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ONCOLYTICS BIOTECH INC
CIK: 0001129928  ·  File(s): 333-289819  ·  Started: 2025-08-27  ·  Last active: 2025-08-27
Response Received 1 company response(s) High - file number match
UL SEC wrote to company 2025-08-27
ONCOLYTICS BIOTECH INC
File Nos in letter: 333-289819
CR Company responded 2025-08-27
ONCOLYTICS BIOTECH INC
File Nos in letter: 333-289819
ONCOLYTICS BIOTECH INC
CIK: 0001129928  ·  File(s): 000-31062  ·  Started: 2016-11-01  ·  Last active: 2016-11-01
Response Received 1 company response(s) High - file number match
CR Company responded 2016-10-14
ONCOLYTICS BIOTECH INC
File Nos in letter: 000-31062
References: September 30, 2016
Summary
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UL SEC wrote to company 2016-11-01
ONCOLYTICS BIOTECH INC
File Nos in letter: 000-31062
Summary
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ONCOLYTICS BIOTECH INC
CIK: 0001129928  ·  File(s): N/A  ·  Started: 2016-09-30  ·  Last active: 2016-09-30
Awaiting Response 0 company response(s) Medium
UL SEC wrote to company 2016-09-30
ONCOLYTICS BIOTECH INC
Summary
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DateTypeCompanyLocationFile NoLink
2025-08-27 Company Response ONCOLYTICS BIOTECH INC NV N/A Read Filing View
2025-08-27 SEC Comment Letter ONCOLYTICS BIOTECH INC NV 333-289819 Read Filing View
2016-11-01 SEC Comment Letter ONCOLYTICS BIOTECH INC NV N/A Read Filing View
2016-10-14 Company Response ONCOLYTICS BIOTECH INC NV N/A Read Filing View
2016-09-30 SEC Comment Letter ONCOLYTICS BIOTECH INC NV N/A Read Filing View
DateTypeCompanyLocationFile NoLink
2025-08-27 SEC Comment Letter ONCOLYTICS BIOTECH INC NV 333-289819 Read Filing View
2016-11-01 SEC Comment Letter ONCOLYTICS BIOTECH INC NV N/A Read Filing View
2016-09-30 SEC Comment Letter ONCOLYTICS BIOTECH INC NV N/A Read Filing View
DateTypeCompanyLocationFile NoLink
2025-08-27 Company Response ONCOLYTICS BIOTECH INC NV N/A Read Filing View
2016-10-14 Company Response ONCOLYTICS BIOTECH INC NV N/A Read Filing View
2025-08-27 - CORRESP - ONCOLYTICS BIOTECH INC
CORRESP
 1
 filename1.htm

 ONCOLYTICS BIOTECH INC.

 Suite 804, 322 11th Avenue SW

 Calgary, Alberta, Canada, T2R 0C5

 VIA EDGAR

 August 27, 2025

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Life Sciences

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention:

 Tyler Howes

 Re:

 Oncolytics
Biotech Inc.

 Registration Statement on Form
F-3

 File No. 333-289819

 To the addressee set forth above:

 Pursuant to Rule 461 of the
U.S. Securities Act of 1933, as amended, Oncolytics Biotech Inc. (the "Company") hereby requests acceleration of the effective
date of its registration statement on Form F-3 (File No. 333-289819) (the "Registration Statement"), to 4:00 p.m. Eastern
Time on August 29, 2025, or as soon thereafter as practicable.

 Please contact Christopher
J. Clark of Latham & Watkins LLP, special U.S. counsel to the Company, at (202) 637-2374 or Christopher.J.Clark@lw.com, as soon as
the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

 Very truly yours,

 ONCOLYTICS BIOTECH INC.

