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United States securities and exchange commission logo
May 16, 2022
Paul Berns
Chief Executive Officer
Neumora Therapeutics, Inc.
65 Grove Street
Watertown, Massachusetts 02472
Re: Neumora
Therapeutics, Inc.
Amendment No. 3 to
Draft Registration
Statement on Form S-1
Submitted May 2,
2022
CIK No. 0001885522
Dear Mr. Berns:
We have reviewed your amended draft 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 providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. 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 the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Amendment No. 3 to Draft Registration Statement on Form S-1 submitted
May 2, 2022
Our Precision Neuroscience Pipeline, page 5
1. We acknowledge the
revisions to your pipeline table here and elsewhere in the prospectus,
including the deletion
of the label for your discovery programs. Please explain the
significance of the
gray line separating the last three rows of the pipeline table from your
other neuropsychiatry
programs.
Paul Berns
FirstName LastNamePaul Berns
Neumora Therapeutics, Inc.
Comapany
May NameNeumora Therapeutics, Inc.
16, 2022
May 16,
Page 2 2022 Page 2
FirstName LastName
Results of preclinical studies or clinical trials of any product candidates...,
page 32
2. We refer to your disclosure that recent findings related to your
preclinical GRIN2B
program raised potential safety issues that led to the termination of
such program. Please
expand your disclosure of such findings that led to the termination of
such program.
Please also advise whether such safety issues impact any of your other
preclinical
programs, such as your GRIN2A positive allosteric modulator program.
Recent Acquisition of Assets
Alairion, Inc., page 98
3. We note your disclosure on pages 17, 24, 99 and elsewhere in the
prospectus that you
paused the active program acquired from Alairion indefinitely based on
pre-IND feedback
received from the FDA. Please expand your disclosure of the feedback
received from the
FDA and the active program acquired from Alairion, including whether
such program is
related to any of your product candidates.
NMRA-511, page 137
4. We note your disclosure on page 138 that you completed a Phase 1a
clinical trial in
February 2021 and quantitative EEG analysis suggested potential proof
of mechanism.
Please revise your characterization of the clinical trial to discuss
the data rather than
drawing conclusions from the results.
NMRA-M4R, page 138
5. We refer to your disclosure on page 139 relating to a Phase 2 clinical
trial of a M1/M4-
preferring muscarinic agonist and a positive Phase 1b clinical trial
of a M4 receptor
positive allosteric modulator. Please expand your disclosure to
clarify the scope and
design of such trials, including who conducted the trials.
NMRA-GRIN2A, page 140
6. We note your disclosure that you have identified lead molecules in a
series of GRIN2A
positive allosteric modulators that have demonstrated target
engagement in animal
models. Please expand your disclosure of the preclinical research you
have conducted to
date, including the scope, design and the data observed from such
animal models.
Paul Berns
FirstName LastNamePaul Berns
Neumora Therapeutics, Inc.
Comapany
May NameNeumora Therapeutics, Inc.
16, 2022
May 16,
Page 3 2022 Page 3
FirstName LastName
You may contact Eric Atallah at 202-551-3663 or Al Pavot at 202-551-3738
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Jane Park at 202-551-7439 or Laura Crotty at 202-551-7614 with any other
questions.
Sincerely,
Division of
Corporation Finance
Office of Life
Sciences
cc: Phillip Stoup, Esq.