SEC Comment Letter 0000000000-24-013213 to Jabez Biosciences, Inc. (CIK 0002038185)
Jabez Biosciences, Inc. (CIK 0002038185)
Date: Nov. 27, 2024 · CIK: 0002038185 · Accession: 0000000000-24-013213
AI Filing Summary & Sentiment
File numbers found in text: 024-12509
Letter
November 27, 2024 Tamara Jovonovich Chief Executive Officer Jabez Biosciences, Inc. 6393 Blackstone Dr. Zionsville, IN 46077 Re:Jabez Biosciences, Inc. Amendment No. 2 to Offering Statement on Form 1-A Filed November 20, 2024 File No. 024-12509 Dear Tamara Jovonovich: We have reviewed your amended offering statement and have the following comments. Please respond to this letter by amending your offering statement and providing the requested information. 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 any amendment to your offering 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 November 13, 2024 letter. Amendment No. 2 to Offering Statement on Form 1-A Regulatory Process, page 23 1.We note your response to prior comment 4 and reissue in part. You state that performance of adequate and well-controlled clinical trials in accordance with good clinical practice are required for the FDA to approve a new drug application. Please expand your disclosure to provide further details regarding the regulatory structure of the clinical trials referenced.
November 27, 2024 Page 2 Technology Rights, page 26 2.In response to prior comment 6 we note that you have identified certain technology rights as "not associated with any patents or patent applications[.]" Please provide further details regarding the items listed in this section, such as how you obtained these rights and if they are being licensed from a third party. Directors and Executive Officers, page 31 3.In response to prior comment 7 you state that Robert Lewis, your Chief Operating Officer, also serves as "the President and a Director of NOK Therapeutics, Inc." Please revise your disclosure to state the total number of hours per week that Robert Lewis anticipates working for Jabez Biosciences, Inc. Refer to Item 10(a) of Form 1-A. Further, please include an appropriate risk factor discussing any risks associated with having a part-time Chief Operating Officer. Please contact Christine Torney at 202-551-3652 or Mary Mast at 202-551-3613 if you have questions regarding comments on the financial statements and related matters. Please contact Doris Stacey Gama at 202-551-3188 or Joshua Gorsky at 202-551- 7836 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc:Jim Byrd
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November 27, 2024
Tamara Jovonovich
Chief Executive Officer
Jabez Biosciences, Inc.
6393 Blackstone Dr.
Zionsville, IN 46077
Re:Jabez Biosciences, Inc.
Amendment No. 2 to Offering Statement on Form 1-A
Filed November 20, 2024
File No. 024-12509
Dear Tamara Jovonovich:
We have reviewed your amended offering statement and have the following
comments.
Please respond to this letter by amending your offering statement and providing the
requested information. 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 any amendment to your offering 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 November 13,
2024 letter.
Amendment No. 2 to Offering Statement on Form 1-A
Regulatory Process, page 23
1.We note your response to prior comment 4 and reissue in part. You state that
performance of adequate and well-controlled clinical trials in accordance with good
clinical practice are required for the FDA to approve a new drug application. Please
expand your disclosure to provide further details regarding the regulatory structure of
the clinical trials referenced.
November 27, 2024
Page 2
Technology Rights, page 26
2.In response to prior comment 6 we note that you have identified certain technology
rights as "not associated with any patents or patent applications[.]" Please provide
further details regarding the items listed in this section, such as how you obtained
these rights and if they are being licensed from a third party.
Directors and Executive Officers, page 31
3.In response to prior comment 7 you state that Robert Lewis, your Chief Operating
Officer, also serves as "the President and a Director of NOK Therapeutics,
Inc." Please revise your disclosure to state the total number of hours per week that
Robert Lewis anticipates working for Jabez Biosciences, Inc. Refer to Item 10(a) of
Form 1-A. Further, please include an appropriate risk factor discussing any risks
associated with having a part-time Chief Operating Officer.
Please contact Christine Torney at 202-551-3652 or Mary Mast at 202-551-3613 if
you have questions regarding comments on the financial statements and related
matters. Please contact Doris Stacey Gama at 202-551-3188 or Joshua Gorsky at 202-551-
7836 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Jim Byrd