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United States securities and exchange commission logo
February 7, 2024
Carmine Stengone
Chief Executive Officer and President
Contineum Therapeutics, Inc.
10578 Science Center Drive, Suite 200
San Diego, California 92121
Re: Contineum
Therapeutics, Inc.
Amendment No. 1 to
Draft Registration Statement on Form S-1
Submitted January
29, 2024
CIK No. 0001855175
Dear Carmine Stengone:
We have reviewed your amended draft registration statement and have
the following
comments.
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 a comment applies 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 this
letter and your amended
draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are
to comments in our
January 11, 2024 letter.
Amendment No. 1 to Draft Registration Statement on Form S-1
Prospectus Summary
Company Overview, page 1
1. We note your response
to our prior comment 3 and reissue in part. You continue to
reference PIPE-791 as a
"highly differentiated" therapeutic for both IPF and Progressive
MS throughout the
prospectus. Please revise your disclosure to explain why you believe
this is the case,
providing support for the use of this term as necessary. In addition, please
revise your statement
that the company has "demonstrated" the ability to develop selective
compounds targeting
challenging molecular pathways, as the statement appears premature
given the company has
not received approval for or commercialized any of its product
candidates.
Carmine Stengone
Contineum Therapeutics, Inc.
February 7, 2024
Page 2
PIPE-791 for the Potential Treatment of IPF, page 2
2. We note the revisions made in response to our prior comment 4 on pages 2,
5, 114 and
117. Please revise your statement that you believe PIPE-791 "has the
potential to be the
first FDA-approved once-daily drug to treat IPF," which appears
equivalent to claiming it
is a first-in-class therapeutic, and is speculative given your current
stage of development.
Our Strategy, page 5
3. Please revise to remove your statements here and on page 117 that you
intend to "[r]apidly
pursue clinical development of PIPE-791" as it is speculative that you
may control the
pace of clinical development of your product candidates.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
93
4. We note your response to our prior comment 9 and reissue in part. Please
revise to
disclose the exact period of time the J&J License Agreement may expire
"after the first
commercial sale of such licensed product in such country."
Please contact Ibolya Ignat at 202-551-3636 or Kevin Kuhar at
202-551-3662 if you have
questions regarding comments on the financial statements and related matters.
Please contact
Daniel Crawford at 202-551-7767 or Laura Crotty at 202-551-7614 with any other
questions.
Sincerely,
FirstName LastNameCarmine Stengone
Division of
Corporation Finance
Comapany NameContineum Therapeutics, Inc.
Office of Life
Sciences
February 7, 2024 Page 2
cc: Jeffrey Thacker, Esq.
FirstName LastName