A Cancer Therapeutics & Diagnostics Company
445 Northern Blvd. Suite 24 Great Neck NY 11021— Phone: (516) 482-1200 fax: (516) 482-3848
R&D Lab: 9700 Great Seneca Highway, Rockville, MD 20850 (240) 314-0596
www.neogenix.com
parlen@neogenix.com
July 29, 2010
VIA EDGAR AND OVERNIGHT COURIER
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Suzanne Hayes, Branch Chief
Division of Corporation Finance
Re: | Neogenix Oncology, Inc. (the “Company”) |
Amendment No. 3 to Registration Statement on Form 10-12G
Filed July 16, 2010
File No. 000-53963
Dear Ms. Hayes:
We are responding to the comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided on July 28, 2010 with respect to the Company’s Registration Statement on Form 10-12G (the “Form 10”). Your comment is presented in bold italics below, followed by the Company’s response.
General
1. | In response to prior comment 2, you state that you will provide a reasonable range. It is not clear how a rangewould be applicable since the amount of aggregate potential milestone payments under the agreement is amaterial term of the agreement that requires disclosure. Please confirm that if you enter into a licenseagreement you will disclose the aggregate potential milestone payments or explain how a range is applicable. |
Response: If the Company enters into a license agreement it will disclose the aggregate potential milestone payments.
Please feel free to contact our counsel, Mark Kass, by telephone at (202) 585-8181 or by fax at (866) 773-4656, or John Partigan, by telephone at (202) 585-8535 or by fax at (866) 947-3586, should you have any questions or further comments.
Sincerely, |
/s/ Dr. Philip Arlen Dr. Philip Arlen Chief Executive Officer |