Correspondence 0001493152-23-003172 from IMPACT BIOMEDICAL INC. (IBO)
IMPACT BIOMEDICAL INC.
Date: Jan. 31, 2023 · CIK: 0001834105 · Accession: 0001493152-23-003172
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File numbers found in text: 333-253037
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CORRESP
1
filename1.htm
January
31, 2023
U.S.
Securities & Exchange Commission
Division
of Corporation Finance
Office
of Life Sciences
100
F Street, N.E.
Washington
D.C. 20549
Re:
Impact
BioMedical, Inc.
Amendment
No. 7 to Registration Statement on Form S-1
Filed
January 9, 2023
File
No. 333-253037
Ladies
and Gentlemen:
On
behalf of Impact BioMedical, Inc. (the “Company”), this letter responds to comments provided by the staff of the Division
of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to the undersigned
on January 20, 2023, regarding the amendment to the Company’s Registration Statement on Form S-1, which was filed with the Commission
on January 9, 2023 (“Amendment No. 7”).
The
substance of the Staff’s comments has been restated below in bold/italicized text. The Company’s responses to the Staff’s
comments are set out immediately under the restated comment. An amendment to the Registration Statement that reflects changes made in
response to the Staff’s comments, along with changes made to update certain other information in the Registration Statement, has
also been filed on this date (“Amendment No. 8”). Unless otherwise indicated, defined terms used herein have the meanings
set forth in Amendment No. 7.
Amendment
No. 7 to Form S-1 filed January 9, 2023 Capitalization, page 17
1.
Your
“Total capitalization” line item does not appear mathematically accurate. Please advise us or revise your filing accordingly.
Response:
The Company has revised the Registration Statement to clarify its total capitalization line item.
Sincerely,
Darrin
M. Ocasio, Esq.
1185
Avenue of the Americas | 31st Floor | New York, NY | 10036
T
(212) 930 9700 | F (212) 930 9725 | WWW.SRF.LAW