SecProbe.io

CORRESP
1
filename1.htm

    David
    L. Ficksman ● (310) 789-1290 ● dficksman@troygould.com
    File
    No. 03671-0001

    October
    12, 2017

VIA
FEDERAL EXPRESS AND EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Caleb French

    Re:
    Bone
        Biologics Corporation

        Post-Effective
        Amendment to Form S-1

        Filed
        September 8, 2017

        File
        No. 333-212892

        Post-Effective
        Amendment to Form S-1

        Filed
        September 8, 2017

        File
        No. 333-200156

Ladies
and Gentlemen:

By
letter dated October 4, 2017, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
provided Bone Biologics Corporation (the “Company”) with a comment on the Company’s Post-Effective Amendments
to Form S-1 described above.

This
letter contains the Company’s response to the Staff’s comment. The numbered response and the heading set forth below
correspond to the numbered comments and heading in the Staff’s letter dated October 11, 2017.

The
Company has revised the Registration Statements in response to the Staff’s comments and concurrently is filing post-effective
Amendments to the Registration Statements (the “Amended Registration Statements”). In addition to changes made
in response to the Staff’s comments, the Amended Registration Statements contain some updated information that appeared
in the Registration Statements, none of which is material in the Company’s view.

To
facilitate the Staff’s review of the Amended Registration Statements, we are providing supplementally with this letter a
blacklined copy of the Registration Statements marked to show changes from the applicable Registration Statement.

Securities
and Exchange Commission

October
12, 2017

Page
2

1.
We note your prospectus cover discloses that shares of your common stock are quoted on the OTC Pink and that the selling shareholders
may sell the shares in negotiated transactions, at market prices prevailing at the time of sale or at negotiated prices. Being
quoted on the OTC Pink does not satisfy the requirement that there be an established public trading market in order for selling
shareholders to offer their shares at other than a fixed price. Therefore, please revise your post-effective amendments to reflect
the fixed price at which the shares will be offered, or advise.

COMPANY’S
RESPONSE

The
Common Stock of the Company is currently trading on the OTCQB market. Accordingly, the Company believes that the disclosure in
the Registration Statements regarding the sales price of the shares is accurate. The Company has amended the Registration Statements
to indicate that the shares are trading on the QTCQB market rather than the QTC Pink.

The
Company is responsible for the adequacy and accuracy of the disclosure in the filing. The Company acknowledges that staff comments
or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to
the filing; and the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

*
* *

If
you have any questions regarding this response, please direct them to the undersigned at (310) 789-1290 or at dficksman@troygould.com.

    Very
    truly yours,

    /s/
    David L. Ficksman

    David
    L. Ficksman

DLF

    cc:
    Deina
    Walsh

    Stephen
    LeNeve

    Jeffrey
    Frelick