July 18, 2019
July 18, 2019
Ms. Vanessa Countryman
Secretary
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-0609
Re: File No. S7-06-19: Amendments to the Accelerated Filer and Large Accelerated Filer Definitions
Dear Ms. Countryman:
Aequor, Inc is a pre-clinical-stage biotech company. We are pleased to support the SECs proposed rule to amend the definitions of accelerated and large accelerated filers.
Aequor has developed a portfolio of green, non-toxic chemical compounds that combat bacterial and fungal contamination and infection, including the antimicrobial-resistant strains (the Superbugs). We have initiated the process to go public in the near future as an emerging growth company (EGC). This will enable us access to public capital markets earlier in our growth cycle due to the 2012 JOBS Act onramp and regulary relief provisions.
Aequor is counting on the prospects of both the ability to access public capital markets and the regulatory relief afforded to EGCs so that we can dedicate our funds to RD in the anti-infective sector. This sector is particularly handicapped because of the perceived low ROI compared to the development of drugs that need to be taken every day for the rest of the patients lives (the blockbusters). Funding the research to find new antibiotics to combat the Superbugs is critical for biodefense and pandemic preparedness that are needed for the health and welfare of all societies.
If the proposed rule is implemented in its current form, Aequor and other future and current small public companies with less than the $100 million annual revenue cap and $700 million in public float will benefit from relief from Sarbanes-Oxley (SOX) 404(b) requirement of the auditors attestation of internal controls over financial reporting. This requirement disproportionately burdens companies like ours. We need the certainty and predictability provided by the proposed rule so that we can focus our resources on the already daunting challenges of clinical trials and other requirements for new drug approval from the Food and Drug Administration.
We strongly believe that this proposed rule will benefit Aequor and other small public companies engaged in innovation to discover new drugs to treat the most threatening health problems. We thank you for your efforts to expand relief from SOX 404(b) for small public companies and welcome this opportunity to comment.
Sincerely,
Marilyn Bruno, Ph.D.
Aequor, Inc.
www.aequorinc.com