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Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Response Received
1 company response(s)
High - file number match
SEC wrote to company
2025-03-11
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
↓
Company responded
2025-03-12
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Response Received
1 company response(s)
High - file number match
SEC wrote to company
2024-07-03
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
↓
Company responded
2024-07-31
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Response Received
1 company response(s)
High - file number match
SEC wrote to company
2023-10-12
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
↓
Company responded
2023-10-12
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Filing - Correspondence from Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP · 2023-10-12
Generating summary...
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Response Received
1 company response(s)
High - file number match
SEC wrote to company
2021-07-06
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
↓
Company responded
2021-07-13
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Response Received
1 company response(s)
High - file number match
SEC wrote to company
2020-07-02
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
↓
Company responded
2020-07-06
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Response Received
1 company response(s)
High - file number match
Company responded
2019-08-08
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
↓
SEC wrote to company
2019-08-09
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Filing - SEC Comment Letter to Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
UPLOAD · 2019-08-09
Generating summary...
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Response Received
4 company response(s)
High - file number match
Company responded
2017-11-16
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
References: October 10, 2017
↓
Company responded
2017-12-19
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
↓
Company responded
2017-12-19
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
↓
SEC wrote to company
2018-10-01
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
↓
Company responded
2018-10-12
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
References: October 1, 2018
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Response Received
1 company response(s)
High - file number match
SEC wrote to company
2018-03-12
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Filing - SEC Comment Letter to Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
UPLOAD · 2018-03-12
Generating summary...
↓
Company responded
2018-03-15
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Filing - Correspondence from Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP · 2018-03-15
Generating summary...
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Awaiting Response
0 company response(s)
Medium
SEC wrote to company
2017-10-11
Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
Summary
| Date | Type | Company | Location | File No | Link |
|---|---|---|---|---|---|
| 2025-03-12 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | Princeton, NJ | N/A | Read Filing View |
| 2025-03-11 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | Princeton, NJ | 333-285661 | Read Filing View |
| 2024-07-31 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2024-07-03 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | 333-280536 | Read Filing View |
| 2023-10-12 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2023-10-12 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2021-07-13 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2021-07-06 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2020-07-06 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2020-07-02 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2019-08-09 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2019-08-08 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2018-10-12 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2018-10-01 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2018-03-15 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2018-03-12 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2017-12-19 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2017-12-19 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2017-11-16 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2017-10-11 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| Date | Type | Company | Location | File No | Link |
|---|---|---|---|---|---|
| 2025-03-11 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | Princeton, NJ | 333-285661 | Read Filing View |
| 2024-07-03 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | 333-280536 | Read Filing View |
| 2023-10-12 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2021-07-06 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2020-07-02 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2019-08-09 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2018-10-01 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2018-03-12 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2017-10-11 | SEC Comment Letter | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| Date | Type | Company | Location | File No | Link |
|---|---|---|---|---|---|
| 2025-03-12 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | Princeton, NJ | N/A | Read Filing View |
| 2024-07-31 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2023-10-12 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2021-07-13 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2020-07-06 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2019-08-08 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2018-10-12 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2018-03-15 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2017-12-19 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2017-12-19 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
| 2017-11-16 | Company Response | Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) | DE | N/A | Read Filing View |
2025-03-12 - CORRESP - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP 1 filename1.htm GRACE THERAPEUTICS, INC. 103 Carnegie Center, Suite 300 Princeton, New Jersey 08540 March 12, 2025 VIA EDGAR Office of Life Sciences Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attention: Jason Drory Re: Grace Therapeutics, Inc. Registration Statement on Form S-3 Filed March 10, 2025 File No. 333-285661 Request for Acceleration of Effective Date To Whom it May Concern, Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Grace Therapeutics, Inc. hereby requests that the Securities and Exchange Commission accelerate the effective date of the above-referenced Registration Statement on Form S-3 and declare such Registration Statement effective as of 4:00 p.m., Eastern Time, on March 13, 2025, or as soon thereafter as possible. Please direct any questions or comments concerning this request to Steven Abrams of Hogan Lovells US LLP at (267) 675-4671. Also, please notify Mr. Abrams when this request for acceleration has been granted. Very truly yours, GRACE THERAPEUTICS, INC. By: /s/ Prashant Kohli Name: Prashant Kohli Title: Chief Executive Officer
2025-03-11 - UPLOAD - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) File: 333-285661
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> March 11, 2025 Prashant Kohli Chief Executive Officer Grace Therapeutics, Inc. 103 Carnegie Center, Suite 300 Princeton, NJ 08540 Re: Grace Therapeutics, Inc. Registration Statement on Form S-3 Filed March 10, 2025 File No. 333-285661 Dear Prashant Kohli: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Jason Drory at 202-551-8342 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Steve Abrams </TEXT> </DOCUMENT>
2024-07-31 - CORRESP - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP
1
filename1.htm
July 31, 2024
CORRESPONDENCE FILED VIA EDGAR
Office of Life Sciences
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Daniel Crawford
Re:
Acasti Pharma Inc.
