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SEC Comment Letter 0000000000-23-011351 to Abivax S.A. (ABVX) (CIK 0001956827) (ABVX)

Abivax S.A. (ABVX) (CIK 0001956827)
Date: Oct. 17, 2023 · CIK: 0001956827 · Accession: 0000000000-23-011351

Financial Reporting Capital Structure Regulatory Compliance

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File numbers found in text: 333-274780

Date
October 17, 2023
Author
Marc de Garidel
Form
UPLOAD
Company
Abivax S.A. (ABVX) (CIK 0001956827)

Letter

United States securities and exchange commission logo October 17, 2023 Marc de Garidel Chief Executive Officer Abivax SA 7-11 boulevard Haussmann 75009 Paris France Re:Abivax SA Amendment No. 1 to Registration Statement on Form F-1 Filed October 16, 2023 File No. 333-274780 Dear Marc de Garidel: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe the comment applies 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 this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our October 5, 2023 letter. Amendment No. 1 to Registration Statement on Form F-1, filed October 16, 2023 Capitalization, page 85 1.Please revise the description in the second bullet to quantify separately the amount of the tranches drawn for the Kreos/Claret OCABSA and Heights Convertible Notes as well as the amounts repaid under the First KC Agreement, the Second KC Agreement and the OCEANE bonds.

FirstName LastNameMarc de Garidel Comapany NameAbivax SA October 17, 2023 Page 2 FirstName LastName Marc de Garidel Abivax SA October 17, 2023 Page 2 Please 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
October 17, 2023
Marc de Garidel
Chief Executive Officer
Abivax SA
7-11 boulevard Haussmann
75009 Paris
France
Re:Abivax SA
Amendment No. 1 to Registration Statement on Form F-1
Filed October 16, 2023
File No. 333-274780
Dear Marc de Garidel:
            We have reviewed your amended registration statement and have the following comment.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe the comment applies 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 this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our October 5, 2023 letter.
Amendment No. 1 to Registration Statement on Form F-1, filed October 16, 2023
Capitalization, page 85
1.Please revise the description in the second bullet to quantify separately the amount of the
tranches drawn for the Kreos/Claret OCABSA and Heights Convertible Notes as well as
the amounts repaid under the First KC Agreement, the Second KC Agreement and the
OCEANE bonds.

 FirstName LastNameMarc de Garidel
 Comapany NameAbivax SA
 October 17, 2023 Page 2
 FirstName LastName
Marc de Garidel
Abivax SA
October 17, 2023
Page 2
            Please 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