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CORRESP
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    December
                                            14, 2023

    Michael
                                            J. FitzGerald*

    Eoin
    L. Kreditor*

    Lynne
    Bolduc

    Robert
    C. Risbrough

    George
    Vausher, LLM, CPA‡

    David
    M. Lawrence

    Charles
    C. McKenna

    Brook
    John Changala

    Natalie
    F. Foti

    Josephine
    Rachelle Aranda

    Pfrancez
    C. Quijano

    William
    Allen Miller

    Sam
    Sayed

    Litao
    Zhou

    Ikechukwu
    (Ike) Ubaka

    John
    M. Marston†

    Ralph
    G. Martinez†

    Deborah
    M. Rosenthal†

    Maria
    M. Rullo†

    VIA
    EDGAR
    Author’s
    Email: lbolduc@fkbrlegal.com

    U.S.
    Securities and Exchange Commission

    Division
    of Corporation Finance

    Office
    of Manufacturing

    100
    F Street, N.E.

    Washington,
    D.C. 20549

    Attn:
    Andi Carpenter, Martin James,

    Jenny
    O’Shanick, and Evan Ewing

    Re:

    Alternative
    Ballistics Corporation

    Amendment
    No. 1 to Offering Statement on Form 1-A

    Filed
    November 6, 2023

    File
    No. 024-12349

Ladies
and Gentlemen:

On
behalf of Alternative Ballistics Corporation (the “Company”), we are responding to the comments (the “Comments”)
of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
contained in its letter dated November 28, 2023 (the “Comment Letter”), relating to the above-referenced Offering
Statement on Form 1-A (the “Offering Statement”).

Set
forth below are the Company’s responses to the Comments. The heading and page number in this letter correspond to the heading and
page number contained in the Comment Letter and, to facilitate the Staff’s review, we have reproduced the text of the Staff’s
comment in bold below. Capitalized terms used but not defined herein have the meanings given to them in the Offering Statement.

Amendment
No 1 to Registration Statement on Form 1-A

Cover
page

 1. We
                                            note your disclosure that the offering will “terminate at the earlier of (i) the date
                                            at which the Maximum Offering set forth above has been sold, or (ii) the date at which this
                                            Offering is earlier terminated by us at our sole discretion.” We also note your disclosure
                                            on page 6 that the offering will “terminate at the earlier of (i) the date at which
                                            the Maximum Offering set forth above has been sold, (ii) one year from the qualification
                                            of this Offering, or (iii) the date at which this Offering is earlier terminated by us at
                                            our sole discretion.” Please revise.

Response:
We have reconciled all of the disclosures related to the termination of the Offering so that they all state that the Offering will
terminate at the earlier of (i) the date at which the Maximum Offering set forth above has been sold, (ii) one year from the qualification
of the Offering, or (iii) the date at which the Offering is earlier terminated by us at our sole discretion.

2
Park Plaza, Suite 850 ˖ Irvine, California 92614 1150 South Olive Street, Suite 10-128 ˖ Los Angeles, California 90015

Telephone: 949-788-8900 ˖ Facsimile: 949-788-8980 ˖ www.fkbrlegal.com

*Professional
Corporation ˖ †Of Counsel ˖ ‡Certified Specialist in Estate Planning, Trust & Probate Law, and in Taxation
Law, State Bar of California

  December
                                            14, 2023

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 2. We
                                            note your disclosures that your directors, executive officers and significant stockholders
                                            may be able to influence your company and that your Chief Executive Officer has 68.2% voting
                                            control “through his ownership of 2,000,000 shares of Series A Preferred Stock, which
                                            has 100 to 1 voting rights.” If true, please revise the cover page to prominently disclose
                                            that the company will be a controlled company post-offering, identify the controlling stockholder(s)
                                            and such stockholders’ total voting power, and include appropriate risk factor disclosure.

Response:
We have included disclosures related to the Company’s status as a controlled company post-offering and identified Steven Luna,
the Company’s CEO, as the controlling stockholder and his 64.54% voting power post-Offering, assuming that we raise the Maximum
Offering. We have also included a risk factor regarding the same.

 3. We
                                            note your disclosure on page 52 that the “Selling Stockholders may only make offers
                                            and sales of their shares of up to 30% of the gross proceeds from this Offering.” Please
                                            revise your cover page to include this disclosure.

Response:
We have included the disclosure that the “Selling Stockholders may only make offers and sales of their shares of up to 30% of the
gross proceeds from this Offering” on the cover page.

 4. We
                                            note your disclosure that you are an emerging growth company and that more information can
                                            be found in the section entitled “Offering Circular Summary—Implications of Being
                                            an Emerging Growth Company,” however, this section does not appear. Please advise or
                                            revise. Further, please revise to include a risk factor disclosing that you are an emerging
                                            growth company and discuss any related material risks.

Response:
We have included a disclosure in the Offering Circular Summary titled “Implications of Being an Emerging Growth Company and Smaller
Reporting Company.” We have also included a risk factor disclosing the Company’s status as an emerging growth company describing
the related risks.