Registration Statement on Form S-4 (File No. 333-280536)
Request for Acceleration of Effective Date
Dear Mr. Crawford:
Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Acasti Pharma Inc. (the “Company”) hereby respectfully
requests that the U.S. Securities and Exchange Commission accelerate the effective date and time of the above referenced Registration Statement on Form S-4 (the “Registration Statement”) and declare the
Registration Statement effective as of 4:00 p.m. Eastern Time on August 2, 2024, or as soon thereafter as practicable.
The Company requests that it be notified of such effectiveness by a telephone call to Steven Abrams of Hogan Lovells US LLP at (267) 675-4671.
[Signature page follows]
Sincerely,
Acasti Pharma Inc.
/s/ Prashant Kohli
Prashant Kohli
Chief Executive Officer and Director
2024-07-03 - UPLOAD - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192) File: 333-280536
July 3, 2024
Prashant Kohli
Chief Executive Officer
Acasti Pharma Inc.
103 Carnegie Center, Suite 300
Princeton, NJ 08540
Re:Acasti Pharma Inc.
Registration Statement on Form S-4
Filed June 27, 2024
File No. 333-280536
Dear Prashant Kohli:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that
the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact Daniel Crawford at 202-551-7767 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Steven Abrams, Esq.
2023-10-12 - UPLOAD - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
United States securities and exchange commission logo
October 12, 2023
Brian Ford
Interim Chief Financial Officer
Acasti Pharma Inc.
2572 boul. Daniel-Johnson, 2nd Floor
Laval, Québec, Canada H7T 2R3
Re:Acasti Pharma Inc.
Registration Statement on Form S-3
Filed October 6, 2023
File No. 333-274899
Dear Brian Ford:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact Joshua Gorsky at 202-551-7836 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Brandon Kinnard
2023-10-12 - CORRESP - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP 1 filename1.htm CORRESP ACASTI PHARMA INC. 2572 boul. Daniel-Johnson. 2nd Floor Laval, Québec, Canada H7T 2R3 October 12, 2023 VIA EDGAR Office of Life Sciences Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attn: Joshua Gorsky Re: Acasti Pharma Inc. Registration Statement on Form S-3 Filed October 6, 2023 File No. 333-274899 Request for Acceleration of Effective Date Dear Mr. Gorsky: Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Acasti Pharma Inc. hereby requests that the Securities and Exchange Commission accelerate the effective date of the above-referenced Registration Statement on Form S-3 and declare such Registration Statement effective as of 4:00 p.m., Eastern Time, on October 16, 2023, or as soon thereafter as possible. Please direct any questions or comments concerning this request to Brandon Kinnard of Hogan Lovells US LLP at (303) 454-2477. Also, please notify Mr. Kinnard when this request for acceleration has been granted. Very truly yours, ACASTI PHARMA INC. By: /s/ Prashant Kohli Name: Prashant Kohli Title: Chief Executive Officer MACROBUTTON DocID \\4133-8110-5740 v1
2021-07-13 - CORRESP - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP 1 filename1.htm CORRESP Acasti Pharma Inc. 3009 boul. De la Concorde E., Suite 102 Laval, Québec, Canada H7E 2B5 July 13, 2021 VIA EDGAR Fredrick Philantrope Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Acasti Pharma Inc. Registration Statement on Form S-4 Filed June 30, 2021 (as amended July 13, 2021) File No. 333-257589 Dear Mr. Philantrope: Pursuant to Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, the undersigned, on behalf of Acasti Pharma Inc., respectfully requests that the effective date of the Registration Statement on Form S-4 referred to above be accelerated so that it will become effective at 4:00 P.M. Eastern Time on July 15, 2021, or as soon as practicable thereafter. If you have any questions or require additional information, please contact Jason Comerford, Esq. of Osler, Hoskin & Harcourt LLP at (646) 528-8742. Thank you for your assistance and cooperation in this matter. Very truly yours, ACASTI PHARMA INC. By: /s/ Jan D’Alvise Jan D’Alvise Chief Executive Officer cc: Jason Comerford, Esq., Osler, Hoskin & Harcourt LLP François Paradis, Esq., Osler, Hoskin & Harcourt LLP
2021-07-06 - UPLOAD - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
United States securities and exchange commission logo
July 6, 2021
Jan D'Alvise
President, Chief Executive Officer and Director
Acasti Pharma Inc.
3009 boul. De la Concorde E., Suite 102
Laval, Quebec, Canada H7E 2B5
Re:Acasti Pharma Inc.
Registration Statement on Form S-4
Filed July 1, 2021
File No. 333-257589
Dear Ms. D'Alvise:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact Joe McCann at (202) 551-6262 or Fredrick Philantrope at (202) 551-6875
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Jason Comerford
2020-07-06 - CORRESP - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP
1
filename1.htm
July 6, 2020
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Re: Acasti Pharma Inc.
Registration Statement on Form S-3
File No. 333-239538
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended,
Acasti Pharma Inc., a Québec corporation (the “Company”), respectfully requests that the Securities and Exchange
Commission (the “Commission) accelerate the effective date of the above-referenced Registration Statement (the “Registration
Statement”) so that the same will become effective at 4:00 p.m. on July 7, 2020 or as soon thereafter as is practicable.
The Company also requests the Commission confirm the effective date and time of the Registration Statement to Company counsel,
Osler, Hoskin & Harcourt LLP, Attention: Jason Comerford, by email to JComerford@osler.com.
ACASTI PHARMA INC.
By:
/s/ Janelle D’Alvise
Name: Janelle D’Alvise
Title: Chief Executive Officer
2020-07-02 - UPLOAD - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
United States securities and exchange commission logo
July 2, 2020
Janelle D’Alvise
Chief Executive Officer
Acasti Pharma Inc.
545 Promenade du Centropolis, Suite 100
Laval, Québec, Canada H7T 0A3
Re:Acasti Pharma Inc.
Registration Statement on Form S-3
Filed June 30, 2020
File No. 333-239538
Dear Ms. D’Alvise:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact Jeffrey Gabor at 202-551-2544 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Jason Comerford, Esq.
2019-08-09 - UPLOAD - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
August 8, 2019
Janelle D'Alvise
Chief Executive Officer
Acasti Pharma Inc.
545 Promenade du Centropolis, Suite 100
Laval, Québec, Canada H7T 0A3
Re:Acasti Pharma Inc.
Registration Statement on Form F-3
Filed August 7, 2019
File No. 333-233063
Dear Ms. D'Alvise:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact Christine Westbrook at 202-551-5019 with any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Jason Comerford, Esq.
2019-08-08 - CORRESP - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP
1
filename1.htm
August 8, 2019
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Re: Acasti Pharma Inc.
Registration Statement on Form F-3
File No. 333-233063
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended,
Acasti Pharma Inc., a Québec corporation (the “Company”), respectfully requests that the Securities and Exchange
Commission (the “Commission) accelerate the effective date of the above-referenced Registration Statement (the “Registration
Statement”) so that the same will become effective at 4:00 p.m. on August 9, 2019 or as soon thereafter as is practicable.
The Company also requests the Commission confirm the effective date and time of the Registration Statement to Company counsel,
Osler, Hoskin & Harcourt LLP, Attention: Jason Comerford, by email to JComerford@osler.com.
ACASTI PHARMA INC.
By:
/s/ Janelle D’Alvise
Name: Janelle D’Alvise
Title: Chief Executive Officer
2018-10-12 - CORRESP - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP
1
filename1.htm
Osler, Hoskin & Harcourt llp
620 8th Avenue – 36th Floor
New York, N.Y. 10018
212.867.5800 main
212.867.5802 facsimile
New York
Toronto
Montréal
Calgary
Ottawa
Vancouver
October 12, 2018
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
Attention: Dorrie Yale and Erin Jaskot
Re:
Acasti Pharma Inc.
Post-Effective Amendment No. 1 to Registration Statement
on Form F-1
Filed September 21, 2018
File No. 333-220755
Ladies and Gentlemen:
On behalf of Acasti Pharma Inc. (the “Company”),
we are today filing with the U.S. Securities and Exchange Commission (the “Commission”) the Amendment No. 1
to Post-Effective Amendment No. 1 (the “Amendment No. 1”) to the Company’s registration statement on Form
F-1, first filed on September 29, 2017 and declared effective by the Commission on December 19, 2017. This Amendment No. 1 is filed
with the Commission in response to the comment received from the staff’s letter dated October 1, 2018.
For ease of review, the staff’s comment has been reproduced
below in italics, followed by the Company’s response.
Post-effective Amendment to Form F-1
General
1.
We note that you have omitted substantially all of the disclosure required by Part I of Form F-1 in this post-effective amendment to your registration statement on Form F-1. Please amend to include all of the disclosures required by Part I. Refer to Rule 472(b) of the Securities Act of 1933, as amended.
Response: Concurrently herewith, the Company has filed Amendment No. 1, which includes disclosures required by Part I of Form F-1. Pursuant to General Instruction VI of Form F-1, the Company
has elected to incorporate by reference reports filed by the Company under the Securities Exchange Act of 1934, as amended, to
provide the information required by Item 3 and Item 4 of Form F-1 in accordance with Item 4A and Item 5 of Form F-1.
Should you have any questions, please contact
the undersigned at 212-991-2533.
Sincerely,
/s/ Jason Comerford
cc:
Janelle D’Alvise, Acasti Pharma Inc.
Linda O’Keefe, Acasti Pharma Inc.
Jean-François Boily, Acasti Pharma Inc.
osler.com
2018-10-01 - UPLOAD - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
October 1, 2018
Janelle D’Alvise
President and Chief Executive Officer
Acasti Pharma Inc.
545 Promenade du Centropolis, Suite 100
Laval, Québec, Canada H7T 0A3
Re:Acasti Pharma Inc.
Post-effective Amendment No. 1 to
Registration Statement on Form F-1
Filed September 21, 2018
File No. 333-220755
Dear Ms. D’Alvise:
We have reviewed your post-effective amendment and have the following comment. 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 amending your registration statement and providing the
requested information. If you do not believe our 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 the comment, we may have additional comments.
Post-effective Amendment to Form F-1
General
1.We note that you have omitted substantially all of the disclosure required by Part I of
Form F-1 in this post-effective amendment to your registration statement on Form F-1.
Please amend to include all of the disclosures required by Part I. Refer to Rule 472(b) of
the Securities Act of 1933, as amended.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
FirstName LastNameJanelle D’Alvise
Comapany NameAcasti Pharma Inc.
