DRSLTR 1 filename1.htm DRSLTR
LOGO   

425 MARKET STREET

SAN FRANCISCO

CALIFORNIA 94105-2482

 

TELEPHONE: 415.268.7000

FACSIMILE: 415.268.7522

 

WWW.MOFO.COM

  

MORRISON FOERSTER LLP

 

BEIJING, BERLIN, BRUSSELS, DENVER,

HONG KONG, LONDON, LOS ANGELES,

NEW YORK, NORTHERN VIRGINIA,

PALO ALTO, SACRAMENTO, SAN DIEGO,

SAN FRANCISCO, SHANGHAI,

SINGAPORE,

TOKYO, WASHINGTON, D.C.

July 17, 2017

Writer’s Direct Contact

+1-415-268-7197

JCampbell@mofo.com

CONFIDENTIAL SUBMISSION VIA EDGAR

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, DC 20549

 

Re: Krystal Biotech, Inc.

Draft Registration Statement on Form S-1

Ladies and Gentlemen:

On behalf of Krystal Biotech, Inc., a Delaware corporation (the “Company”) we are submitting a draft Registration Statement on Form S-1 (the “Registration Statement”) to the staff of the Securities and Exchange Commission (“SEC”) for confidential nonpublic review pursuant to Section 6(e) of the Securities Act of 1933, as amended (the “Securities Act”). The Registration Statement submitted herewith relates to the initial public offering of the Company’s common stock.

We confirm to you that as of the date of this letter, the Company is an emerging growth company, as defined in Section 2(a)(19) of the Securities Act, because its total gross revenues during the fiscal year ended December 31, 2016, its most recently completed fiscal year, were less than $1 billion. Please note this information is disclosed in the Company’s income statement included in the Registration Statement on page F-4. In addition, we confirm to you that as of the date of this letter none of the disqualifying conditions set forth in Section 2(a)(19) have occurred.

A formal filing of the Registration Statement will be made at a later date, which in no event will be later than 15 days before the Company commences its road show.


 

LOGO

July 17, 2017

Page Two

 

If you have any questions in connection with this filing, please do not hesitate to contact me at (415) 268-7197 or by e-mail at JCampbell@mofo.com.

Sincerely,

/s/ John W. Campbell, Esq.

 

Cc: Krish S. Krishnan (krish@krystalbio.com)

Emiko Kurotsu, Esq. (ekurotsu@mofo.com)

Michael Maline, Esq. (mmaline@goodwinlaw.com)

Seo Salimi, Esq. (ssalimi@goodwinlaw.com)

Enclosures