SecProbe.io

November 14 , 2013

Via E -mail
Thomas A. Nicolette
Chief Executive Officer, President and Director
Akers Biosciences, Inc.
201 Grove Road
Thorofare, New Jersey 08086

Re: Akers Biosciences, Inc.
Amendment No. 2 to Registration Statement on Form S -1
Filed November 1 , 2013
  File No. 333 -190456

Dear Mr. Nicolette :

We have reviewed your amended registration statement  and your  response letter dated
November 1,  2013 to our comment letter dated October 23, 2013 and have the following
additional 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 registration statement and providing t he
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 a response.

After reviewing any subsequent amendment to your registration state ment and the
information you provide in response to these  comments, we may have  additional comments.

Consolidated Financial Statements
Six Months ended June 30, 2013 and 2012
Note 19 -Subsequent Events, page F -14

1. Please refer to prior comment 6. As a reminder, please disclose any equity issuances
made subsequent to the balance sheet date, such as common stock, preferred stock,
options, warrants, etc.  Provide us an analysis of how you determined the fair value of the
common stock and your intended acco unting treatment for any transactions.  Disclose the
reasons for any differences between the fair value used for the equity issuances and your
anticipated IPO price.

Thomas A. Nicolette
Akers Biosciences, Inc.
November 14 , 2013
Page 2

 Note 18 -Subsequent Events, page F -36

2. Please refer to prior comment 8. We acknowledge  your plan to implement a reverse stock
split prior to the planned offering. We may have further comments, regarding the
difference between the $0.02 price per share and your anticipated IPO price, once the IPO
price has been set.

We urge all persons who  are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending reg istration statement please provide  a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant t o delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effect iveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for accele ration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate  to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Thomas A. Nicolette
Akers Biosciences, Inc.
November 14 , 2013
Page 3

 You may conta ct Frank Wyman  at (202) 551 -3660 or Mary Mast at (202) 551 -3613  if
you have questions regarding comments on the financial statements and related matters.  Please
contact S cot Foley  at (202) 551 -3383, Bryan Pitko at (202) 551 -3203  or me at (202) 551 -3715
with any other questions.

Sincerely,

 /s/ Bryan J. Pitko for

 Jeffrey P. Riedler
Assistant Director

cc:  Joseph Lucosky, Esq.
 Lucosky Brookman LLP
 101 Wood Avenue South, 5th Floor
Woodbridge, NJ 08830