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United States securities and exchange commission logo
September 30, 2020
Norbert Bischofberger, Ph.D.
President and Chief Executive Officer
Kronos Bio, Inc.
1300 So. El Camino Real, Suite 300
San Mateo, CA 94402
Re: Kronos Bio, Inc.
Registration
Statement on Form S-1
Filed September 18,
2020
File No. 333-248925
Dear Dr. Bischofberger:
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 filed September 18, 2020
Overview, page 2
1. We note your disclosure
leading into the discovery table that you anticipate submitting an
IND for a drug
candidate arising from one of the programs identified in your table in
2022. Please balance
this disclosure by indicating, if true, that you may not successfully
identify novel product
candidates that can selectively modulate the specific oncogenic
TRNs specified in this
table.
Prior Development of ENTO, page 122
2. We note your additional
disclosure in response to our prior comment 6. Please revise to
clarify, if true, that
the investigator could not determine that the 14 serious AE's were
unrelated to treatment.
Norbert Bischofberger, Ph.D.
Kronos Bio, Inc.
September 30, 2020
Page 2
Therapeutic Rationale and Clinical Data in HOX/MEIS-High AML, page 125
3. We note your additional disclosure in response to our prior comment 7. We
also note your
disclosure that you intend to develop ENTO in combination with IC in
newly-diagnosed
AML patients with NPM1 mutations. Please revise to clarify if the
differences between
CR rates for patients receiving the IC and ENTO combination therapy with
just NPM1
mutations and the historical CR rates for patients with NPM1 mutations
receiving IC
therapy alone are statistically significant.
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 Sasha Parikh at 202-551-3627 or Julie Sherman at
202-551-3640 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Deanna Virginio at 202-551-4530 or Tim Buchmiller at 202-551-3635 with
any other
questions.
Sincerely,
FirstName LastNameNorbert Bischofberger, Ph.D.
Division of
Corporation Finance
Comapany NameKronos Bio, Inc.
Office of Life
Sciences
September 30, 2020 Page 2
cc: Charles J. Bair, Esq.
FirstName LastName