SEC Comment Letter 0000000000-23-010378 to Abivax S.A. (ABVX) (CIK 0001956827) (ABVX)
Abivax S.A. (ABVX) (CIK 0001956827)
Date: Sept. 20, 2023 · CIK: 0001956827 · Accession: 0000000000-23-010378
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo September 20, 2023 Marc de Garidel Chief Executive Officer Abivax SA 7-11 boulevard Haussmann 75009 Paris France Re:Abivax SA Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted September 8, 2023 CIK No. 0001956827 Dear Marc de Garidel: We have reviewed your amended draft 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 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 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 the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 2 to Draft Registration Statement on Form F-1 submitted September 8, 2023 Risk Factors Risks Related to our Financial Position and Need for Additional Capital We have significant debt commitments, which require us to meet certain operating covenants, and if we fail to comply with those covenants..., page 21 1.We note your disclosure stating that as security for the Kreos/Claret Financing, "the Secured Lenders benefit from the grant of first-ranking collateral on [y]our principal tangible and intangible assets, including . . . intellectual property rights in [y]our lead drug candidate[.]" Please revise your disclosure to provide a separate risk factor detailing the risks associated with pledging the intellectual property rights in your lead drug candidate
FirstName LastNameMarc de Garidel Comapany NameAbivax SA September 20, 2023 Page 2 FirstName LastName Marc de Garidel Abivax SA September 20, 2023 Page 2 as security for the Kreos/Claret Financing. You may contact Vanessa Robertson at 202-551-3649 or Mary Mast at 202-551-3613 if you have questions regarding comments on the financial statements and related matters. Please contact Joshua Gorsky at 202-551-7836 or Jason Drory at 202-551-8342 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Ryan Sansom
Show Raw Text
United States securities and exchange commission logo
September 20, 2023
Marc de Garidel
Chief Executive Officer
Abivax SA
7-11 boulevard Haussmann
75009 Paris
France
Re:Abivax SA
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted September 8, 2023
CIK No. 0001956827
Dear Marc de Garidel:
We have reviewed your amended draft 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 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 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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 2 to Draft Registration Statement on Form F-1 submitted September 8, 2023
Risk Factors
Risks Related to our Financial Position and Need for Additional Capital
We have significant debt commitments, which require us to meet certain operating covenants,
and if we fail to comply with those covenants..., page 21
1.We note your disclosure stating that as security for the Kreos/Claret Financing, "the
Secured Lenders benefit from the grant of first-ranking collateral on [y]our principal
tangible and intangible assets, including . . . intellectual property rights in [y]our lead drug
candidate[.]" Please revise your disclosure to provide a separate risk factor detailing the
risks associated with pledging the intellectual property rights in your lead drug candidate
FirstName LastNameMarc de Garidel
Comapany NameAbivax SA
September 20, 2023 Page 2
FirstName LastName
Marc de Garidel
Abivax SA
September 20, 2023
Page 2
as security for the Kreos/Claret Financing.
You may contact Vanessa Robertson at 202-551-3649 or Mary Mast at 202-551-3613 if
you have questions regarding comments on the financial statements and related matters. Please
contact Joshua Gorsky at 202-551-7836 or Jason Drory at 202-551-8342 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Ryan Sansom