SEC Comment Letter 0000000000-24-001524 to BONK, INC. (BNKK)
BONK, INC.
Date: Feb. 8, 2024 · CIK: 0001760903 · Accession: 0000000000-24-001524
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-258005
Letter
United States securities and exchange commission logo February 8, 2024 Brian S. John Chief Executive Officer Safety Shot, Inc. 1061 E. Indiantown Rd., Ste. 110 Jupiter, FL 33477 Re:Safety Shot, Inc. Post-Effective Amendment No. 6 on Form S-1 Filed February 5, 2024 File No. 333-258005 Dear Brian S. John: We have conducted a limited review of the post-effective amendment to your registration statement and have the following comments. Please respond to this letter by filing a post-effective amendment 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 and the information you provide in response to this letter, we may have additional comments. Post-Effective Amendment No. 6 to Form S-1 Our Business Legal Proceedings, page 47 1.We note your disclosure concerning the written complaint sent by Bigger Capital Fund, L.P. Please revise to disclose the allegations or claims. General 2.We note your response to prior comment 3, which we reissue in part. With respect to NoStingz, clarify if the claims related to repelling jellyfish venom and protecting from sea lice also fall within the definition of cosmetics. With respect to SS-100, revise to further clarify how SS-100 would be characterized as a drug in contrast to Safety Shot, which you characterize as a dietary/nutritional supplement. In addition, please disclose additional information to clarify the basis for your statement that SS-100 would qualify for Orphan Drug Designation to treat Acute Alcohol Poisoning. For example, clarify how Acute
FirstName LastNameBrian S. John Comapany NameSafety Shot, Inc. February 8, 2024 Page 2 FirstName LastName Brian S. John Safety Shot, Inc. February 8, 2024 Page 2 Alcohol Poisoning meets the FDA’s definition of a Rare Disease. Please also revise the Government Regulation section to clarify the process for seeking FDA approval of a drug and for obtaining Orphan Drug Designation. 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. Please contact Juan Grana at 202-551-6034 or Margaret Sawicki at 202-551-7153 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc: Arthur S. Marcus, Esq.
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United States securities and exchange commission logo
February 8, 2024
Brian S. John
Chief Executive Officer
Safety Shot, Inc.
1061 E. Indiantown Rd., Ste. 110
Jupiter, FL 33477
Re:Safety Shot, Inc.
Post-Effective Amendment No. 6 on Form S-1
Filed February 5, 2024
File No. 333-258005
Dear Brian S. John:
We have conducted a limited review of the post-effective amendment to your registration
statement and have the following comments.
Please respond to this letter by filing a post-effective amendment 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 and the information you provide in response to this
letter, we may have additional comments.
Post-Effective Amendment No. 6 to Form S-1
Our Business
Legal Proceedings, page 47
1.We note your disclosure concerning the written complaint sent by Bigger Capital Fund,
L.P. Please revise to disclose the allegations or claims.
General
2.We note your response to prior comment 3, which we reissue in part. With respect to
NoStingz, clarify if the claims related to repelling jellyfish venom and protecting from sea
lice also fall within the definition of cosmetics. With respect to SS-100, revise to further
clarify how SS-100 would be characterized as a drug in contrast to Safety Shot, which you
characterize as a dietary/nutritional supplement. In addition, please disclose additional
information to clarify the basis for your statement that SS-100 would qualify for Orphan
Drug Designation to treat Acute Alcohol Poisoning. For example, clarify how Acute
FirstName LastNameBrian S. John
Comapany NameSafety Shot, Inc.
February 8, 2024 Page 2
FirstName LastName
Brian S. John
Safety Shot, Inc.
February 8, 2024
Page 2
Alcohol Poisoning meets the FDA’s definition of a Rare Disease. Please also revise the
Government Regulation section to clarify the process for seeking FDA approval of a drug
and for obtaining Orphan Drug Designation.
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.
Please contact Juan Grana at 202-551-6034 or Margaret Sawicki at 202-551-7153 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc: Arthur S. Marcus, Esq.