October 1, 2018 Page 2
FirstName LastName
Janelle D’Alvise
Acasti Pharma Inc.
October 1, 2018
Page 2
Please contact Dorrie Yale at 202-551-8776 or Erin Jaskot at 202-551-3442 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Jason Comerford
2018-03-15 - CORRESP - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP 1 filename1.htm CORRESP March 15, 2018 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F. Street, N.E. Washington, D.C. 20549 Re: Acasti Pharma Inc. Registration Statement on Form F-3 File No. 333-223464 Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Acasti Pharma Inc., a Québec corporation (the “Company”), respectfully requests that the Securities and Exchange Commission (the “Commission) accelerate the effective date of the above-referenced Registration Statement (the “Registration Statement”) so that the same will become effective at 4:00 p.m. on March 16, 2018 or as soon thereafter as is practicable. The Company also requests the Commission confirm the effective date and time of the Registration Statement to Company counsel, Osler, Hoskin & Harcourt LLP, Attention: Jason Comerford, by email to JComerford@osler.com. ACASTI PHARMA INC. By: /s/ Janelle D’Alvise Name: Janelle D’Alvise Title: Chief Executive Officer
2018-03-12 - UPLOAD - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
March 12, 2018
Janelle D'Alvise
Chief Executive Officer
Acasti Pharma Inc.
545 Promenade du Centropolis, Suite 100
Laval, Quebec, Canada H7T 0A3
Re:Acasti Pharma Inc.
Registration Statement on Form F-3
Filed March 6, 2018
File No. 333-223464
Dear Ms. D'Alvise:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact Christine Westbrook at (202) 551-5019 with any questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Jason Comerford, Esq.
2017-12-19 - CORRESP - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP 1 filename1.htm CORRESP The Benchmark Company, LLC 150 E 58th Street, 17th floor New York, NY 10155 Dawson James Securities, Inc. 1 North Federal Highway, 5th Floor Boca Raton, FL 33432 December 19, 2017 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: Acasti Pharma, Inc. (the “Company”) Registration Statement on Form F-1 File No. 333-220755 Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), the undersigned, as underwriter of the proposed offering, hereby joins the request of Acasti Pharma, Inc. that the effective date of the above-referenced Registration Statement on Form F-1 be declared effective at 4:30 p.m. (Washington, D.C. time) on Tuesday, December 19, 2017, or as soon as practicable thereafter. In connection with this acceleration request and pursuant to Rule 460 under the Securities Act, please be advised that between December 15, 2017 and the date hereof, approximately 1,350 copies of the preliminary prospectus dated December 14, 2017 were distributed to underwriters, dealers, institutions and others. The undersigned advise that the underwriters have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. Sincerely, The Benchmark Company, LLC By: /s/ John J. Borer Name: John J. Borer Title: Senior Managing Director Dawson James Securities, Inc. By: /s/ Robert D. Keyser, Jr. Name: Robert D. Keyser, Jr. Title: CEO
2017-12-19 - CORRESP - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP 1 filename1.htm CORRESP December 19, 2017 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F. Street, N.E. Washington, D.C. 20549 Re: Acasti Pharma Inc. Registration Statement on Form F-1 File No. 333-220755 Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Acasti Pharma Inc., a Québec corporation (the “Company”) respectfully requests that the Securities and Exchange Commission (the “Commission) accelerate the effective date of the above-referenced Registration Statement (the “Registration Statement”) so that the same will become effective at 4:30 p.m. on December 19, 2017 or as soon thereafter as is practicable. The Company also requests the Commission confirm the effective date and time of the Registration Statement to Company counsel, Osler, Hoskin & Harcourt LLP, Attention: Jason Comerford, by email to JComerford@osler.com. ACASTI PHARMA INC. By: /s/ Janelle D’Alvise Name: Janelle D’Alvise Title: Chief Executive Officer
2017-11-16 - CORRESP - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
