SEC Comment Letter 0000000000-23-007490 to IMPACT BIOMEDICAL INC. (IBO)
IMPACT BIOMEDICAL INC.
Date: July 13, 2023 · CIK: 0001834105 · Accession: 0000000000-23-007490
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File numbers found in text: 333-253037
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United States securities and exchange commission logo
July 13, 2023
Frank D. Heuszel
Chief Executive Officer
Impact BioMedical Inc.
275 Wiregrass Pkwy
West Henrietta, NY 14586
Re:Impact BioMedical Inc.
Amendment No. 12 to Registration Statement on Form S-1
Filed June 30, 2023
File No. 333-253037
Dear Frank D. Heuszel:
We have reviewed your amended registration statement and have the following
comments. In some of our comments, 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 comments apply 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 these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our June 27, 2023 letter.
Amendment No. 12 to Registration Statement on Form S-1
Capitalization, page 17
1.We note your revised disclosures in response to prior comment 1. However, you did not
address why Non-controlling interest in subsidiary is included in Total capitalization. As
previously requested, please explain to us why you have included your Non-controlling
interest in your Total capitalization or remove the line item.
FirstName LastNameFrank D. Heuszel
Comapany NameImpact BioMedical Inc.
July 13, 2023 Page 2
FirstName LastName
Frank D. Heuszel
Impact BioMedical Inc.
July 13, 2023
Page 2
You may contact Eric Atallah at 202-551-3663 or Mary Mast at 202-551-3613 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jordan Nimitz at 202-551-5831 or Tim Buchmiller at 202-551-3635 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Darrin M. Ocasio, Esq.