Peter N. Handrinos Direct Dial: 617-948-6060 peter.handrinos@lw.com |
200 Clarendon Street Boston, Massachusetts 02116 Tel: +1.617.948.6000 Fax: +1.617.948.6001 www.lw.com | |||
![]() |
FIRM / AFFILIATE OFFICES | |||
Barcelona | Moscow | |||
Beijing | Munich | |||
Boston | New York | |||
February 23, 2018 |
Brussels | Orange County | ||
Century City | Paris | |||
Chicago | Riyadh | |||
Dubai | Rome | |||
Düsseldorf | San Diego | |||
Frankfurt | San Francisco | |||
Hamburg | Seoul | |||
Hong Kong | Shanghai | |||
VIA EDGAR AND OVERNIGHT DELIVERY | Houston | Silicon Valley | ||
London | Singapore | |||
Los Angeles | Tokyo | |||
Mr. Jeffrey Gabor | Madrid | Washington, D.C. | ||
Office of Healthcare and Insurance | Milan |
United States Securities and Exchange Commission
100 F Street, N.E.
Mail Stop 4720
Washington, D.C. 20549
Re: | Homology Medicines, Inc. |
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted January 30, 2018
CIK 0001661998
Dear Mr. Gabor:
On behalf of Homology Medicines, Inc., a Delaware corporation (the Company), we are transmitting this letter in response to comments received from the staff (the Staff) of the Securities and Exchange Commission by letter dated February 9, 2018 with respect to the Companys Confidential Draft Registration Statement on Form S-1 (as amended by Amendment No. 1, the Draft Registration Statement). This letter is being submitted together with Amendment No. 2 (Amendment No. 2) to the Draft Registration Statement, which has been revised to address various of the Staffs comments. The bold and numbered paragraph below corresponds to the numbered paragraph in the Staffs letter and is followed by the Companys response. For the Staffs convenience, we are also sending, by courier, copies of this letter and marked copies of Amendment No. 2 that reflect changes made to the Draft Registration Statement. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in the Draft Registration Statement.
February 23, 2018
Page 2
Prospectus Summary, page 1
1. | We note your response to comment 1. Please balance your disclosure in the Summary by clearly stating that you are a preclinical company, you have not submitted an IND for HMI-102 or any other product candidate, and that you will require additional capital to move beyond Phase 1/2. |
Response: The Company respectfully acknowledges the Staffs comment and in response has revised the disclosure on pages 1, 74 and 90 of Amendment No. 2.
We hope that the foregoing has been responsive to the Staffs comments and look forward to resolving any outstanding issues as quickly as possible. Please do not hesitate to contact me at 617-948-6060 or Wesley Holmes at 212-906-1366 with any questions or further comments you may have regarding this filing or if you wish to discuss the above.
Sincerely, |
/s/ Peter N. Handrinos
Peter N. Handrinos of LATHAM & WATKINS LLP |
Enclosures
cc: (via e-mail)
Arthur O. Tzianabos, Ph.D., President and Chief Executive Officer, Homology Medicines, Inc.
Wesley C. Holmes, Latham & Watkins LLP