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CORRESP Filing

AlphaTON Capital Corp
Date: May 12, 2025 · CIK: 0001095435 · Accession: 0001171843-25-003090

Regulatory Compliance Offering / Registration Process Financial Reporting

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File numbers found in text: 333-28696

Referenced dates: May 8, 2025

Date
May 12, 2025
Author
Andrew D. Hudders
Form
CORRESP
Company
AlphaTON Capital Corp

Letter

United States Securities and Exchange Commission Division of Corporation Finance – Office of Washington, DC 20549 Attention: Mr. Tim Buchmiller Re: Portage Biotech Inc. Comment Letter dated May 8, 2025 Form F-3, Amendment No. 1 File No. 333-28696

Dear Mr. Buchmiller:

Reference is made to the letter of the staff (the "Staff") of the Securities and Exchange Commission (the "Commission"), dated May 8, 2025 ("Comment Letter"), commenting on the filing of Form F-3 ("Form F-3") of Portage Biotech Inc. (the "Company"). I am responding on behalf of the Company, as its United States counsel, to the Comment Letter. The response format sets forth the Staff comment followed by the Company response thereto.

The Company has amended the Form F-3 to remove the registration of debt securities and correspondingly removed all reference to debt securities in the registration statement, legal opinion and fee table.

The Company understands that its management persons are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff of the Securities and Exchange Commission.

If you have any questions about the foregoing, please do not hesitate to contact Andrew D. Hudders of this firm at 212-907-7349 or ahudders@golenbock.com.

Very truly yours,
/S/ Golenbock Eiseman Assor Bell & Peskoe LLP

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CORRESP
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 Attorneys at Law | 711 Third Ave., New York, NY 10017-4014
 T (212) 907-7300 | F (212) 754-0330 | www.golenbock.com

 Direct Dial No.: (212) 907-7349

 Direct Fax No.: (212) 754-0330

 Email Address: AHudders @GOLENBOCK.COM

 May 12, 2025

 United States Securities and Exchange Commission

 Division of Corporation Finance – Office of

 Life Sciences

 Washington, DC 20549

 Attention: Mr. Tim Buchmiller

 Re:

 Portage Biotech Inc.
 Comment Letter dated May 8, 2025
 Form F-3, Amendment No. 1
 File No. 333-28696

 Dear Mr. Buchmiller:

 Reference is made to the letter of
the staff (the "Staff") of the Securities and Exchange Commission (the "Commission"), dated May 8, 2025 ("Comment
Letter"), commenting on the filing of Form F-3 ("Form F-3") of Portage Biotech Inc. (the "Company"). I am
responding on behalf of the Company, as its United States counsel, to the Comment Letter. The response format sets forth the Staff comment
followed by the Company response thereto.

 The Company has amended the Form F-3 to remove the registration of debt
securities and correspondingly removed all reference to debt securities in the registration statement, legal opinion and fee table.

 The Company understands that its management persons are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff of the
Securities and Exchange Commission.

 If you have any questions about the foregoing, please do not hesitate
to contact Andrew D. Hudders of this firm at 212-907-7349 or ahudders@golenbock.com.

 Very truly yours,

 /S/ Golenbock Eiseman Assor Bell & Peskoe LLP

 Golenbock Eiseman Assor Bell & Peskoe LLP

 cc:
 Ms. Andrea Park,

 Chief Financial Officer