SEC Comment Letter for INNOCAN PHARMA (INNPF) — May 14, 2025
INNOCAN PHARMA Corp
Date: May 14, 2025 · CIK: 0001889791 · Accession: 0000000000-25-005182
AI Filing Summary & Sentiment
Letter
May 14, 2025 Iris Bincovich Chief Executive Officer Innocan Pharma Corporation 1015, 926 - 5 Avenue SW Calgary, Alberta T2P 0N7 Canada Re:Innocan Pharma Corporation Amendment No. 3 to Draft Registration Statement on Form F-1 Submitted May 12, 2025 CIK No. 0001889791 Dear Iris Bincovich: 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 May 8, 2025 letter. Amendment No. 3 to Draft Registration Statement on Form F-1 Prospectus Summary The Offering, page 7 1.We note your revisions in response to prior comment 3. As requested by the prior comment, please revise to clearly disclose here and in the related bullet points on pages 76 and 78 the minimum and maximum number of shares that may be issuable upon conversion of the debenture.
May 14, 2025 Page 2 Business Human Application of Liposome-based Technology, page 108 2.Although we note your revised disclosure in response to prior comment 5, your disclosure continues to use the term "efficacy" with regard to your animal studies and such term has also been added in your qualifying disclosure that such "efficacy" has not yet been verified in human clinical studies. As conclusions of efficacy are within the sole authority of the FDA and comparable foreign regulators, please revise each instance of this disclosure to avoid using this term. Please contact Gary Newberry at 202-551-3761 or Sasha Parikh at 202-551-3627 if you have questions regarding comments on the financial statements and related matters. Please contact Tim Buchmiller at 202-551-3635 or Jessica Dickerson at 202-551- 8013 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc:David Huberman, Esq.
Show Raw Text
May 14, 2025
Iris Bincovich
Chief Executive Officer
Innocan Pharma Corporation
1015, 926 - 5 Avenue SW
Calgary, Alberta T2P 0N7
Canada
Re:Innocan Pharma Corporation
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted May 12, 2025
CIK No. 0001889791
Dear Iris Bincovich:
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 May 8, 2025 letter.
Amendment No. 3 to Draft Registration Statement on Form F-1
Prospectus Summary
The Offering, page 7
1.We note your revisions in response to prior comment 3. As requested by the prior
comment, please revise to clearly disclose here and in the related bullet points on
pages 76 and 78 the minimum and maximum number of shares that may be issuable
upon conversion of the debenture.
May 14, 2025
Page 2
Business
Human Application of Liposome-based Technology, page 108
2.Although we note your revised disclosure in response to prior comment 5, your
disclosure continues to use the term "efficacy" with regard to your animal studies and
such term has also been added in your qualifying disclosure that such "efficacy" has
not yet been verified in human clinical studies. As conclusions of efficacy are within
the sole authority of the FDA and comparable foreign regulators, please revise each
instance of this disclosure to avoid using this term.
Please contact Gary Newberry at 202-551-3761 or Sasha Parikh at 202-551-3627 if
you have questions regarding comments on the financial statements and related
matters. Please contact Tim Buchmiller at 202-551-3635 or Jessica Dickerson at 202-551-
8013 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:David Huberman, Esq.