed on March 29, 2024 (the “Form 10-K”).
For ease of review, we have set forth below the Staff’s comment in bold type, followed by the Company’s response thereto.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 1C. Cybersecurity
Cybersecurity Governance, page 61
We note that leaders from your information security, compliance and legal team oversee cybersecurity risk management. Please revise future filings to provide the relevant expertise of such persons or members in such detail as is necessary to fully describe the nature of the expertise as required by Item 106(c)(2)(i) of Regulation S-K.
Response to Comment:
The Company acknowledges the Staff’s comment and confirms that the Company will revise future filings to provide the relevant expertise of such persons or members in such detail as is necessary to fully describe the nature of the expertise as required by Item 106(c)(2)(i) of Regulation S-K.
Securities and Exchange Commission
Division of Corporation Finance
August 22, 2024
Page 2 of 2
⁕⁕⁕
Should any member of the Staff have questions regarding our responses to the comments set forth above or need additional information, please do not hesitate to call me at (480) 434-6670. Thank you for your assistance in this matter.
Very truly yours,
/s/ Joseph Benesch
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August 22, 2024
VIA EDGAR
Doris Stacey Gama and Suzanne Hayes
Division of Corporation Finance
Office of Life Sciences
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Journey Medical Corporation
Form 10-K for Fiscal Year Ended December 31,
2023
Filed March 29, 2024
File No. 001-41063
Ladies and Gentlemen:
We are writing to respond
to the comment provided by the Staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and
Exchange Commission in your letter dated August 21, 2024, relating to the Journey Medical Corporation (“we”, “Journey”,
or the “Company”) Annual Report on Form 10-K for the fiscal year ended December 31, 2023, filed on March 29, 2024 (the
“Form 10-K”).
For ease of review, we have
set forth below the Staff’s comment in bold type, followed by the Company’s response thereto.
Form 10-K for the Fiscal Year Ended December
31, 2022
Item 1C. Cybersecurity
Cybersecurity Governance, page 61
We note that leaders from your information security, compliance
and legal team oversee cybersecurity risk management. Please revise future filings to provide the relevant expertise of such persons or
members in such detail as is necessary to fully describe the nature of the expertise as required by Item 106(c)(2)(i) of Regulation S-K.
Response to Comment:
The Company acknowledges the
Staff’s comment and confirms that the Company will revise future filings to provide the relevant expertise of such persons or members
in such detail as is necessary to fully describe the nature of the expertise as required by Item 106(c)(2)(i) of Regulation S-K.
Securities and Exchange Commission
Division of Corporation Finance
August 22, 2024
Page 2 of 2
⁕⁕⁕
Should any member of the Staff
have questions regarding our responses to the comments set forth above or need additional information, please do not hesitate to call
me at (480) 434-6670. Thank you for your assistance in this matter.
Very truly yours,
/s/ Joseph Benesch
Joseph Benesch
Chief Financial Officer
cc (electronic): Ramsey Alloush, General Counsel
Rakesh Gopalan, Troutman Pepper Hamilton
Sanders LLP
David S. Wolpa, Troutman Pepper Hamilton
Sanders LLP