United States securities and exchange commission logo
July 6, 2021
Mir Imran
President and Chief Executive Officer
Rani Therapeutics Holdings, Inc.
2051 Ringwood Avenue
San Jose, CA 95131
Re: Rani Therapeutics
Holdings, Inc.
Amendment No. 1 to
Draft Registration
Statement on Form S-1
Submitted June 22,
2021
CIK No. 0001856725
Dear Mr. Imran:
We have reviewed your amended draft registration statement and
have the following
comment. In our comment 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 comment applies 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 this
comment and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted
June 22, 2021
Business
Intellectual Property, page 168
1. We note the revised
disclosure provided in response to our prior comment 14 and we
reissue the comment in
part. In relation to the company's material patents, please further
revise your
intellectual property disclosure to clearly describe on an individual or patent
family basis the type
of patent protection granted for each product or technology
(composition of matter,
use, or process), the expiration year of each patent, and the
jurisdiction, including
any foreign jurisdiction, of each material pending or issued patent.
In this regard, it may
be useful to provide this disclosure in tabular form to support the
Mir Imran
Rani Therapeutics Holdings, Inc.
July 6, 2021
Page 2
narrative already included.
You may contact Kevin Kuhar at 202-551-3662 or Tracey McKoy at
202-551-3772 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Lauren Hamill at 303-844-1008 or Laura Crotty at 202-551-7614 with any
other
questions.
Sincerely,
FirstName LastNameMir Imran
Division of
Corporation Finance
Comapany NameRani Therapeutics Holdings, Inc.
Office of Life
Sciences
July 6, 2021 Page 2
cc: Josh Seidenfeld
FirstName LastName