IMMUNOMEDICS, INC.
300 THE AMERICAN ROAD
MORRIS PLAINS, NEW JERSEY, 07950
September 18, 2017
Via EDGAR and e-mail
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Judiciary Plaza
Washington, DC 20549-4561
Mail Stop 3010
Attn: Irene Paik
Re: Acceleration Request of Immunomedics, Inc. (the “Company”) Form S-3, File No. 333-219594 (the “Registration Statement”)
Dear Ms. Paik:
The Company hereby requests, pursuant to conversations with the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) that the effective date for the Registration Statement referred to above be accelerated so that it will be declared effective at 9:30 a.m. (Eastern) on September 19, 2017, or as soon as practicable thereafter, pursuant to Rule 461 of the Securities Act of 1933, as amended.
The Company acknowledges that: (i) should the Commission or the staff of the Commission, acting pursuant to delegated authority, declare the filing effective, such declaration does not foreclose the Commission from taking any action with respect to the filing; (ii) the action of the Commission or the staff of the Commission, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please contact Andrew P. Gilbert, Esq. or Scott A. Cowan, Esq. of DLA Piper LLP (US) at (973) 520-2553 or (973) 520-2554, respectively, with any questions or comments. Thank you for your assistance with this filing.
| IMMUNOMEDICS, INC. | |
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| By: | /s/ Michael R. Garone |
| Name: | Michael R. Garone |
| Title: | Vice President, Finance and |
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| Chief Financial Officer |
cc: Andrew P. Gilbert, Esq. (via e-mail)
Scott A. Cowan, Esq. (via e-mail)
