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Correspondence 0001104659-24-005370 from ArriVent Biopharma, Inc. (AVBP) (CIK 0001868279) (AVBP)

ArriVent Biopharma, Inc. (AVBP) (CIK 0001868279)
Date: Jan. 22, 2024 · CIK: 0001868279 · Accession: 0001104659-24-005370

AI Filing Summary & Sentiment

File numbers found in text: 333-276397

Referenced dates: January 12, 2024

Date
January 22, 2024
Author
/s/ John T. Rudy
Form
CORRESP
Company
ArriVent Biopharma, Inc. (AVBP) (CIK 0001868279)

Letter

One Financial Center

Boston, MA 02111

617 542 6000

mintz.com

January 22, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E. Washington, D.C. 20549

Attention: Christopher Edwards and Suzanne Hayes, Office of Life Sciences

Re: ArriVent BioPharma, Inc.

Registration Statement on Form S-1

Filed January 5, 2024

File No. 333-276397 (the “Registration Statement”)

Ladies and Gentlemen:

We are submitting this letter on behalf of ArriVent BioPharma, Inc. (the “Company”) in response to the comment from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) received by letter dated January 12, 2024 (the “Comment Letter”) from the Division of Corporation Finance, Office of Life Sciences, to Zhengbin (Bing) Yao, Ph.D., President and Chief Executive Officer of the Company, relating to the above-referenced Registration Statement. In conjunction with this letter, the Company is filing Amendment No. 1 to its Registration Statement on Form S-1 (the “Amended Registration Statement”) with the Commission.

For reference, we have set forth below in italics the Staff’s comment from the Comment Letter and have keyed the Company’s response to the numbering of the comment and the headings used in the Comment Letter. The response is based on information provided to Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. by representatives of the Company. Page numbers referred to in the response reference the applicable pages of the Amended Registration Statement.

Form S-1 filed January 5, 2024

Management's Discussion and Analysis of Financial Condition and Results of Operations

Determination of Fair Value of Our Common Stock, page 108

Comment 1: We note your response to prior comment eight, as well as your disclosure related to options granted on January 1 and January 4, 2024 on page 108. Please revise this section to discuss how the estimated fair value per common share on grant date for these options compare to the low end and midpoint of estimated price range when available. Revise to identify the extent to which any incremental increase in value between the grant date and the date of the filing is due to specific and identifiable business activities or events.

Response 1: The Staff’s comment is acknowledged, and the Company has revised the disclosure on pages 109 and 110 of the Amended Registration Statement to address how the estimated fair value per common share for the options granted on January 1 and January 4, 2024 compares to the low end and midpoint of the Company’s estimated price range and to discuss the factors considered when determining such estimated price range.

* * * * *

Boston Los Angeles New York San Diego San Francisco TORONTO Washington

MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.

MINTZ

January 22, 2024

Page 2

We hope that the above response will be acceptable to the Staff. Please do not hesitate to call me at (617) 348-3050 with any comments or questions regarding the proposed disclosure. We thank you for your time and attention.

Sincerely,
/s/ John T. Rudy

Show Raw Text
CORRESP
1
filename1.htm

  One Financial Center

Boston, MA 02111

617 542 6000

mintz.com

January 22, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E. Washington, D.C. 20549

Attention: Christopher Edwards and Suzanne Hayes, Office of Life Sciences

Re: ArriVent BioPharma, Inc.

Registration Statement on Form S-1

Filed January 5, 2024

File No. 333-276397 (the “Registration Statement”)

Ladies and Gentlemen:

We are submitting this letter on behalf of ArriVent BioPharma, Inc.
(the “Company”) in response to the comment from the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) received by letter dated January 12, 2024 (the “Comment Letter”)
from the Division of Corporation Finance, Office of Life Sciences, to Zhengbin (Bing) Yao, Ph.D., President and Chief Executive Officer
of the Company, relating to the above-referenced Registration Statement. In conjunction with this letter, the Company is filing Amendment
No. 1 to its Registration Statement on Form S-1 (the “Amended Registration Statement”) with the Commission.

For reference, we have set forth below in italics the Staff’s
comment from the Comment Letter and have keyed the Company’s response to the numbering of the comment and the headings used in the
Comment Letter. The response is based on information provided to Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. by representatives
of the Company. Page numbers referred to in the response reference the applicable pages of the Amended Registration Statement.

Form S-1 filed January 5, 2024

Management's Discussion and Analysis of Financial
Condition and Results of Operations

Determination of Fair Value of Our Common Stock, page 108

Comment 1: We note your response to prior comment eight,
as well as your disclosure related to options granted on January 1 and January 4, 2024 on page 108. Please revise this section to discuss
how the estimated fair value per common share on grant date for these options compare to the low end and midpoint of estimated price range
when available. Revise to identify the extent to which any incremental increase in value between the grant date and the date of the filing
is due to specific and identifiable business activities or events.

Response 1: The Staff’s comment
is acknowledged, and the Company has revised the disclosure on pages 109 and 110 of the Amended Registration Statement to address
how the estimated fair value per common share for the options granted on January 1 and January 4, 2024 compares to the low end and
midpoint of the Company’s estimated price range and to discuss the factors considered when determining such estimated price
range.

* * * * *

Boston
Los Angeles     New York     San Diego     San Francisco     TORONTO     Washington

MINTZ,
LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.

MINTZ

  January 22, 2024

 Page 2

We hope that the above response will be acceptable
to the Staff. Please do not hesitate to call me at (617) 348-3050 with any comments or questions regarding the proposed disclosure. We
thank you for your time and attention.

    Sincerely,

    /s/ John T. Rudy

    John T. Rudy

cc: Securities and Exchange Commission

Li Xiao

Kevin Vaughn

ArriVent BioPharma, Inc.

Zhengbin (Bing) Yao, Ph.D.

Robin LaChapelle

James Kastenmayer

Mintz, Levin, Cohn, Ferris, Glovsky
and Popeo, P.C.

Matthew T. Simpson

Latham & Watkins LLP

Nathan Ajiashvili

Alison A. Haggerty