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United States securities and exchange commission logo
June 17, 2024
Martin Babler
President and Chief Executive Officer
Alumis Inc.
280 East Grand Avenue
South San Francisco, CA 94080
Re: Alumis Inc.
Registration
Statement on Form S-1
Filed June 7, 2024
File No. 333-280068
Dear Martin Babler:
We have reviewed your
registration statement and have the following comments.
Please respond to this letter by amending your registration
statement and providing the
requested information. If you do not believe a 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 letter, we may have additional comments.
Registration Statement on Form S-1, Filed June 7, 2024
Business
Manufacturing, page 132
1. Please disclose the
names of your principal suppliers. Refer to Regulation S-K Item
101(h)(4)(v).
Management
Composition of Our Board of Directors, page 153
2. We note your revised
disclosure that your board of directors currently includes three
vacancies, one of which
you expect to fill prior to the closing of this offering by mutual
agreement of your board
of directors pursuant to the terms of a voting agreement. Given
that your voting
agreement provides certain of your stockholders with the right to
designate directors for
election to your board of directors, please revise your disclosure to
clarify whether the
vacancy you expect to fill is the vacancy described in clause (vii) in
the last paragraph on
page 153.
Martin Babler
Alumis Inc.
June 17, 2024
Page 2
Certain Relationships and Related Person Transactions, page 176
3. We note that, in your discussion of your related person transactions
with the BBA
Funds, you removed certain disclosures regarding your former director's,
Julian C.
Baker's, relationship with the BBA Funds. Similarly, we note that you
removed
disclosures regarding your transactions with venBio Global Strategic
Fund IV, L.P., an
entity affiliated with your former director, Richard Gaster. To the
extent that these
transactions occurred while Julian C. Baker and Richard Gaster, as
applicable, served as
your directors and such persons had a direct or indirect material
interest in the respective
transactions, please revise this section to add back the disclosures of
these relationships or
otherwise advise.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
Please contact Franklin Wyman at 202-551-3660 or Kevin Vaughn at
202-551-3494 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jessica Dickerson at 202-551-8013 or Tim Buchmiller at 202-551-3635
with any other
questions.
Sincerely,
FirstName LastNameMartin Babler
Division of
Corporation Finance
Comapany NameAlumis Inc.
Office of Life
Sciences
June 17, 2024 Page 2
cc: Dave Peinsipp, Esq.
FirstName LastName