SecProbe.io

CORRESP
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filename1.htm

5582
Broadcast Court

Sarasota,
Florida 34320

December
19, 2024

Division
of Corporation Finance

Office
of Industrial Applications and Services

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

    Re:
    NAYA
    Biosciences, Inc.

    Registration
    Statement on Form S-3

    File
    No. 333-279593

To
whom it may concern:

NAYA
Biosciences, Inc. (the “Company”) hereby requests, pursuant to Rule 461 under the Securities Act of 1933, as amended, that
the above-referenced registration statement be accelerated to 5:00 p.m., Eastern Time, on Friday, December 20, 2024, or as soon thereafter
as practicable.

The
Company hereby acknowledges that:

    1.
    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;

    2.
    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 accuracy of the disclosure in the filing; and

    3.
    the
    Company may not assert staff comments or the declaration of effectiveness of this registration statement as a defense in any proceeding
    initiated by the Commission or any person under the federal securities laws of the United States.

    Very
    truly yours,

    NAYA
    BIOSCIENCES, INC.

    By:
    /s/
    Steven Shum

    Steven
    Shum

    Chief
    Executive Officer

  cc:
  Katherine Bagley, Esq.

  Robert
Augustin, Esq.