SecProbe.io

December 9, 2014

Via E -mail
Michael Schuler
Chief Executive Officer
Bone Biologics, Corp.
175 May Street, Suite 400
Edison, NJ 08837

Re: Bone Biologics, Corp.
  Registration Statement on Form S-1
Filed  November 12, 2014
  File No.  333-200156

Dear Mr. Schuler :

We have limited our review of your registration statement to those issues we have
addressed in our 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 the
requested information .  Where 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 your
response.

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

General

1. Given the nature of the offering, the size of the offering relative to the number of shares
outstanding held by non -affiliates , and the identity and nature of the selling shareholders ,
it appears that these se curities may be being offered by or on behalf of the registrant. If
so, the offering is not eligible to be conducted on a continuous or delayed basis pursuant
to Rule 415(a)(1)(i) of Regulation C. Please provide us with your detailed analysis of
why this o ffering is not by or on behalf of the registrant, which analysis should address
all of the factors set forth in Securities Act Rules Compliance and Disclosure
Interpretation 612.09. Alternatively, please revise the registration statement to name the
sellin g stockholders as underwriters, disclose that such selling stockholders must resell
their shares at a fixed price throughout the offering, even after you become quoted or
listed, and make conforming changes to your prospectus accordingly, including your
cover page, summary and plan of distribution sections.

Michael Schuler
Bone Biologics, Corp.
December 9, 2014
Page 2

 2. Please update your combined financial statements to include unaudited interim financial
statements as required by Rule 8 -08 of Regulation S -X and update the related information
in your filing, such as your Results of Operations,  accordingly.

Management ’s Discussion and Analysis and Results of Operations, pag e 23

Liquidity and Capital Resources, page 26

3. Here and elsewhere throughout your registration statement, as applicable, please disclose
the convertible promissory note you issued in favor of  MTF on September 19, 2014,
including the interest rate, conversion terms, and any other material terms and conditions
of such convertible promissory note .

Selling Stockholders, page 44

4. With respect to the shares to be offered for resale by each selling security holder that is a
legal entity, including but not limited to Katayama Chemical Industry Co, LTD,
Shellwater & Company , HEWM/VLG Investment LLC, ForeFront Capital, Aragen
Bioscience , Alquest, Inc., and The Gilson Group, please disclose the natural person or
persons who exercise the sole or shared voting and/or dispositive powers with respect to
the shares to be offered by that shareholder.

Exhibit 5.1

5. All exhibits are subject to o ur review. Accordingly, please file the legal opinion in your
next amendment, or as soon as possible. Please note that we may hav e comments on the
legal opinion, once filed. Understand that we will need adequate time to review the legal
opinion before acce lerating effectiveness.

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 accel eration of the effective date
of the pending registration 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 n ot foreclose the Commission from taking any action with respect
to the filing;

Michael Schuler
Bone Biologics, Corp.
December 9, 2014
Page 3

  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

 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 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 all ow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please  contact Jennifer López, Staff Attorney,  at (202) 551 -3792 , Liz Walsh, Staff
Attorney, at (202) 551 -3696 or me at (202) 5 51-3720  with any other questions.

Sincerely,

 /s/ Elizabeth C. Walsh  for

Mara L. Ransom
Assistant Director

cc: William N. Haddad
     Reed Smith, LLP