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SEC Company Response from AXIM BIOTECHNOLOGIES, INC. (AXIM) (CIK 0001514946) (AXIM) — Jun 21, 2021

AXIM BIOTECHNOLOGIES, INC. (AXIM) (CIK 0001514946)
Date: June 21, 2021 · CIK: 0001514946 · Accession: 0001078782-21-000578

AI Filing Summary & Sentiment

File numbers found in text: 333-256162

Date
June 21, 2021
Author
Not clearly detected
Form
CORRESP
Company
AXIM BIOTECHNOLOGIES, INC. (AXIM) (CIK 0001514946)

Letter

Sec Correspondence

AXIM Biotechnologies, Inc.

6191 Cornerstone Court, E. Suite 114

San Diego, CA 92121

June 21, 2021

VIA EDGAR

Division of Corporation Finance

Office of Life Sciences

U.S. Securities & Exchange Commission (the “Commission”)

100 F Street, N.E.

Washington, D.C. 20549

Attention:

David Gessert

Re:

AXIM Biotechnologies, Inc.

Registration Statement on Form S-1/A

Filed June 9, 2021

File No. 333-256162

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, AXIM Biotechnologies, Inc. (the “Company”) hereby requests that the effective date for the above-referenced Amendment No. 1 to the Registration Statement on Form S-1 (File No. 333-256162) be accelerated so that it will be declared effective at 5:00 PM Eastern Standard Time on June 22, 2021, or as soon thereafter as is practicable.

The undersigned, on behalf of the Company, acknowledges the following:

·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 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

Sincerely,
AXIM BIOTECHNOLOGIES, INC.

Show Raw Text
CORRESP
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filename1.htm

Sec Correspondence

AXIM Biotechnologies, Inc.

6191 Cornerstone Court, E. Suite 114

San Diego, CA 92121

June 21, 2021

VIA EDGAR

Division of Corporation Finance

Office of Life Sciences

U.S. Securities & Exchange Commission (the “Commission”)

100 F Street, N.E.

Washington, D.C. 20549

Attention:

 David Gessert

Re:

 AXIM Biotechnologies, Inc.

 Registration Statement on Form S-1/A

 Filed June 9, 2021

 File No. 333-256162

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, AXIM Biotechnologies, Inc. (the “Company”) hereby requests that the effective date for the above-referenced Amendment No. 1 to the Registration Statement on Form S-1 (File No. 333-256162) be accelerated so that it will be declared effective at 5:00 PM Eastern Standard Time on June 22, 2021, or as soon thereafter as is practicable.

The undersigned, on behalf of the Company, acknowledges the following:

·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 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

Sincerely,

AXIM BIOTECHNOLOGIES, INC.

/s/ John W. Huemoeller II

John W. Huemoeller II

President