SecProbe.io

November 26 , 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. 3 to Registration Statement on Form S -1
Filed November 1 8, 2013
  File No. 333 -190456

Dear Mr. Nicolette :

We have reviewed your amended registration statement  and your response letter da ted
November 18, 2013 to our comment letter dated November 14, 2013 and  we 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 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 amendment to your registration state ment and the information you
provide in response to these  comments, we may have  additional comments.

Consolidated Financial Statements
Nine Months ended September 30, 2013 and 2012
Note 20 --Subsequent Events, page F -16

1. As a reminder, please disclose any equity issuances made subsequent to the latest 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 i ntended
accounting treatment for any transactions.  Disclose the reasons for any differences
between the fair value used for th ese equity issuances and your anticipated IPO price.

2. As adjusted for the 1 for 156 reverse stock split , the purchase price of t he 80 million
shares issued in June 2013 appeared to equate to $3.12 per share. We may have further
comments, regarding the differe nce between this $3.12  price per share and your
anticipated IPO price.

Thomas A. Nicolette
Akers Biosciences, Inc.
November 26, 2013
Page 2

 Consolidated Financial Statements
Years Ended Decembe r 31, 2012 and 2011
General

3. Please retroactively adjust all share s and per share amounts for the 1 for 156 reverse
stock split that took effect on November 22, 2013.

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 i ts 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 d ate
of the pending regist ration 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 Commissio n from taking any action with respect
to the filing;

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

 the company may not assert staff comments and the declaration of effectiveness 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 acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of thei r 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 rev iew any amendment prior to the requested effective date of the
registration statement.

Thomas A. Nicolette
Akers Biosciences, Inc.
November 26, 2013
Page 3

 You may contact Frank Wyman  at (202) 551 -3660 or Mary Mast at (202) 551 -3613  if
you have questions regarding comments on the financial statements and relat ed 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