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United States securities and exchange commission logo
May 6, 2021
Julien Gander, LL.M.
General Counsel
Molecular Partners AG
Wagistrasse 14
8952 Z rich-Schlieren
Switzerland
Re: Molecular Partners
AG
Registration
Statement on Form F-1
Filed April 22,
2021
File No. 333-255447
Dear Mr. Gander:
We have reviewed your 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.
Registration Statement on Form F-1
Prospectus Summary, page 1
1. We note your revisions
in response to prior comment 1. Please remove references to the
"encouraging" activity
and/or tolerability of your programs on pages 6, 110 and 140.
Please also revise to
describe what you mean by "clinical benefit" on page 113.
Our Pipeline, page 2
2. We note your response
to our prior comment 3. Please remove the two discovery
programs from your
pipeline table. We will not object to a discussion of the programs
below the table.
Julien Gander, LL.M.
Molecular Partners AG
May 6, 2021
Page 2
Our Strategy, page 6
3. We note your revisions in response to prior comment 5. We also note
statements that
partnering with Novartis will allow you to more rapidly develop your
product candidate
and that your strategy is to rapidly advance the clinical development of
your COVID-19
antiviral therapeutic product candidates. Please revise this disclosure
to remove any
implication that you will be successful in commercializing your product
candidates in a
rapid or accelerated manner as such statements are speculative.
Principal Shareholders, page 179
4. We note your revisions in response to prior comment 17 and reissue in
part. Please revise
your disclosure to identify the natural person or persons who have voting
and investment
control of the shares held by Suvretta Capital Management, LLC and Essex
Woodlands
Health Ventures VIII, LLC. It appears that UBS Fund Management
(Switzerland) AG
may be a wholly-owned subsidiary of UBS Group AG. If this is correct,
please revise
footnote 8 to the table accordingly.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
You may contact Christie Wong at (202) 551-3648 or Terence O Brien at
(202) 551-3355
if you have questions regarding comments on the financial statements and
related matters. Please
contact Ada 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
May 6, 2021 Page 2
cc: Ryan Sansom, Esq.
FirstName LastName