Correspondence 0001493152-24-042753 from BONK, INC. (BNKK)
BONK, INC.
Date: Oct. 28, 2024 · CIK: 0001760903 · Accession: 0001493152-24-042753
AI Filing Summary & Sentiment
Referenced dates: October 25, 2024
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CORRESP
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filename1.htm
October
29, 2024
Securities
and Exchange Commission
Division
of Corporate Finance
100
F Street, NE
Washington,
D.C. 20549
Attn:
Mr. Juan Grana and Ms. Margaret Sawicki
Re:
Safety Shot, Inc.
Amendment
No. 2 to Registration Statement on Form S-3
Submitted
October 17, 2024
File
No. 333- 282315
Dear
Mr. Juan Grana and Ms. Margaret Sawicki:
Please
find below our responses to the questions raised by the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) in its letter of comments dated October 25, 2024 (the “Comment Letter”) relating
to the amendment No. 2 to the registration statement on Form S-3, which was submitted to the Commission by Safety Shot, Inc. (the “Company”
or “we”) on October 17, 2024.
The
Company’s responses are numbered to correspond to the Staff’s comments. For your convenience, each of the Staff’s comments
contained in the Comment Letter has been restated.
We
have also updated the Registration Statement on Form S-3/A (the “Registration Statement”) which is submitted to the
Commission simultaneously together with this letter.
Amendment
No. 2 to Registration Statement on Form S-3
Prospectus
Summary, page 3
1. 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 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.
Response:
We have revised the Registration Statement in accordance with the Staff’s comment. Please see page 4 of the Registration Statement
for details. Specifically, the Company has amended the S-3 to (i) clarify what is meant by “informal research and experimentation”;
(ii) explain how the Visual Analogue Scale is used to measure cognitive responses and how physical function was assessed and how physical
function was observed and how significant improvement is defined; and (iii) disclosed the age range of participants, the amount of alcohol
consumed and the range of BACs measured amongst the participants
Should
you have any questions regarding the foregoing, please do not hesitate to contact the Company’s counsel, Arthur Marcus, Esq. of
Sichenzia Ross Ference Carmel LLP at (212) 930-9700.
Very truly
yours,
By:
/s/
Jarrett Boon
Name:
Jarrett Boon