The Company respectfully directs the Staff to the disclosure regarding the directed share program in the Prospectus Summary on page 9 of the Revised Registration Statement and under the heading “Underwriting—Directed Share Program” on page 204 of the Revised Registration Statement.

The Company advises the Staff that no directors, officers or other affiliates of the Company within the meaning of Rule 405 of the Securities Act of 1933, as amended, will be participating in the directed share program.  As a result, the Company has revised the disclosure on pages 9 and 204 of the Revised Registration Statement to remove references to director participation in the directed share program, and on page 72 of the Revised Registration Statement under the heading “Risk Factors— Our principal stockholders and management own a significant percentage of our stock and will be able to exert significant control over matters subject to stockholder approval” to remove the reference to purchases by affiliates under the Company’s directed share program.

In addition, in response to the Staff’s comment, the Company has revised the disclosure on page 186 of the Revised Registration Statement to include disclosure regarding the directed share program under the heading “Certain Relationships and Related Party Transactions—Directed Share Program” to disclose that certain related persons may participate in the directed share program, since certain of such persons, although not affiliates, are “related persons” within the meaning of Item 404 of Regulation S-K.

In response to the Staff’s original comment, the Company has revised the disclosure on page 82 of the Revised Registration Statement as requested.

In addition, the Company respectfully directs the Staff to the disclosure in the last paragraph on page 82 of the Revised Registration Statement which states that the net proceeds from the offering, together with the Company’s existing cash and cash equivalents, will not be sufficient to fund any of the Company's product candidates through regulatory approval, and the Company anticipates needing to raise additional capital to complete the development of and commercialize its product candidates. It is difficult to predict the cost and timing required to complete development and obtain regulatory approval of, and commercialize, product candidates due to, among other factors, the Company’s lack of experience as a company with initiating, conducting and completing preclinical studies and clinical trials, and uncertainty regarding the scope and design of clinical trials required to obtain regulatory approval for its product candidates, the rate of subject enrollment in its planned clinical trials, filing requirements with various regulatory agencies, clinical trial results, the actual costs of manufacturing, supplying and commercializing its product candidates and other factors outside of the Company’s control. The amounts and timing of the Company’s expenditures will depend upon numerous factors including the cost and results of its research and development efforts, the timing, cost and success of preclinical studies and any clinical trials it may commence in the future, the timing of regulatory submissions, its ability to obtain additional financing, the amount of cash obtained through its existing collaborations and future collaborations, if any, and any unforeseen cash needs.  Therefore, the Company is unable to determine the amount and source of other funds needed to achieve regulatory approval at this time.

In response to the Staff’s comment, the Company respectfully advises the Staff that Fidelity Management & Research Company (“Fidelity”) has never been, and is not currently, a “related person” within the meaning of Item 404 of Regulation S-K and, therefore, is not required to be disclosed in the section  titled “Certain Relationships and Related Party Transactions.”.

In response to the Staff’s comment, Exhibit 23.1 to the Revised Registration Statement has been revised as requested.

In response to the Staff’s comment, the Company has updated its website to comply with the Staff’s comments.

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Securities and Exchange Commission

November 30, 2020

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