SEC Comment Letter 0000000000-23-007958 to Mural Oncology plc (MURA) (CIK 0001971543)
Mural Oncology plc (MURA) (CIK 0001971543)
Date: July 25, 2023 · CIK: 0001971543 · Accession: 0000000000-23-007958
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United States securities and exchange commission logo
July 25, 2023
Iain Brown
Chief Financial Officer
Mural Oncology Ltd
10 Earlsfort Terrace
Dublin 2, D02 T380, Ireland
Re:Mural Oncology Ltd
Amendment No. 2 to
Draft Registration Statement on Form 10
Submitted July 14, 2023
CIK No. 0001971543
Dear Iain Brown:
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 Registration Statement on Form 10 as Confidentially Submitted on July 14,
2023
Business, page 105
1.We note your response to prior comment 6, which we reissue in part. There are still
numerous instances throughout the Information Statement where information presented in
your tables and figures appears to be printed in type that is too small to read. Even with
enhanced pixilation, such text is not legible. Please revise to ensure any included figures
and graphics can be read. By way of example only and not limitation, we note the
following:
•Text in the leftmost blue columns and in the "Indication" and "Dosing" columns of
FirstName LastNameIain Brown
Comapany NameMural Oncology Ltd
July 25, 2023 Page 2
FirstName LastName
Iain Brown
Mural Oncology Ltd
July 25, 2023
Page 2
your pipeline overview and discovery programs tables on page 112
•Text related to Part C in the dose expansion figure on page 116
•Line items on the x and y axes in many of your tables, such as on pages 120 and 121.
Safety Observations, page 122
2.We note your response to to prior comment 11 and the distinction between the severity of
adverse events as graded by the CTCAE and as defined by the FDA. Please disclose all
serious adverse events observed in ARTISTRY-1 meeting the FDA definition and
quantify the number of each type of event.
Conditions to the Distribution, page 173
3.You disclose that Alkermes in its sole discretion may waive any of the listed conditions to
the distribution, including that Alkermes shall have received a private letter ruling from
the IRS and a tax opinion from Goodwin Procter LLP. If Alkermes waives any
such condition and the changes, such as those resulting from different tax
consequences, would be material to Alkermes' shareholders, please tell us how such
changes will be communicated to shareholders.
Voting, page 192
4.We note your revisions in response to prior comment 14. We also note your reference to
your Constitution and your response letter's reference to Regulation 96 of your
Constitution.
•Please file your articles and bylaws or instruments corresponding thereto.
•Additionally, your disclosure is not clear as to when voting is decided on a show of
hands if all resolutions put to a vote of a general meeting of shareholders are to be
decided on a poll. Please clarify when a show of hands may or will determine the
vote. For example, will a show of hands determine the vote of a resolution at a
special meeting, for other questions that arise at a meeting for which a poll is not
demanded, or any other circumstances?
•Please incorporate risk factor disclosure describing the limitations on shareholder
voting rights in cases where show of hands voting can be used.
FirstName LastNameIain Brown
Comapany NameMural Oncology Ltd
July 25, 2023 Page 3
FirstName LastName
Iain Brown
Mural Oncology Ltd
July 25, 2023
Page 3
You may contact Frank Wyman at 202-551-3660 or Vanessa Robertson at 202-551-3649
if you have questions regarding comments on the financial statements and related
matters. Please contact Lauren Hamill at 303-844-1008 or Suzanne Hayes at 202-551-3675 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Robert E. Puopolo