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United States securities and exchange commission logo
June 9, 2021
Julien Gander, LL.M.
General Counsel
Molecular Partners AG
Wagistrasse 14
8952 Z rich-Schlieren
Switzerland
Re: Molecular Partners
AG
Amendment No. 3 to
Registration Statement on Form F-1
Filed June 9, 2021
File No. 333-255447
Dear Mr. Gander:
We have reviewed your amended 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 amending your registration
statement and providing the
requested information. 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 any amendment to your registration statement and
the information you
provide in response to these comments, we may have additional comments.
Amendment No. 3 to Registration Statement on Form F-1
Use of Proceeds, page 83
1. We note your disclosure
that you intend to advance the development of your infectious
disease program
including the expansion of your research and development activities for
COVID-19 antiviral
therapeutic product candidates using the proceeds of this offering.
Please revise to
disclose an estimate of how far in the development of your infectious
disease program the
proceeds from this offering will allow you to reach, including
the development of a
certain number of additional products, specific phases of clinical
trials or preclinical
testing.
Julien Gander, LL.M.
Molecular Partners AG
June 9, 2021
Page 2
Swiss Tax Implications for U.S. Holders, page 234
2. We note that the tax opinion filed as Exhibit 8.1 appears to be a
short-form tax opinion.
Please revise this section in your filing to clearly identify that the
"Swiss Tax Implications
for U.S. Holders" disclosure is the opinion of the counsel or accountant.
Please revise the
opinion to also include a similar statement. Counsel or the accountant
must opine on the
tax consequences of the offering, not the manner in which those
consequences are
described in the prospectus. For guidance, refer to Sections III.B.2 and
III.C.2 of Staff
Legal Bulletin No. 19.
You may contact Christie Wong at 202-551-3684 or Terence O'Brien at
202-551-3355 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 LastNameJulien Gander, LL.M.
Division of
Corporation Finance
Comapany NameMolecular Partners AG
Office of Life
Sciences
June 9, 2021 Page 2
cc: Ryan Sansom, Esq.
FirstName LastName