CORRESP 1 filename1.htm CORRESP New York Toronto Montréal Calgary Ottawa Vancouver Osler, Hoskin & Harcourt LLP 620 8th Avenue – 36th Floor New York, N.Y. 10018 212.867.5800 MAIN 212.867.5802 FACSIMILE November 16, 2017 VIA EDGAR U.S. Securities and Exchange Commission 100 F Street N.E. Washington, D.C. 20549 Attention: Jeffrey Gabor and Suzanne Hayes Re: Acasti Pharma Inc. Registration Statement on Form F-1 Filed September 29, 2017 File No. 333-220755 Ladies and Gentlemen: On behalf of Acasti Pharma Inc. (the “Company”), we are today filing with the U.S. Securities and Exchange Commission (the “Commission”) Amendment No. 1 to the Company’s registration statement on Form F-1, filed on September 29, 2017. Amendment No. 1 is filed with the Commission in response to the comments received from the Staff’s letter dated October 10, 2017 (the “Staff’s Letter”). For ease of review, the staff’s comments have been reproduced below in italics and numbered as in the Staff’s Letter, followed by the Company’s response. Form F-1 Filed September 29, 2017 1. Please revise your prospectus to disclose the number of shares to be offered. For guidance, please refer to Rule 430A and Compliance Disclosure Interpretation, Securities Act Rules, Question 227.02 Response: The registration statement cover page and certain other sections of the registration statement have been updated to disclose the number of shares expected to be offered. 2. We note that you have included your recent trading price on the prospectus cover page. Please clarify that the offering price will be substantially similar to the market price or describe the method by which the price is to be determined. See Instruction 2 to Item 501(b)(3) of Regulation S-K. Additionally, please explain the statement on page 101, “[A]fter the public offering, the offering price and other selling terms may be changed by the underwriters.” Response: The registration statement cover page has been updated to include the following statement: “The final public offering price will be determined through negotiation between us and the lead underwriters in the offering and the recent market price used throughout this prospectus may not be indicative of the final offering price.” In addition, we have deleted the statement “After the public offering of the shares, the offering price and other selling terms may be changed by the underwriters. Sales of shares made outside the United States may be made by affiliates of the underwriters.” from the Underwriting section of the registration statement. Should you have any questions with respect to this letter, please contact the undersigned at 212-991-2533. Sincerely, /s/ Jason Comerford cc: Janelle D’Alvise, Acasti Pharma Inc. Linda O’Keefe, Acasti Pharma Inc.
2017-10-11 - UPLOAD - Grace Therapeutics, Inc. (GRCE) (CIK 0001444192)
October 10, 2017 Janelle D’Alvise Chief Executive Officer Acasti Pharma Inc. 545 Promenade du Centropolis, Suite 100 Laval, Québec, Canada H7T 0A3 Acasti Pharma Inc. Registration Statement on Form F-1 Filed September 29, 2017 File No. 333-220755Re: Dear Ms. D’Alvise: We have limited our review of your registration statement to those issues we have addressed in our 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 amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Form F-1 Filed September 29, 2017 Cover Page 1. Please revise your prospectus to disclose the number of shares to be offered. For guidance, please refer to Rule 430A and Compliance Disclosure Interpretation, Securities Act Rules, Question 227.02 2. We note that you have included your recent trading price on the prospectus cover page. Please clarify that the offering price will be substantially similar to the market price or describe the method by which the price is to be determined. See Instruction 2 to Item 501(b)(3) of Regulation S-K. Additionally, please explain the statement on page 101, "[A]fter the public offering, the offering price and other selling terms may be changed by the underwriters." Janelle D’Alvise Acasti Pharma Inc. October 10, 2017 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Jeffrey Gabor at 202-551-2544 or Suzanne Hayes at 202-551-3675 with any questions. Division of Corporation Finance Office of Healthcare & Insurance cc: Jason Comerford
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