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November 1, 2022
John Morgan
Chief Executive Officer
Lee Pharmaceuticals, Inc.
11 N Water Street
Mobile, AL 36602
Re:Lee Pharmaceuticals, Inc.
Amendment No. 1 to Offering Statement on Form 1-A
Filed October 18, 2022
File No. 024-11991
Dear John Morgan:
            We have reviewed your amended offering 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 amending your offering statement and providing the
requested information.  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 any amendment to your offering statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our October 5, 2022 letter.
Amendment No. 1 to Form 1-A filed October 18, 2022
Risk Factors
Risks Related to the Company and Its Business, page 10
1.Please add risk factor disclosure regarding governmental regulation of your storage of
health information. For example, disclose whether HIPAA or similar laws in other
jurisdictions in which you intend to operate will apply to your business, and the potential
effect on your results of operation and shareholders.

 FirstName LastNameJohn Morgan
 Comapany NameLee Pharmaceuticals, Inc.
 November 1, 2022 Page 2
 FirstName LastName
John Morgan
Lee Pharmaceuticals, Inc.
November 1, 2022
Page 2
Description of Business
Corporate History, page 22
2.We note your response to our prior comment 2.  Please further describe the strategic and
financial rationale for reviving the company by acquiring Accelerate Global Market
Solutions Corp., and discuss how you identified Accelerate Global in particular.
Plan of Operations, page 22
3.Please disclose the expected capital expenditures required to develop your application and
the expected timeline for development.
4.You disclose that you will accept payment for your application in the form of
cryptocurrency. Please discuss whether you have a policy for determining whether to hold
such crypto assets or immediately convert them into fiat currency or into other crypto
assets, and include the factors that you will consider in making such determinations.
Additionally, please describe your digital asset storage and custodial practices in detail.
Disclose your accounting policies with respect to digital assets. Please ensure that you
provide risk factor disclosure regarding these issues.
Description of Securities
Series A Preferred Stock, page 29
5.We note your response to our prior comment 9.  Please explain the mechanism by which
holders of the Series A Preferred Stock control 60% of the voting power.  For example,
clarify whether Mr. Morgan will retain 60% of the voting power to the extent he transfer
or converts some of the Series A Preferred Stock but not all of it.  Additionally, revise
your disclosure throughout the filing to reflect the controlled nature of the company.
            You may contact Lauren Pierce, Staff Attorney, at (202) 551-3887 or Joshua Shainess,
Legal Branch Chief, (202) 551- 7951 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Jeff Turner