Correspondence 0001213900-24-104983 from Jabez Biosciences, Inc. (CIK 0002038185)
Jabez Biosciences, Inc. (CIK 0002038185)
Date: Dec. 3, 2024 · CIK: 0002038185 · Accession: 0001213900-24-104983
AI Filing Summary & Sentiment
File numbers found in text: 024-12509
Letter
United States Securities and Exchange Commission Office of Life Sciences Re: Jabez Biosciences, Inc. Amendment No. 2 to Offering Statement on Form 1-A Filed November 20, 2024 File No. 024-12509
Dear Mr. Gorsky and Mses. Gama, Torney and Mast,
We are in receipt of your comment letter dated in the above referenced matter and hereby respond to same as follows:
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.
RESPONSE: We have amended the Form 1-A/A accordingly.
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.
RESPONSE: We have amended the Form 1-A/A accordingly.
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.
RESPONSE: We have amended the Form 1-A/A accordingly.
Respectfully Submitted,
/s/ Tamara
Jovonovich
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CORRESP
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filename1.htm
JABEZ BIOSCIENCES,
INC.
6393
Blackstone Dr.
Zionsville,
IN 46077
December
3, 2024
Doris
Stacey Gama
Joshua
Gorsky
Christine
Torney
Mary
Mast
United
States Securities and Exchange Commission
Office
of Life Sciences
Washington,
DC
Re:
Jabez
Biosciences, Inc.
Amendment
No. 2 to Offering Statement on Form 1-A
Filed
November 20, 2024
File No.
024-12509
Dear
Mr. Gorsky and Mses. Gama, Torney and Mast,
We
are in receipt of your comment letter dated in the above referenced matter and hereby respond to same as follows:
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.
RESPONSE:
We have amended the Form 1-A/A accordingly.
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.
RESPONSE:
We have amended the Form 1-A/A accordingly.
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.
RESPONSE:
We have amended the Form 1-A/A accordingly.
Respectfully Submitted,
/s/ Tamara
Jovonovich
Tamara Jovonovich, President