April 5, 2022
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences
100 F Street, N.E.
Washington, D.C. 20549
Attention: Christine Torney
Vanessa Robertson
| Re: | Kazia Therapeutics Ltd |
Form 20-F for the fiscal year ended June 30, 2021
Filed October 7, 2021
File No. 000-29962
Ladies and Gentlemen:
Kazia Therapeutics Ltd (the “Company”) is providing this letter in response to comments (the “Comments”) received from the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance (the “Staff”) by letter dated March 22, 2022, with respect to the Company’s Annual Report on Form 20-F that was filed on October 7, 2021.
Set forth below is the Company’s response to the Comments, which for your convenience we have incorporated into this response letter. Capitalized terms used in this response letter but not otherwise defined in this response letter shall have the meanings set forth in the Annual Report.
Form 20-F for the fiscal year ended June 30, 2021
Item 5. Operating and Financial Review and Prospects
A. Operating Results
Expenses, page 22
| 1. | Please provide us with proposed disclosure to be included in future periodic reports which separately quantifies your research and development expense by project. If you do not track your research and development costs by project, disclose that fact as well as why you do not maintain and evaluate research and development costs by project. |
We acknowledge your comment and propose to disclose research and development expense by project in our future periodic reports in the following format (disclosures shown for FY21 report for illustrative purposes):
| A$’000 | FY21 | FY20 | ||||||
Paxalisib | ||||||||
- Phase II trial | 1,941 | 3,690 | ||||||
- GBM Agile trial | 8,148 | 1,523 | ||||||
- other paxalisib | 966 | 670 | ||||||
EVT801 | 1,098 | — | ||||||
Cantrixil | 429 | 1,673 | ||||||
R&D salaries | 694 | 854 | ||||||
Amortisation of licensed assets | 1,265 | 1,084 | ||||||
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Total R&D expense | 14,541 | 9,494 | ||||||
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Item 18. Financial Statements
Note 5. Revenue, page F-20
| 2. | Please tell us your consideration of providing disclosure of the out-license agreements with Oasmia and Simcere to separately quantify upfront payments and milestone payments by type, as these both appear to be material agreements. |
We offer the following comments in relation to this question:
| • | It is the Company’s view that we have complied with the disclosure requirements of IFRS 15 in our annual report on Form 20-F |
| • | We note that disclosure of the revenue earned from our out-license agreements with Oasmia and Simcere appears on pages 40 – 41 of our annual report on Form 20-F, showing that all revenue received in fiscal 2021 represents up front payments. |
| • | In future periodic reports, we will give consideration to providing additional voluntary disclosure in Note 5 to the financial statements, separately identifying upfront payments and milestone payments by type. |
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We appreciate your consideration.
Please feel free to contact me via email gabrielle.heaton@kaziatherapeutics.com.
Yours sincerely,
/s/ Gabrielle Heaton
Gabrielle Heaton
Director, Finance & Administration