0001193125-14-018868.txt : 20140423 0001193125-14-018868.hdr.sgml : 20140423 20140123172333 ACCESSION NUMBER: 0001193125-14-018868 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20140123 FILER: COMPANY DATA: COMPANY CONFORMED NAME: APPLIED GENETIC TECHNOLOGIES CORP CENTRAL INDEX KEY: 0001273636 STANDARD INDUSTRIAL CLASSIFICATION: BIOLOGICAL PRODUCTS (NO DIAGNOSTIC SUBSTANCES) [2836] IRS NUMBER: 593553710 STATE OF INCORPORATION: DE FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11801 RESEARCH DRIVE STREET 2: SUITE D CITY: ALACHUA STATE: FL ZIP: 32615 BUSINESS PHONE: 386-462-2204 MAIL ADDRESS: STREET 1: 11801 RESEARCH DRIVE STREET 2: SUITE D CITY: ALACHUA STATE: FL ZIP: 32615 CORRESP 1 filename1.htm CORRESP
  

Seaport West

155 Seaport Boulevard

Boston, MA 02210-2600

617 832 1000 main

617 832 7000 fax

January 23, 2014   

Robert W. Sweet, Jr.

617 832 1160 direct

rws@foleyhoag.com

 

 

Via EDGAR

Mr. Jeffrey P. Riedler

Assistant Director

United States Securities and Exchange Commission

Division of Corporate Finance

100 F. Street, NE

Washington, DC 20549

 

 

  Re: Applied Genetic Technologies Corporation
       CIK No. 0001273636
       Registration Statement on Form S-1
       File No. 333-193309

 

Dear Mr. Riedler:

On January 10, 2014, Applied Genetic Technologies Corporation (“AGTC”) filed with the Securities and Exchange Commission (the “Commission”) its registration statement on Form S-1 (File No. 333-193309) (the “Registration Statement”), in accordance with the Securities Act of 1933, as amended.

The Registration Statement reflects changes to AGTC’s previously submitted draft registration statement on Form DRS relating to the same offering, as amended, made in response to the comments of the Staff set forth in the Commission’s letter dated January 6, 2014. The heading and numbered paragraph below correspond to the headings and numbered paragraphs of the Commission’s letter. References to page numbers (other than in headings taken from the Commission’s letter) are to pages of the prospectus which forms a part of the Registration Statement. Other changes have also been made, as indicated in the marked

Mr. Jeffrey P. Riedler

January 23, 2014

Page 2

 

materials submitted to the Commission contemporaneously with the filing of the Registration Statement.

On behalf of AGTC, we respond to the specific comments of the Staff as follows:

Our Business, page 84

License Agreements, page 112

1. We note your response to our prior comment 17. Please revise your description of the material terms for each of your license agreements to disclose the aggregate maximum potential payments that you may be required to pay upon achievement of development, regulatory and/or commercial milestones. Please also clarify that the requested aggregate amounts are disclosed on a per product basis. In relation to your request for confidential treatment with respect to the license agreements, please note that we are generally willing to grant confidential treatment for individual milestone payments provided that the aggregate amount of such payments is disclosed in the prospectus.

Response: The description of the license agreements beginning on page 112 has been revised to disclose the aggregate maximum potential payments that AGTC may be required to pay upon achievement of development, regulatory and/or commercial milestones, presented on a per product basis.

If you have any questions regarding this filing or these supplemental responses, please do not hesitate to contact me at (617) 832-1160.

Sincerely,

/s/ Robert W. Sweet, Jr.

Robert W. Sweet, Jr.

RWS:

 

cc: Susan B. Washer