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February 10, 2021
Zheng Wei, Ph.D.
Chief Executive Officer
Connect Biopharma Holdings Limited
Science and Technology Park
East R&D Building, 3rd Floor
6 Beijing West Road, Taicang
Jiangsu Province, China 215400
Re: Connect Biopharma
Holdings Limited
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted January
26, 2021
CIK No. 0001835268
Dear Dr. Wei:
We have reviewed your amended draft registration statement and
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 this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.
After reviewing the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
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
Zheng Wei, Ph.D.
Connect Biopharma Holdings Limited
February 10, 2021
Page 2
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 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.
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.
You may contact Eric Atallah at 202-551-3663 or Vanessa Robertson at
202-551-3659 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Ada D. Sarmento at 202-551-3798 or Tim Buchmiller at 202-551-3635 with
any other
questions.
Sincerely,
FirstName LastNameZheng Wei, Ph.D.
Division of
Corporation Finance
Comapany NameConnect Biopharma Holdings Limited
Office of Life
Sciences
February 10, 2021 Page 2
cc: Patrick A. Pohlen, Esq.
FirstName LastName