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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

Date
January 9, 2023
Author
Darrin
Form
CORRESP
Company
IMPACT BIOMEDICAL INC.

Letter

Re: Impact BioMedical, Inc.

January 31, 2023

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Life Sciences

F Street, N.E.

Washington D.C. 20549

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.

Show Raw Text
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.

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