 By:
 /s/ Kirk Look

 Name:
 Kirk Look

 Title:
 Chief Financial Officer

 cc: 	Christopher J. Clark, Esq., Latham & Watkins LLP
2025-08-27 - UPLOAD - ONCOLYTICS BIOTECH INC File: 333-289819
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 27, 2025

Jared Kelly
Chief Executive Officer
Oncolytics Biotech Inc.
4350 Executive Drive, Suite 325
San Diego, CA 92121

 Re: Oncolytics Biotech Inc.
 Registration Statement on Form F-3
 Filed August 22, 2025
 File No. 333-289819
Dear Jared Kelly:

 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 Tyler Howes at 202-551-3370 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Christopher J. Clark, Esq.
</TEXT>
</DOCUMENT>
2016-11-01 - UPLOAD - ONCOLYTICS BIOTECH INC
Mail Stop 4546

 November 1, 2016

Kirk Look
Chief Financial Officer
Oncolytics Biotech Inc.
Suite 210, 1167 Kensington Crescent, N.W.
Calgary, Alberta, T2N 1X7

Re: Oncolytics Biotech Inc.
Form 20 -F for Fiscal Year Ended December 31, 2015
Filed March 24, 2016
File No. 000-31062

Dear  Mr. Look :

We have completed our review of your filing .  We remind you that the company and its
management are responsible for the accuracy and adequacy of the ir disclosure s, notwithstanding
any review, comments, action or absence  of action  by the staff .

Sincerely,

 /s/ Suzanne Hayes

Suzanne Hayes
Assistant Director
Office of Healthcare and Insurance

cc: Jason K. Brenkert, Esq.
Dorsey & Whitney LLP
2016-10-14 - CORRESP - ONCOLYTICS BIOTECH INC
Read Filing Source Filing Referenced dates: September 30, 2016
CORRESP
1
filename1.htm

October 13, 2016

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

Attention: Suzanne Hayes and Jeffrey Gabor

Re:
Responses to the Securities and Exchange Commission

Staff Comments dated September 30, 2016, regarding

Oncolytics Biotech Inc.

Form 20-F for Fiscal Year Ended December 31, 2015

Filed March 24, 2016

 File No. 000-31062

Ladies and Gentlemen:

This letter responds to the staff’s comments set forth in the September 30, 2016 letter regarding the above-referenced Annual Report on Form 20-F (the “Annual Report”) of Oncolytics Biotech Inc. For your convenience, the staff’s comments are included below and we have numbered our responses accordingly.

In some of the responses, we have agreed to change or supplement the disclosure contained in the Annual Report in our future filings.  We are doing so in the spirit of cooperation with the staff of the Securities and Exchange Commission, and not because we believe our prior filing was materially deficient or inaccurate.

We have also indicated in some responses that we believe no change in disclosure in the Annual Report is appropriate and have explained why.

Our responses are as follows:

The Clinical Trial Chart, page 17

Staff Comment No. 1.

In some instances it appears that the trial number identifies the party conducting the trial. However, the reference does not appear consistent.  For example, the description of “US Phase 1b Multiple Myeloma” in exhibit 15.1, appears to describe the trial identified as REO 019 in the clinical trial chart. However, the chart does not identify USC as a sponsor. Additionally, it is not clear if COG and REO are intended to identify trial sponsors. In future filings, please clarify the trial sponsor.

Company’s Response:

The Company agrees that in its future filings it will ensure that for each of its clinical trials the disclosure clearly identifies the trial sponsor.

Exhibit 15.1 Management’s Discussion and Analysis

Clinical Trial Program

Staff Comment No. 2.

We note your disclosure that various other parties sponsor trials and that you supply REOLYSIN for use during the trial, intellectual capital to support the principal investigators and in some cases cost sharing. Please expand the discussion to more fully describe each party’s rights and obligations under each of your third party agreements.

Company’s Response:

With respect to the clinical trials sponsored by other third parties, the Company’s disclosure in Exhibit 15.1 Management’s Discussion and Analysis accurately describes the obligations of each party.

With respect to the Company, we are obliged to provide study drug (REOLYSIN) and assist the principal investigator when there are questions with respect to the study drug.  In addition, the Company has a financial responsibility that is also set forth in the respective clinical trial agreement for each such trial.

With respect to the third party (the “Investigator”), the respective Investigator is obligated to conduct the study as defined by the protocol.  This includes patient screening and enrollment, treatment, monitoring and the overall clinical trial management and reporting.  The Investigator must also comply with the respective regulations promulgated by the relevant jurisdiction.

The Company’s financial commitment related to these third party sponsored trials is disclosed as part of Exhibit 15.1 - Contractual Obligations.  Included in the purchase obligation amount of $2,083,331 is $480,693 related to these third party clinical trials. The Company does not believe that its financial obligations under its third party clinical trial agreements are substantial enough to be material to the Company.

