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United States securities and exchange commission logo
August 11, 2020
Nello Mainolfi, Ph.D.
President and Chief Executive Officer
Kymera Therapeutics, Inc.
300 Technology Square, 2nd Floor
Cambridge, MA 02139
Re: Kymera
Therapeutics, Inc.
Registration
Statement on Form S-1
Filed July 31, 2020
Amendment No. 1 to
Registration Statement on Form S-1
Filed August 5,
2020
File No. 333-240264
Dear Dr. Mainolfi:
We have reviewed your registration statement and have the
following comments. In
some of our comments, we may ask you to provide us with information so
we may better
understand your disclosure.
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.
Registration Statement on Form S-1
Prospectus Summary
Overview, page 1
1. Refer to comment 2. The
products in your discovery pipeline are not sufficiently
advanced or under your
control to emphasize in the pipeline table. Revise to eliminate the
discovery pipeline.
2. Refer to comment 3.
Revise the pipeline to include individual columns for Phases 2 and
3, or tell us on what
basis you believe you will be able to combine your Phase 2 and 3
studies for all of the
product candidates listed in this table.
Nello Mainolfi, Ph.D.
Kymera Therapeutics, Inc.
August 11, 2020
Page 2
3. Refer to comment 4. Revise the pipeline table to clearly distinguish
between the
application for which you will seek regulatory approval for KT-474. In
doing so, explain
or delete the reference to "others."
Risk Factors
Risks Related to Intellectual Property, page 46
4. We note your response to comment 8. As you take the position Kymera will
not be
required to change its name, revise to add a risk factor specifically
outlining the risks if
you are unable to trademark Kymera in the United States. Expand on your
disclosure that
you "may not be able to compete effectively and [y]our business may be
adversely
affected."
Business Overview, page 100
5. Refer to comment 13. You continue to describe your potential products as
potent on
pages 1, 81, 99, 103 and elsewhere. Revise these and all similar
statements in the
document.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
You may contact Vanessa Robertson at (202) 551-3649 or Daniel Gordon at
(202) 551-
3486 if you have questions regarding the financial statements and related
matters. Please contact
Abby Adams at (202) 551-6902 or Celeste Murphy at (202) 551-3257 with any other
questions.
Sincerely,
FirstName LastNameNello Mainolfi, Ph.D.
Division of
Corporation Finance
Comapany NameKymera Therapeutics, Inc.
Office of Life
Sciences
August 11, 2020 Page 2
cc: William D. Collins, Esq.
FirstName LastName