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Correspondence 0001493152-23-025722 from INTELLIGENT BIO SOLUTIONS INC. (INBS)

INTELLIGENT BIO SOLUTIONS INC.
Date: July 27, 2023 · CIK: 0001725430 · Accession: 0001493152-23-025722

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File numbers found in text: 333-273219

Date
July 12, 2023
Author
ARENTFOX SCHIFF LLP
Form
CORRESP
Company
INTELLIGENT BIO SOLUTIONS INC.

Letter

Re: Intelligent Bio Solutions Inc.

July 27, 2023

VIA EDGAR SUBMISSION

Securities and Exchange Commission

Division of Corporation Finance

F Street, N.E.

Washington, D.C. 20549

Attention: Benjamin Richie

Registration Statement on Form S-1

Filed July 12, 2023

File No. 333-273219

Ladies and Gentlemen:

This letter is being submitted on behalf of Intelligent Bio Solutions Inc. (the “Company” or “INBS”) in response to the comment letter, dated July 19, 2023, of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) with respect to the Company’s Registration Statement on Form S-1 filed on July 12, 2023 (the “Registration Statement”). The Company’s Amendment No. 1 Registration Statement (the “Amended Registration Statement”) has been filed with the Commission.

For your convenience, we have repeated the comment prior to the response in italics.

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.

Response:

The Company notes the Staff’s comment and has expanded its disclosure in the Amended Registration Statement to specifically include all required information previously incorporated by reference.

* * *

Securities and Exchange Commission

July 27, 2023

Should you have any questions regarding the foregoing, please do not hesitate to contact Johnathan Duncan at (212) 745-9539.

Sincerely,
ARENTFOX SCHIFF LLP

Show Raw Text
CORRESP
1
filename1.htm

July
27, 2023

VIA
EDGAR SUBMISSION

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Benjamin Richie

    Re:
    Intelligent
    Bio Solutions Inc.

    Registration
    Statement on Form S-1

    Filed
    July 12, 2023

    File
    No. 333-273219

Ladies
and Gentlemen:

This
letter is being submitted on behalf of Intelligent Bio Solutions Inc. (the “Company” or “INBS”)
in response to the comment letter, dated July 19, 2023, of the staff of the Division of Corporation Finance (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) with respect to the Company’s Registration Statement
on Form S-1 filed on July 12, 2023 (the “Registration Statement”). The Company’s Amendment No. 1 Registration
Statement (the “Amended Registration Statement”) has been filed with the Commission.

For
your convenience, we have repeated the comment prior to the response in italics.

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.

Response:

The
Company notes the Staff’s comment and has expanded its disclosure in the Amended Registration Statement to specifically include
all required information previously incorporated by reference.

*  *  *

  Securities and Exchange Commission

                                July 27, 2023

Should
you have any questions regarding the foregoing, please do not hesitate to contact Johnathan Duncan at (212) 745-9539.

    Sincerely,

    ARENTFOX SCHIFF LLP

    /s/ Johnathan C. Duncan

    By:
    Johnathan C. Duncan

cc: Harry Simeonidis, CEO and President