United States securities and exchange commission logo
July 26, 2021
Tillman U. Gerngross, Ph.D.
Chief Executive Officer
Adagio Therapeutics, Inc.
303 Wyman Street, Suite 300
Waltham, MA 02451
Re: Adagio
Therapeutics, Inc.
Registration
Statement on Form S-1
Filed July 16, 2021
File No. 333-257975
Dear Dr. Gerngross:
We have reviewed your amended registration statement 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 comment applies 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 this comment, we may have additional comments.
Unless we note
otherwise, our references to prior comments are to comments in our July
8, 2021 letter.
Registration Statement on Form S-1
Prospectus Summary, page 1
1. We note your revised
disclosure in response to our prior comment 2 that you are
conducting a combined
Phase 2/3 global clinical trial designed to provide a path to
authorization,
marketing approval and commercial launch in 2022. Please further revise
your disclosure to
provide time frames over which you have control, such as the timing of
your submissions to the
FDA. For those over which you have no control, revise to clarify
that you may not meet
your time frames for submission, and if you do, there is no
guarantee the FDA would
approve your submission, and no guarantee they would do so in
your anticipated time
frame.
Tillman U. Gerngross, Ph.D.
Adagio Therapeutics, Inc.
July 26, 2021
Page 2
You may contact Tara Harkins at 202-551-3639 or Al Pavot at 202-551-3738
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Abby Adams at 202-551-6902 or Irene Paik at 202-551-6553 with any other
questions.
Sincerely,
FirstName LastNameTillman U. Gerngross, Ph.D.
Division of
Corporation Finance
Comapany NameAdagio Therapeutics, Inc.
Office of Life
Sciences
July 26, 2021 Page 2
cc: Divakar Gupta, Esq.
FirstName LastName