There are no royalties or other rights granted to third parties relating to approved products.

Staff Comment No. 3.

Please provide your analysis supporting your conclusion that none of the third party clinical trial agreements are required to be filed as an exhibit.

Company’s Response:

The Company analyzed the requirement to file agreements as exhibits to the Annual Report pursuant to Form 20-F’s “Instructions as to Exhibits.” Specifically, instruction 4(b), which provides, in relevant part, that “[i]f a contract is the type that ordinarily accompanies the kind of business you and your subsidiaries conduct, we will consider it have been made in the ordinary course of business and will not require you to file it, unless it falls within one or more [categories].”

Specifically, the Company concluded that these clinical trial agreements, where the sponsor of the clinical study is a third party (Third Party Sponsored Clinical Trials), have been entered into in the normal course of our business, and therefore, have been made in the “ordinary course of business.”  The terms of our Third Party Sponsored Clinical Trials are similar to the terms of the clinical trial agreements we enter into when the Company is the sponsor.

Further, of the relevant categories that may still require the filing of an ordinary course agreement as set forth in instruction 4(b), none of the Third Party Sponsored Clinical Trial agreements falls into those categories; the most relevant being instruction 4(b)(ii), an agreement on which the business of the Company is substantially dependent.

The Company has not entered into a Third Party Sponsored Clinical Trial agreement on which it is substantially dependent.  In 2015, we had 12 clinical studies ongoing investigating different cancer indications.  Consequently, given the breadth of our overall clinical program, we concluded that the Company is not substantially dependent upon any one contract for its ongoing business.

* * * * *

Thank you for your review of the filing.  If you should have any questions regarding the response letter, please do not hesitate to contact the undersigned at (403) 670-7658 or Jason K. Brenkert of Dorsey & Whitney LLP at (303) 352-1133.

Sincerely,

Oncolytics Biotech Inc.

/s/ Kirk Look

Kirk Look

Chief Financial Officer

cc: Jason Brenkert, Dorsey & Whitney LLP
2016-09-30 - UPLOAD - ONCOLYTICS BIOTECH INC
September 30, 2016

Kirk Look
Chief Financial Officer
Oncolytics Biotech Inc.
Suite 210, 1167 Kensington Crescent, N.W.
Calgary, Alberta, T2N 1X7

Re: Oncolytics Biotech Inc.
 Form 20-F for Fiscal Year Ended December 31, 201 5
Filed March 24, 2016
File No. 000 -31062

Dear  Mr. Look:

We have reviewed your filing an d 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

The Clinical Trial Chart, page 17

1.  In some instance s it appears that the trial number identifies the party conducting the trial.
However, the reference does not appear consistent.  For example, the description of “US
Phase 1b Multiple Myeloma” in exhibit 15.1, appears to describe the trial identified as
REO 019 in the clinical trial chart. However, the chart does not identify USC as a
sponsor.  Additionally, it is not clear if COG and REO are intended to identify trial
sponsors.   In future filings, please clarify the trial sponsor.

Exhibit 15.1 Managemen t’s Discussion and Analysis

Clinical Trial Program

2. We note your disclosure that various other parties sponsor trials and that you supply
REOLYSIN for use during the trial, intellectual capital to support the principal
investigators and in some cases c ost sharing.  Please expand the discussion to more fully
describe each party’s rights and obligations under each of your third party agreements.

Kirk Look
Oncolytics Biotech Inc.
September 30, 2016
Page 2

 To the extent you have committed to provide financial support to the trial, please quantify
your commitments.  To the extent the third party will have royalty or other rights to any
approved products, please describe these rights.

3. Please provide your analysis supporting your conclusion that none of the third pa rty
clinical trial agreements are  required to be f iled as an exhibit.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requ ire.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from  taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please contact Jeffrey Gabor  at (202) 551 -2544  or Suzanne Hayes at (202) 551 -3675 with
any questions.

Sincerely,

 /s/ Suzanne Hayes

Suzanne Hayes
Assistant Director
Office of Healthcare and Insurance

cc: Jason K. Brenkert, Esq.
Dorsey & Whitney LLP