SecProbe.io

September 22, 2025
Robert Bradley Lim
Chief Executive Officer
iSpecimen Inc.
8 Cabot Road, Suite 1800
Woburn, MA 08101
Re:iSpecimen Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed September 8, 2025
File No. 333-289725
Dear Robert Bradley Lim:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our August 29, 2025 letter.
Amendment No. 2 to Registration Statement on Form S-1 filed September 8, 2025
Risk Factors
Risks Related to Our Corporate Treasury Initiative and Digital Assets, page 33
1.Please add risk factor disclosure addressing the possibility that a determination that
your Solana is being offered and sold as a security could lead to your classification as
an "investment company" under the Investment Company Act of 1940 and the
associated risks and potential consequences.
Our plan to establish a Solana-based corporate treasury program . . ., page 33
Please revise your risk factor disclosure to address potential impacts to the price of
Solana such as competition from other crypto assets and the level of adoption of
Solana relative to other crypto assets. Additionally, please provide quantitative 2.

September 22, 2025
Page 2
information that demonstrates the volatility of Solana.
Our purchase strategy may expose us to additional risks, including illiquidity associated with
"Locked SOL", page 33
3.Revise your statement here that you "may" acquire Locked Solana to instead state that
you intend to acquire Locked Solana, if true. Please also expand on your disclosure
regarding "Locked SOL" to explain the process by which these tokens would become
"unlocked" and freely tradable. Please explain whether the contractual transfer or
vesting restrictions are expected to vary between different lots of Locked Solana and
if you plan to adopt any policies or procedures regarding the applicable restrictions
on the Locked Solana you purchase.
Business
Corporate Treasury Initiative, page 50
4.Provide further disclosure explaining the material aspects of Solana. In that regard:
•Describe the use case for Solana including its intended purpose, use,
and function.
•Provide a discussion of Solana "tokenomics" discussing the past and current
supply of Solana, how new Solana is created, any burn mechanism, and any
inflationary or deflationary mechanism.
•Include a discussion of the Solana ecosystem and a description of the lifecycle of
the Solana token.
•Provide more detailed risk factor disclosure addressing the material risks related
to Solana and its ownership.
5.Please identify the third-party custodians you intend to use to store any Solana you
acquire. If you have not yet identified any custodians, disclose the material aspects of
the custody arrangements you intend to use, to the extent known, and discuss whether
you intend to have a custodial arrangement in place prior to the acquisition of any
Solana. In that regard, we note your press release filed as Exhibit 99.1 to your Form 8-
K filed August 7, 2025 that states that "BlockArrow employs such a layered security
model including offline cold storage, insured custody through Coinbase Custody, and
institutional-grade risk controls. Coinbase Custody's insurance coverage extends to
risks such as theft, damage, or operational failures."
6.Please expand your disclosure to disclose whether you intend to hedge your Solana
exposure. If so, please describe your hedging strategy.
We note that your press release filed as Exhibit 99.1 to your Form 8-K filed
September 4, 2025, states that you "plan for the Solana to be staked including liquid
staking tokenization to increase yields for shareholders in the long-term." Please
revise to address the following comments:
Expand your disclosure to provide a materially complete description of your plans
to stake Solana, engage in liquid staking, and any other methods by which you
intend to generate yield. Without limitation and to the extent applicable, your
disclosure should address the mechanics of the process, the participants involved,
and how awards are determined or other profits generated as well as any risks •7.

September 22, 2025
Page 3
associated with staking and other income-generating strategies and the impact of
those risks to investors. Also disclose your policies and procedures for your
staking plans, including, for example, how much of your Solana you intend to
stake and how any agreement with a staking provider will operate.
•Revise to disclose with specificity the bonding and unbonding periods associated
with staking Solana, discuss how they affect liquidity and disclose the material
terms of any policies and procedures you have in place to manage liquidity in this
regard.
•Provide risk factor disclosure addressing the liquidity risks of your staking plans
and your plans to purchase locked Solana.
•Add a risk factor to address the additional counterparty risks if you pursue
strategies to create income streams or otherwise generate funds using your Solana
holdings.
8.Discuss how you intend to generate profit through your long term Solana treasury
strategy, if you have any plans to generate profit other than through staking.
General
9.We note your Form 8-K filed September 4, 2025, and Exhibit 99.1 filed thereto
indicate that you will pursue a strategy of establishing a Solana-based treasury
program and engaging in other crypto asset related activities. Please revise to further
describe the extent to which you intend to focus on crypto asset related activities over
your primary business operations as a "global marketplace platform" of "patients,
biospecimens, and data for research." Include appropriate risk factor disclosure
concerning this separate strategy.
10.Discuss the material aspects of your plans to engage in crypto asset related activities
other than your planned Solana treasury. In that regard:
•Discuss your plans for purchasing crypto assets other than Solana. We note your
press release filed as Exhibit 99.1 to your Form 8-K filed August 7, 2025 refers to
"plans to initially select Solana," and your press release filed as Exhibit 99.1 to
your Form 8-K filed September 4, 2025 states that "iSpecimen has been
approached by several Crypto currency-related companies that have presented
opportunities in tokenized real-world assets as well as among highly ranked
cryptocurrencies."
•Discuss the material aspects of your plans to engage in spot trading, including
what percentage of your treasury you intend to allocate to spot trading. Your press
release filed as Exhibit 99.1 to your Form 8-K filed September 4, 2025 states that
"[you] also plan to partially diversify [y]our Solana holding and allow a small
percentage for spot trading."

September 22, 2025
Page 4
            Please contact Nicholas O'Leary at 202-551-4451 or Katherine Bagley at 202-551-
2545 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Ross D. Carmel, Esq.