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September 21, 2020
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences
100 F Street, N.E.
Washington, D.C. 20549-3720
| Attention: | Ameen Hamady |
Kevin Kuhar
Deanna Virginio
Dorrie Yale
| Re: | PMV Pharmaceuticals, Inc. |
Registration Statement on Form S-1
Filed September 4, 2020
File No. 333-248627
Ladies and Gentlemen:
On behalf of our client, PMV Pharmaceuticals, Inc. (the “Company”), we submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in its letter dated September 16, 2020 (the “Comment Letter”), relating to the above referenced Registration Statement on Form S-1 (“Registration Statement”). We are concurrently submitting via EDGAR this letter and a revised draft of the Registration Statement (the “Submission No. 4”). For the Staff’s reference, we have included both a clean copy of Submission No. 4 and a copy marked to show all changes from the version filed on September 4, 2020.
In this letter, we have recited the comments from the Staff in italicized, bold type and have followed the comments with the Company’s response. Except for page references contained in the comments of the Staff, or as otherwise specifically indicated, page references herein correspond to the page of Submission No. 4.
Registration on Form S-1
Prospectus Summary, page 1
| 1. | We note your response to prior comment 2 that you have revised your disclosure on page 2 to disclose that the FDA will require post-approval trials to confirm clinical benefit. However, we note that you also refer to a pivotal Phase 1/2 trial on page 1, stating that the FDA “could” ask for additional trials. Please delete the last two sentences on page 1, as you already have a discussion about your belief of a potential pivotal trial on page 2. In addition, to the extent true, please also add on page 2 that you have not had any discussions with the FDA regarding the trial being a pivotal trial. |
AUSTIN BEIJING BOSTON BRUSSELS HONGKONG LONDON LOSANGELES NEWYORK PALOALTO
SANDIEGO SANFRANCISCO SEATTLE SHANGHAI WASHINGTON,DC WILMINGTON,DE
Securities and Exchange Commission
September 21, 2020
Page 2
The Company respectfully advises the Staff that in response to the Staff’s comments, the Company has revised the disclosure on page 1 to delete the last two sentences identified by the Staff and revised the disclosure on page 2 to indicate that the Company has not had any discussions with the FDA regarding the Company’s Phase 1/2 clinical trial having the potential to serve as a pivotal study.
* * * *
Securities and Exchange Commission
September 21, 2020
Page 3
Please direct any questions with respect to this confidential submission to me at (212) 497-7736 or mbaier@wsgr.com.
| Sincerely, |
| WILSON SONSINI GOODRICH & ROSATI |
| Professional Corporation |
| /s/ Megan J. Baier |
| Megan J. Baier |
| cc: | David Mack, Ph.D., PMV Pharmaceuticals, Inc. |
Winston Kung, PMV Pharmaceuticals, Inc.
Tony Jeffries, Wilson Sonsini Goodrich & Rosati, P.C.
Catherine Riley Tzipori, Wilson Sonsini Goodrich & Rosati, P.C.
Brian J. Cuneo, Latham & Watkins LLP
Richard Kim, Latham & Watkins LLP