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| February 16, 2021 | Düsseldorf | San Diego | ||||
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VIA EDGAR
Ms. Ada D. Sarmento Office of Life Sciences Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street N.E. Washington, D.C. 20549 |
Frankfurt Hamburg Hong Kong Houston London Los Angeles Madrid Milan |
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| Re: | Connect Biopharma Holdings Limited |
| Amendment No. 1 to Draft Registration Statement on Form F-1 |
| Submitted January 26, 2021 |
| CIK No. 0001835268 |
Dear Ms. Sarmento:
We are in receipt of the Staffs letter dated February 10, 2021 with respect to the above-referenced confidential draft Registration Statement (the Draft Registration Statement). We are responding to the Staffs comments on behalf of Connect Biopharma Holdings Limited (Connect Biopharma or the Company) as set forth below. Simultaneously with the submission of this letter, the Company is confidentially submitting via EDGAR Amendment No. 2 to its Registration Statement on Form F-1 (the Amendment) responding to the Staffs comments and updating the Draft Registration Statement.
The Companys responses set forth in this letter are numbered to correspond to the numbered comments in the Staffs letter. All terms used but not defined herein have the meanings assigned to such terms in the Amendment. For ease of reference, we have set forth the Staffs comments and the Companys response for each item below.
Amendment No. 1 to Draft Registration Statement on Form F-1
Prospectus Summary
Our Pipeline, page 1
| 1. | We note your revisions in response to prior comment 1. Please revise all performance claims so that the basis for each statement is clear and you avoid any suggestion that your candidate has demonstrated efficacy. For example, you state that the administration of CBP-201 in your Phase 1b trial led to rapid improvements in signs and symptoms of AD disease activity. Please provide the objective data from your Phase 1b trial that supports this statement. You also state that pharmacokinetic data from your Phase 1a trial suggest that the CBP-201 dose could be administered every four weeks. Please provide the objective data from your Phase 1a trial that supports this statement. Also, please revise to provide the objective data that supports your belief that CBP-201 has the potential to have a faster onset of action and a greater clinical |
February 16, 2021
Page 2
| response than the current standard of care. If the detail that is required to support these statements is too lengthy for the prospectus summary, please remove the statements from the prospectus summary. |
Connect Biopharmas Response: The Company has revised the disclosure on pages 2, 115, 119, 121, 122, 125 and 127 of the Amendment in response to the Staffs comment.
Business
Role of S1P1 in inflammation, page 129
| 2. | We note your revisions in response to prior comment 4. Please remove the reference to favorable results in prior clinical trials of second generation S1P1 modulators since that may imply efficacy. |
Connect Biopharmas Response: The Company has revised the disclosure on page 131 of the Amendment in response to the Staffs comment.
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Any comments or questions regarding the foregoing should be directed to the undersigned at 858-523-3959. Thank you in advance for your cooperation in connection with this matter.
Very truly yours,
/s/ Michael E. Sullivan
Michael E. Sullivan
of LATHAM & WATKINS LLP
| cc: | Eric Atallah, Securities and Exchange Commission |
Vanessa Robertson, Securities and Exchange Commission
Tim Buchmiller, Securities and Exchange Commission
Zheng Wei, Ph.D., Connect Biopharma Holdings Limited
Wubin Pan, Ph.D., Connect Biopharma Holdings Limited
Patrick A. Pohlen, Latham & Watkins LLP
Jeffrey T. Woodley, Latham & Watkins LLP