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December 16, 2022
John Morgan
Chief Executive Officer
Lee Pharmaceuticals, Inc.
11 N Water Street
Mobile, AL 36602
Re:Lee Pharmaceuticals, Inc.
Amendment No. 2 to Offering Statement on Form 1-A
Filed December 1, 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 November 1, 2022 letter.
Amendment No. 1 to Form 1-A filed December 1, 2022
Risk Factors
Risks Related to the Company and Its Business, page 10
1.To the extent material, please provide risk factor disclosure regarding your transactions
involving cryptocurrency. Describe any material risks to your business from the
possibility of regulatory developments related to crypto assets. Please also describe any
material risks related to the safeguarding your or your customers’ crypto assets. Describe
any material risks to your business and financial condition if the third party provider that
you use for payments has ineffective policies and procedures surrounding the
safeguarding of crypto assets, conflicts of interest, or comingling of assets.

 FirstName LastNameJohn Morgan
 Comapany NameLee Pharmaceuticals, Inc.
 December 16, 2022 Page 2
 FirstName LastName
John Morgan
Lee Pharmaceuticals, Inc.
December 16, 2022
Page 2
We are not considered a "Covered Entity"..., page 10
2.Notwithstanding your assertion that there is no material risk that HIPAA or other similar
laws related to the storage of health information could apply to your business, please
revise your discussion here to clarify that this position reflects the belief of your
management.  Address the applicability of other rules and regulations relating to your
storage and tracking of unique health information of potential users, and discuss any
related risks to the company and to investors.  If there are no such material risks, consider
moving this disclosure to your Description of Business section. See Item 7(a)(1)(vi) of
Form 1-A.
Description of Business
Corporate History, page 22
3.We note your response to prior comment 2. Please add the information set forth in your
response letter describing the rationale for the acquisition of Accelerate Global Market
Solutions Corp. to the disclosure in the offering statement.
Description of Securities
Series A Preferred Stock, page 29
4.We note your response to prior comment 5.  Please revise your disclosure in the offering
statement to include the information set forth in your response letter explaining the
mechanism by which holders of the Series A Preferred Stock control 60% of the voting
power.
            You may contact Lauren Pierce, Staff Attorney, at (202) 551-3887 or Joshua Shainess,
Legal Branch Chief, at (202) 551-7951 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Jeff Turner