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March 17, 2023
Robert Wiley
Chief Financial Officer
AMMO, INC.
7681 E. Gray Road
Scottsdale, AZ 85260
Re:AMMO, INC.
Form 10-Q for the period ended December 31, 2022
Filed February 14, 2023
Form 8-K
Filed February 14, 2023
File No. 001-13101
Response Dated March 3, 2023
Dear Robert Wiley:
            We have reviewed your March 3, 2023 response to our comment letter 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
February 1, 2023 letter.
Form 10-Q for the period ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 26
1.We note your responses to prior comments 1 and 2, including the revisions to the non-
GAAP financial measure you identify as Adjusted EBITDA.  We note the revised
measure appears to include an adjustment for the tax effect of other non-GAAP
adjustments.  Since Adjusted EBITDA is a pre-tax non-GAAP performance measure, it is
not clear why it is appropriate to include an adjustment for the tax effect of other non-
GAAP adjustments.  Please more fully explain the updated measure or revise it.  This

 FirstName LastNameRobert Wiley
 Comapany NameAMMO, INC.
 March 17, 2023 Page 2
 FirstName LastName
Robert Wiley
AMMO, INC.
March 17, 2023
Page 2
comment is also applicable to the presentation of Adjusted EBITDA in the earnings
release you filed under Form 8-K on February 14, 2023.
Form 8-K filed on February 14, 2023
Exhibit 99.1
Non-GAAP Financial Measures, page 8
2.We note your responses to prior comments 1 and 2, including the revisions to the non-
GAAP financial measures you identify as Adjusted EBITDA, Adjusted Net Income, and
Adjusted Earnings Per Share.  We note in addition to presenting updated non-GAAP
financial measures, you continue to present historical non-GAAP financial measures
based on how each measure was previously calculated.  It appears to us your current
presentation is not appropriate and confusing.  As our prior comments indicated, your
historical non-GAAP financial measures did not comply with Item 10(e) of Regulation S-
K and the related CD&Is.  We believe non-GAAP financial measures should be
consistently presented for each period presented and, if applicable, you should disclose
and discuss any changes in how measures are calculated relative to historical measures;
however, we do not believe continuing to present inappropriate historical measures is
appropriate.  Please more fully explain your current presentation or revise it to eliminate
historical non-GAAP financial measures.
3.We note your response to prior comment 1, including the revisions to the non-GAAP
financial measures you identify as Adjusted Net Income and Adjusted Earnings Per Share
and the revised disclosure that tax effects are computed at statutory rates; however, it is
not clear how the tax effects are actually determined.  For example, based on the
magnitude of the non-GAAP adjustments to Adjusted Net Income and Adjusted Earnings
Per share during the three months ended December 31, 2021 and the nine months ended
December 31, 2021, it is not clear why the tax effects are essentially the same in both
periods.  Please explain or revise.
            You may contact Kevin Stertzel at (202) 551-3723 or Anne McConnell at (202) 551-
3709 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing