United States securities and exchange commission logo
June 5, 2020
Corey Fishman
President and Chief Executive Officer
Iterum Therapeutics plc
200 South Wacker Drive, Suite 2550
Chicago, IL 60606
Re: Iterum Therapeutics
plc
Amendment No. 2 to
Registration Statement on Form S-1
Response dated May
21, 2020
File No. 333-237326
Dear Mr. Fishman:
We have reviewed your May 21, 2020 response to our comment letter
and have the
following comment.
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.
Unless we note
otherwise, our references to prior comments are to comments in our May
14, 2020 letter.
Response Dated May 21, 2020
General
1. We note your response
to prior comment 1. To assist in our understanding and analysis of
your response, please
supplementally furnish the Indenture and any other applicable
governing documents
pertaining to the intra-group loan arrangement between the
Company and Iterum
Bermuda.
Corey Fishman
FirstName LastNameCorey Fishman
Iterum Therapeutics plc
Comapany NameIterum Therapeutics plc
June 5, 2020
Page 2
June 5, 2020 Page 2
FirstName LastName
You may contact Jeffrey Gabor at 202-551-2544 or Joe McCann at
202-551-6262 with
any questions.
Sincerely,
Division of Corporation
Finance
Office of Life Sciences
cc: Brian A. Johnson, Esq.