View:
United States securities and exchange commission logo
March 22, 2021
Brian McKelligon
President and Chief Executive Officer
Akoya Biosciences, Inc.
100 Campus Drive, 6th Floor
Marlborough, MA 01752
Re: Akoya Biosciences,
Inc.
Amendment No. 1 to
Draft Registration Statement on Form S-1
Submitted March 12,
2021
CIK No. 0001711933
Dear Mr. McKelligon:
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. 1 to Draft Registration Statement on Form S-1 submitted
March 12, 2021
Use of Proceeds, page 59
1. We note your response
to prior comment 8. Please disclose the approximate amount of
net proceeds intended
to be used for each purpose listed. Refer to Item 504 of Regulation
S-K.
Brian McKelligon
FirstName LastNameBrian McKelligon
Akoya Biosciences, Inc.
Comapany
March NameAkoya Biosciences, Inc.
22, 2021
March2 22, 2021 Page 2
Page
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, Comparison of the years ended December 31, 2020 and 2019
Revenue, page 75
2. Please revise to disclose how changes in price per instrument
contributed to changes
instrument revenue during 2020 compared to 2019. In that regard, we
see that instrument
revenue per new system placement increased from approximately $181 to
$201.
3. We see that service revenue increased in total as well as a percentage
of total revenue.
Please revise to provide greater insight into the drivers of $1.5
million increase from
instrument service, including whether it related primarily to extended
service contracts,
installation or training.
Costs of Goods Sold, Gross Profit and Gross Margin, page 76
4. Regarding the decrease in cost of product revenue of $2.9 million, or
19%, for the year
ended December 31, 2020, compared to the year ended December 31, 2019,
please revise
to quantify the multiple factors that you attributed to the
fluctuation.
Consolidated Financial Statements for the year ended December 31, 2020
Note 11. Stock compensation plan, Stock Options, page F-27
5. Once you have an estimated offering price or range, please explain to
us the reasons for
any differences between the recent valuations of your common stock
leading up to the
IPO and the estimated offering price. This information will help
facilitate our review of
your accounting for equity issuances including stock compensation.
You may contact Kristin Lochhead at 202-551-3664 or Angela Connell at
202-551-3426
if you have questions regarding comments on the financial statements and
related
matters. Please contact Dillon Hagius at 202-551-7976 or Jeffrey Gabor at
202-551-2544 with
any other questions.
Sincerely,
Division of
Corporation Finance
Office of Life
Sciences
cc: Patrick J. O'Malley, Esq.