SecProbe.io

October 25, 2017
Niels Riedemann
Chief Executive Officer
Fireman B.V.
Winzerlaer Str. 2
07745 Jena, Germany
Re:Fireman B.V.
Registration Statement on Form F-1
Filed October 13, 2017
File No. 333-220962
Dear Mr. Riedemann:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form F-1
Exhibits
1.We note that your counsel's Exhibit. 5.1 opinion is with respect to Option Shares and
Offer Shares, which are ordinary shares of Fireman B.V.  However, your registration
statement relates to the offering of common shares of InflaRx N.V.  Please file a revised
opinion to cover the issuance of InflaRx N.V. common shares.  In the event that such
opinion refers to assumptions relating to the reorganization occurring after
effectiveness, please confirm that you will file an appropriately unqualified opinion by
post-effective amendment no later than the closing date of the offering. For guidance,
please see Section II.B.2.e. of Staff Legal Bulletin No. 19.

 FirstName LastNameNiels Riedemann
 Comapany NameFireman B.V.
 June 16, 2017 Page 2
 FirstName LastNameNiels Riedemann
Fireman B.V.
October 25, 2017
Page 2
2.It is inappropriate to include assumptions that are too broad or assume material facts
underlying the opinion.  The assumptions set forth in paragraphs (d), (e) (to the extent it
does not relate to pricing resolutions), and (j)(i) of your Exhibit 5.1 opinion appear to
assume material facts related to the issue of whether the shares will be validly issued.
Please file an amended 5.1 opinion that does not include these assumptions or explain
why each such assumption is necessary and appropriate.  For guidance, please see
Section II.B.3.a. of Staff Legal Bulletin No. 19.
3.Please remove the limitations set forth in the last paragraph on page 1 and the first
paragraph on page 2 of Exhibit 5.1, the first full paragraph on page 2 of Exhibit 8.1, and
paragraphs 6.2 and 7 of Exhibit 8.2.  In the alternative, please explain why they’re
appropriate and consistent with Section 14 of the Securities Act.  In addition, please
delete the first sentence in the third paragraphs of each of Exhibit 5.1 and 8.1 as they are
statements limiting reliance.  For guidance, please see Section II.B.3.d of Staff Legal
Bulletin No. 19.
4.Paragraphs 4 of your Exhibit 5.1 and Exhibit 8.1 opinions, and paragraph 3 of your
Exhibit 8.2 opinion, include inappropriate limitations on the documents reviewed and
review conducted.  Counsel may indicate that the identified items were the only
items reviewed if it also states that it determined that the identified documents included
all documents that it deemed relevant to rendering an opinion.  Please file amended
opinions that either remove the language indicating that such counsel's review was
limited to the identified items or include a statement that counsel determined that the
identified items were the only documents and searches relevant to rendering an opinion.
5.Please correct the registration statement number referenced in the definition of
"Registration Statement" in your Exhibit 8.2.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

 FirstName LastNameNiels Riedemann
 Comapany NameFireman B.V.
 June 16, 2017 Page 3
 FirstName LastName
Niels Riedemann
Fireman B.V.
October 25, 2017
Page 3
            You may contact Mark Brunhofer at 202-551-3638 or Lisa Vanjoske at 202-551-3614 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Dorrie Yale at 202-551-8776 or Erin Jaskot at 202-551-3442 with any other questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Sophia Hudson