SecProbe.io

February 8, 2013

Via E -mail
Michael Garcia
President and Chief Executive Officer
Camp Nine, Inc.
1065 Kawaiahao St. Ste 2207
Honolulu, Hawaii 96814

Re: Camp Nine, Inc .
Amendment No. 1 to Registration Statement on Form S-1
Filed January 25, 2013
File No. 333-184881

Dear Mr. Garcia :

We have reviewed your responses to the comments in our letter dated December 10, 2012
and have the following additional comments.

Cover Page

1. Please remove the third paragraph, discussing your shell company status, from the cover
page, as this is not responsive to Item 501 of Regulation S -K.

The Company, page 5

2. We note your response to our prior comment 7 and reissue in part.  Please rev ise to also
include your revenue and net loss for the most recent audited period in that first
paragraph.

Because we do not have written contracts, page 8

3. Please indicate briefly in this risk factor what services your independent contractors do
for you.

Because we are currently considered a “shell company”, page 12

4. Please also indicate here that you are considered a “shell company” under the meaning of
Rule 405 under the Securities Act of 1933 as well.  Similarly revise the last paragraph
under “Rule 14 4 Shares,” at page 23.

Michael Garcia
Camp Nine, Inc.
February 8, 2013
Page 2

 5. Please also revise this risk factor to clarify that it is restricted securities that may not be
resold in reliance on Rule 144 until certain requirements are met, similar to the disclosure
you have provided in the last paragraph u nder “Rule 144 Shares,” at page 23.

Products and Pricing, page 20

6. In some of your statements regarding your products, please revise to state them as beliefs,
as the statements appear subjective.  Please revise the following statements:

 “The Ace I is  considered a high performance shortboard.  This surfboard is for the
more advanced surfer that excels at catching waves in all conditions.
Performance is the design emphasis for this model.  It is a good surfboard for
waves up to 8 -10 feet . . . .”

 “The  Bandito is considered a medium performance shortboard . . . it is a still a
good surfboard for waves up to 8 -10 feet.”

 “The Hot Pocket is considered a fun shortboard.  As such this surfboard was
designed with an emphasis on making it easy to catch waves and ride them
without worrying about maneuverability on the wave.  It is a good surfboard for
waves up to 6 feet . . . .”

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing i ncludes the information the Securities Act of 1933 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.

You may contact Effie Simpson at (202) 551 -3346  or Linda Cvrkel at (202) 551 -3313 if
you have questions regarding comments on the financial statements and related matters.  Please
contact John Stickel  at (202) 551 -3324 or me at (202) 551 -3210  with any other questions.

        Sincerely,

        /s/ Susan Block

        Susan Block
        Attorney -Advisor

cc: Puoy Premsrirut , Esq.