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CORRESP Filing

Nasus Pharma Ltd
Date: July 28, 2025 · CIK: 0002029039 · Accession: 0001493152-25-011445

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File numbers found in text: 333-288582

Date
July 28, 2025
Author
Nasus
Form
CORRESP
Company
Nasus Pharma Ltd

Letter

Via EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Life Sciences Re: Nasus Pharma Ltd. (the "Company," "we," "our" and similar terminology) Registration Statement on Form F-1 Filed July 9, 2025 File No. 333-288582

Dear Sirs,

The purpose of this letter is to respond to the comment letter of July 16, 2025, received from the staff (the "Staff") of the U.S. Securities and Exchange Commission regarding the above-mentioned Registration Statement on Form F-1. For your convenience, your original comments appear in bold text, followed by our response. We are concurrently filing Amendment No. 1 to the Registration Statement on Form F-1 ("Amendment No. 1").

Page references in our responses are to Amendment No. 1. Unless otherwise stated, any defined terms in Amendment No. 1 apply within this letter.

Registration Statement on Form F-1

Business

Our Products

Intranasal Epinephrine (NS002), page 90

1. We note your revised disclosure on page 91 discussing data from your enantiomeric stability study between NS002 and Epinephrine. Please revise to disclose additional details about this study, including the number of samples tested, the age and manufacturer of the samples, whether the results are statistically significant and whether you can confirm the samples tested were handled, transported and stored according to the manufacturers' specifications.

Response : In response to the Staff's comment, we have revised the disclosure on pages 91-92 to include additional details about the enantiomeric stability study. The revised disclosure does not include the age of the samples (other than our NS002 sample stored for 24 months), as this data was not collected by the Company; however, the revised disclosure includes the expiration dates of the EpiPen samples used.

If you have any questions or require additional information, please contact our attorneys Eric Victorson, Esq. at (212) 660-3092 or Oded Har-Even, Esq. at (212) 660-5002, each of Sullivan & Worcester LLP.

Sincerely,
Nasus
pharma LTD .

Show Raw Text
CORRESP
 1
 filename1.htm

 Nasus
pharma ltd.

 Yigal
Alon 65

 Tel
Aviv, 6744317, Israel

 July
28, 2025

 Via
EDGAR

 Daniel
Crawford

 Alan
Campbell

 Securities
and Exchange Commission

 Division
of Corporation Finance

 Office
of Life Sciences

 100
F Street, NE

 Washington,
DC 20549

 Re:
 Nasus
 Pharma Ltd. (the "Company," "we," "our" and similar terminology)

 Registration
 Statement on Form F-1

 Filed
 July 9, 2025

 File
 No. 333-288582

 Dear
Sirs,

 The
purpose of this letter is to respond to the comment letter of July 16, 2025, received from the staff (the "Staff") of the
U.S. Securities and Exchange Commission regarding the above-mentioned Registration Statement on Form F-1. For your convenience, your
original comments appear in bold text, followed by our response. We are concurrently filing Amendment No. 1 to the Registration Statement
on Form F-1 ("Amendment No. 1").

 Page
references in our responses are to Amendment No. 1. Unless otherwise stated, any defined terms in Amendment No. 1 apply within this letter.

 Registration
Statement on Form F-1

 Business

 Our
Products

 Intranasal
Epinephrine (NS002), page 90

 1.
 We
 note your revised disclosure on page 91 discussing data from your enantiomeric stability study between NS002 and Epinephrine. Please
 revise to disclose additional details about this study, including the number of samples tested, the age and manufacturer of the samples,
 whether the results are statistically significant and whether you can confirm the samples tested were handled, transported and stored
 according to the manufacturers' specifications.

 Response :
In response to the Staff's comment, we have revised the disclosure on pages 91-92 to include additional details about the enantiomeric
stability study. The revised disclosure does not include the age of the samples (other than our NS002 sample stored for 24 months), as
this data was not collected by the Company; however, the revised disclosure includes the expiration dates of the EpiPen samples used.

 If
you have any questions or require additional information, please contact our attorneys Eric Victorson, Esq. at (212) 660-3092 or Oded
Har-Even, Esq. at (212) 660-5002, each of Sullivan & Worcester LLP.

 Sincerely,

 Nasus
pharma LTD .

 By:
 /s/
 Udi Gilboa

 Executive
 Chairman