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SEC Comment Letter 0000000000-23-007707 to INTELLIGENT BIO SOLUTIONS INC. (INBS)

INTELLIGENT BIO SOLUTIONS INC.
Date: July 19, 2023 · CIK: 0001725430 · Accession: 0000000000-23-007707

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File numbers found in text: 333-273219

Date
July 19, 2023
Author
Not clearly detected
Form
UPLOAD
Company
INTELLIGENT BIO SOLUTIONS INC.

Letter

United States securities and exchange commission logo July 19, 2023 Harry Simeonidis Chief Executive Officer Intelligent Bio Solutions Inc. 142 West 57th Street, 11th Floor New York, New York 10019 Re:Intelligent Bio Solutions Inc. Registration Statement on Form S-1 Filed July 12, 2023 File No. 333-273219 Dear Harry Simeonidis: We have limited our review of your registration statement to those issues we have addressed in our comment. In our comment, 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 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 comment, we may have additional comments. Registration Statement on Form S-1 filed July 12, 2023 Incorporation of Certain Information by Reference, page 77 1.We note that you do not currently appear to be eligible to incorporate information by reference. Refer to General Instruction VII.C of Form S-1. We further note that you incorporate by reference the information required by Item 11(l) of Form S-1, which includes the information required by Item 402 of Regulation S-K. This Item requires information as of the last completed fiscal year. Please revise to either (i) specifically include all required information incorporated by reference or (ii) file your 2023 Annual Report on Form 10-K, including the information required by Item 402 of Regulation S-K, and revise your incorporation by reference section to specifically incorporate by reference the 10-K.

FirstName LastNameHarry Simeonidis Comapany NameIntelligent Bio Solutions Inc. July 19, 2023 Page 2 FirstName LastName Harry Simeonidis Intelligent Bio Solutions Inc. July 19, 2023 Page 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. You may contact Benjamin Richie at 202-551-7857 or Margaret Schwartz at 202-551- 7153 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc: Ralph V. De Martino

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United States securities and exchange commission logo
July 19, 2023
Harry Simeonidis
Chief Executive Officer
Intelligent Bio Solutions Inc.
142 West 57th Street, 11th Floor
New York, New York 10019
Re:Intelligent Bio Solutions Inc.
Registration Statement on Form S-1
Filed July 12, 2023
File No. 333-273219
Dear Harry Simeonidis:
            We have limited our review of your registration statement to those issues we have
addressed in our comment.  In our comment, 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 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 comment, we may have additional comments.
Registration Statement on Form S-1 filed July 12, 2023
Incorporation of Certain Information by Reference, page 77
1.We note that you do not currently appear to be eligible to incorporate information by
reference.  Refer to General Instruction VII.C of Form S-1.  We further note that you
incorporate by reference the information required by Item 11(l) of Form S-1, which
includes the information required by Item 402 of Regulation S-K.  This Item requires
information as of the last completed fiscal year.  Please revise to either (i) specifically
include all required information incorporated by reference or (ii) file your 2023 Annual
Report on Form 10-K, including the information required by Item 402 of Regulation S-K,
and revise your incorporation by reference section to specifically incorporate by reference
the 10-K.

 FirstName LastNameHarry Simeonidis
 Comapany NameIntelligent Bio Solutions Inc.
 July 19, 2023 Page 2
 FirstName LastName
Harry Simeonidis
Intelligent Bio Solutions Inc.
July 19, 2023
Page 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.
            You may contact Benjamin Richie at 202-551-7857 or Margaret Schwartz at 202-551-
7153 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Ralph V. De Martino