Correspondence 0001493152-24-036248 from JUPITER NEUROSCIENCES, INC. (JUNS)
JUPITER NEUROSCIENCES, INC.
Date: Sept. 13, 2024 · CIK: 0001679628 · Accession: 0001493152-24-036248
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File numbers found in text: 333-260183
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filename1.htm
LAURA
ANTHONY, ESQ.
WWW.ALCLAW.COM
CRAIG
D. LINDER, ESQ.*
WWW.SECURITIESLAWBLOG.COM
JOHN
CACOMANOLIS, ESQ.**
Associates
and OF COUNSEL:
CHAD
FRIEND, ESQ., LLM
DIRECT
E-MAIL: LANTHONY@ALCLAW.COM
MICHAEL
R. GEROE, ESQ., CIPP/US***
JESSICA
HAGGARD, ESQ. ****
christopher
t. hines *****
PETER
P. LINDLEY, ESQ., CPA, MBA
JOHN
LOWY, ESQ.*****
STUART
REED, ESQ.
LAZARUS
ROTHSTEIN, ESQ.
SVETLANA
ROVENSKAYA, ESQ.******
HARRIS
TULCHIN, ESQ. *******
*licensed
in CA, FL and NY
**licensed
in FL and NY
***licensed
in CA, DC, MO and NY
****licensed
in MO
*****licensed
in CA and DC
******licensed
in NY and NJ
*******licensed
in NY and NJ
********licensed
in CA and HI (inactive in HI)
September
13, 2024
VIA
ELECTRONIC EDGAR FILING
Office
of Life Sciences
Division
of Corporation Finance
Securities
and Exchange Commission
100
F. Street, N.E.
Washington,
D.C. 20549
Re:
Jupiter
Neurosciences, Inc.
Amendment
No. 20 to Registration Statement on Form S-1
Filed
on September 4, 2024
File
No. 333-260183
Dear
Sir or Madam:
We
have electronically filed herewith on behalf of Jupiter Neurosciences, Inc. (the “Company”) Amendment No. 21 (“Amendment
No. 21”) to the above-referenced Registration Statement on Form S-1. Amendment No. 21 is marked to show changes made from Amendment
No. 20 filed on September 4, 2024. We have included a narrative response herein keyed to the comments of the staff of the Division of
Corporation Finance (the “Staff”) of the Securities and Exchange Commission set forth in the Staff’s comment
letter to Christer Rosén, Chief Executive Officer of the Company, dated September 12, 2024. We trust you shall deem the contents
of this letter responsive to your comment letter.
Amendment
No. 20 to Registration Statement on Form S-1
Description
of Business
Preclinical
results leading to encouraging of JOTROL possibly being a treatment for PD, page 110
1.
Comment:
We note your response to prior comment 2 and reissue. Your disclosure on page 110 continues to to indicate that the mice are induced
to have Parkinson’s Disease, as opposed to “almost mirror the parkinsonian symptoms in PD” and that your “MTPT[sic]
columns are mice induced to have Parkinson’s Disease.” Please revise as previously requested.
Response:
In response to the Staff’s comment, we have revised the conflicting disclosure in Amendment No. 21.
June
30, 2024 Financial Statements
Statements
of Operations, page F-28
2.
Comment:
Please revise the label Net gain (loss) per common share as appropriate, given you present Net income (loss) immediately above.
Also, please revise your references to this Net gain (loss) per share of common stock in your significant accounting policy on page
F-33.
Response:
In response to the Staff’s comment, we have revised the label Net gain (loss) per common share as appropriate and we have
revised our references to this Net gain (loss) per share of common stock in our significant accounting policy on page F-33.
If
the Staff has any further comments regarding Amendment No. 21 to the registration statement on Form S-1, or any subsequent amendments
to the Company’s registration statement on Form S-1, please feel free to contact the undersigned.
Anthony,
Linder & Cacomanolis, PLLC
By:
/s/
Laura Anthony
Laura
Anthony, Esq.
cc:
Jenn
Do/U.S. Securities and Exchange Commission
Angela
Connell/U.S. Securities and Exchange Commission
Daniel
Crawford/U.S. Securities and Exchange Commission
Suzanne
Hayes/U.S. Securities and Exchange Commission
Christer
Rosén/Jupiter Neurosciences, Inc.
Craig
D. Linder, Esq./Anthony, Linder & Cacomanolis, PLLC
1700
PALM BEACH LAKES BLVD., SUITE 820 ● WEST PALM BEACH, FLORIDA ● 33401 ● PHONE: 561-514-0936