Correspondence 0001493152-23-025390 from IMPACT BIOMEDICAL INC. (IBO)
IMPACT BIOMEDICAL INC.
Date: July 24, 2023 · CIK: 0001834105 · Accession: 0001493152-23-025390
AI Filing Summary & Sentiment
File numbers found in text: 333-253037
Letter
Division of Corporation Finance Office of Manufacturing Securities and Exchange Commission Amendment No. 12 to Registration Statement on Form S-1 Filed June 30, 2023 File No. 333-253037
Re: Impact BioMedical Inc.
Dear Mr. Atallah and Ms. Mast:
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”) provided to the undersigned on July 18, 2023 regarding the Company’s Registration Statement on Form S-1.
For convenience, the Staff’s comments have been restated below and the Company’s responses are set out immediately under the restated comments. Unless otherwise indicated, defined terms used herein have the meanings set forth in the S-1.
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.
Response: The Company has revised the disclosure to remove the line item in accordance with the Staff’s comment and conversations during the call on July 24, 2023.
Should you have any questions regarding the foregoing, please do not hesitate to contact the Company’s counsel, Darrin Ocasio, of Sichenzia Ross Ference LLP at (212) 930-9700.
Sincerely,
Frank
D. Heuszel
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CORRESP
1
filename1.htm
July
24, 2023
Division
of Corporation Finance
Office
of Manufacturing
Securities
and Exchange Commission
100
F Street, NE
Washington,
D.C. 20549
Attn:
Eric Atallah and Mary Mast
Re:
Impact
BioMedical Inc.
Amendment
No. 12 to Registration Statement on Form S-1
Filed
June 30, 2023
File
No. 333-253037
Dear
Mr. Atallah and Ms. Mast:
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”) provided to
the undersigned on July 18, 2023 regarding the Company’s Registration Statement on Form S-1.
For
convenience, the Staff’s comments have been restated below and the Company’s responses are set out immediately under the
restated comments. Unless otherwise indicated, defined terms used herein have the meanings set forth in the S-1.
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.
Response:
The Company has revised the disclosure to remove the line item in accordance with the Staff’s comment and conversations during the call on July 24, 2023.
Should
you have any questions regarding the foregoing, please do not hesitate to contact the Company’s counsel, Darrin Ocasio, of Sichenzia
Ross Ference LLP at (212) 930-9700.
Sincerely,
Frank
D. Heuszel
Chief
Executive Officer
cc:
Darrin
M. Ocasio, Esq.