SEC Comment Letter 0000000000-24-011946 to BONK, INC. (BNKK)
BONK, INC.
Date: Oct. 25, 2024 · CIK: 0001760903 · Accession: 0000000000-24-011946
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-282315
Letter
October 25, 2024 Jarrett Boon Chief Executive Officer Safety Shot, Inc. 1061 E. Indiantown Rd., Ste. 110 Jupiter, FL 33477 Re:Safety Shot, Inc. Amendment No. 2 to Registration Statement on Form S-3 Filed October 17, 2024 File No. 333-282315 Dear Jarrett Boon: We have reviewed your amended registration statement and have the following comment(s). Please respond to this letter by amending your registration statement 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 to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our October 15, 2024 letter. Amendment No. 2 to Registration Statement on Form S-3 Prospectus Summary, page 3 We note your response to comment 2. Please revise to address the following points:
•We note your disclosure that you "have conducted extensive informal research and experimentation involving a substantial number of volunteers under the influence of alcohol." Please clarify what you mean by "informal research and experimentation." We also note your disclosure that in connection with the clinical trials "cognitive responses were measured using the Visual Analogue Scale and physical function [was] assessed at the same intervals as the blood draws and breathalyzer assessments to correlate to function." Please revise to briefly explain how the •1.
October 25, 2024 Page 2 Visual Analogue Scale is used to measure cognitive responses and explain how physical function was assessed. Please also clarify whether the Visual Analogue Scale or a different assessment was used to observe in "the pre-clinical tests that the participants showed significant improvement in motor function and reduction in slurred speech and other markers commonly associated with alcohol consumption." Finally, please clarify how you defined significant improvement in connection with these informal tests. •Finally, we note your disclosure that the "clinical trials...consisted of 36 participants that were selected through advertising of the study" and that "participants had to qualify based upon a complete medical history questionnaire, release from physicians and submitting to a standard bloodwork panel." Of the 36 participants, please disclose the age range and, if known, participants’ reported levels of typical alcohol consumption, the range of the number of drinks consumed per participant during the trial and the range of BACs measured among the 36 participants. 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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October 25, 2024
Jarrett Boon
Chief Executive Officer
Safety Shot, Inc.
1061 E. Indiantown Rd., Ste. 110
Jupiter, FL 33477
Re:Safety Shot, Inc.
Amendment No. 2 to Registration Statement on Form S-3
Filed October 17, 2024
File No. 333-282315
Dear Jarrett Boon:
We have reviewed your amended registration statement and have the following
comment(s).
Please respond to this letter by amending your registration statement 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 to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our October 15, 2024 letter.
Amendment No. 2 to Registration Statement on Form S-3
Prospectus Summary, page 3
We note your response to comment 2. Please revise to address the following points:
•We note your disclosure that you "have conducted extensive informal research
and experimentation involving a substantial number of volunteers under the
influence of alcohol." Please clarify what you mean by "informal research and
experimentation."
We also note your disclosure that in connection with the clinical trials "cognitive
responses were measured using the Visual Analogue Scale and physical function
[was] assessed at the same intervals as the blood draws and breathalyzer
assessments to correlate to function." Please revise to briefly explain how the •1.
October 25, 2024
Page 2
Visual Analogue Scale is used to measure cognitive responses and explain how
physical function was assessed. Please also clarify whether the Visual Analogue
Scale or a different assessment was used to observe in "the pre-clinical tests that
the participants showed significant improvement in motor function and reduction
in slurred speech and other markers commonly associated with alcohol
consumption." Finally, please clarify how you defined significant improvement in
connection with these informal tests.
•Finally, we note your disclosure that the "clinical trials...consisted of 36
participants that were selected through advertising of the study" and
that "participants had to qualify based upon a complete medical history
questionnaire, release from physicians and submitting to a standard bloodwork
panel." Of the 36 participants, please disclose the age range and, if known,
participants’ reported levels of typical alcohol consumption, the range of the
number of drinks consumed per participant during the trial and the range of BACs
measured among the 36 participants.
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.