December
                                            14, 2023

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3 of 8

Summary
Financial Data

 5. Please
                                            revise the table to remove the parenthetical disclosure indicating “audited”
                                            and “unaudited” above the columns since your auditors have not issued an audit
                                            report covering this table and therefore all amounts are unaudited. Instead, if true, you
                                            could revise the introductory paragraph to indicate that the amounts presented as of and
                                            for the six months ended June 30, 2023 and 2022 were derived from your unaudited interim
                                            financial statements, and the amounts presented as of and for the years ended December 31,
                                            2022 and 2021 were derived from your audited financial statements, presented elsewhere in
                                            the filing.

Response:
We have removed the parenthetical disclosures indicating “audited” and “unaudited” from the tables. We have also
revised the introductory paragraph indicating that “the amounts presented as of and for the six months ended June 30, 2023 and
2022 were derived from our unaudited interim financial statements, and the amounts presented as of and for the years ended December 31,
2022 and 2021 were derived from our audited financial statements, presented elsewhere in the filing.

Use
of Proceeds

 6. We
                                            note your anticipated use of proceeds if you raise the Maximum Offering amount. Please revise
                                            to describe any anticipated material changes in the use of proceeds if all of the securities
                                            being qualified on the offering statement are not sold.

Response:
We have added the following disclosure to the Use of Proceeds section:

“In
the event that we do not raise the Maximum Offering, we intend to use a majority of the proceeds from this Offering for Sales, Marketing
and Advertising, as well as Manufacturing – Production. There would be a significant decrease in percentage allocation towards
Salaries and Recruitment, while the percentage allocation for the other use of proceeds categories will remain the same.”

Capitalization

 7. We
                                            note that you only present a “pro forma as adjusted” column that gives effect
                                            to the maximum offering. Please revise the introductory paragraphs to clearly disclose that
                                            this is a best-efforts offering with no minimum offering required. Further, refer to the
                                            guidance in Rule 11-02(a)(10) of Regulation S-X and revise to provide additional columns
                                            that assume varying amounts of possible sales (e.g., 25%, 50%, 75%).

Response:
We have updated the introductory paragraph to disclose that this is a best-efforts offering with no minimum offering required. Further,
we have included additional columns assuming the varying amounts of possible sales of 25%, 50%, and 75% of the Maximum Offering.

December
                                            14, 2023

Page
4 of 8

 8. Please
                                            remove the parenthetical disclosure above the columns indicating that the “Pro Forma
                                            and Pro Forma As Adjusted are unaudited” and that the Actual amounts for June 30, 2023
                                            have been “reviewed,” since your auditors have not issued an audit or review
                                            report covering this table. We note that all amounts presented are unaudited. If true, you
                                            could revise the introductory paragraph to say that the amounts presented in the Actual column
                                            were derived from your unaudited interim financial statements for the six months ended June
                                            30, 2023 included elsewhere in the filing.

Response:
We have removed the parenthetical disclosures. We have also revised the introductory paragraph to state that “the amounts presented
in the Actual column were derived from our unaudited interim financial statements for the six months ended June 30, 2023 included elsewhere
in our Offering Statement.”

 9. Please
                                            revise the table to correctly calculate total capitalization for all columns presented as
                                            the sum of total liabilities and total shareholders’ equity (deficit). For example,
                                            total capitalization as of June 30, 2023, in the Actual column, appears to be $105,990.

Response:
The table has been updated to correctly reflect total capitalization.

Dilution

 10. As
                                            this is a best-efforts offering with no minimum offering required, please revise the dilution
                                            information to include a sensitivity analysis reflecting varying amounts of possible sales
                                            (e.g., 25%, 50%, 75%), to supplement the current Maximum Offering presentation.

Response:
The tables in the Dilution section have been revised to include columns to reflect the information if new investors purchase 25%, 50%,
75% or 100% of the Maximum Offering.

Management’s
Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources

 11. Please
                                            revise to describe all material cash requirements, including short-term and long- term requirements,
                                            and the anticipated source of funds needed to satisfy such cash requirements. Further, please
                                            revise this section to discuss all current material debt of the company.

Response:
Under Liquidity & Capital Resources, we have included the following disclosures:

“Our
short-term material cash requirements are $2,336,000 (20% of Maximum Offering), which we expect can provide us with one year of operating
capital. Our long-term material cash requirements are $11,680,000 (100% of the Maximum Offering), which we expect can provide us with
five years of operating capital. The anticipated source of funds to satisfy these cash requirements are through this Offering.

December
                                            14, 2023

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5 of 8

We
have a total of current material debt of $1,000,000 in the form of a convertible promissory note issued on March 29, 2022, which is accruing
interest at 15% per annum and is convertible into shares of our common stock at a conversion rate of $0.20. The conversion of the note
is at the election of the holder, subject to our approval, and the maturity date of the note is March 29, 2025.”

Business;
Our Historical Growth and Growth Strategy

 12. We
                                            note your disclosure on page 8 that you have not produced any revenue as well as your disclosure
                                            that you recently secured your “first purchase order from a department in Florida,
                                            and may have generated anticipated purchase orders from several departments in South America.”
                                            If material, please revise to clearly describe the material terms of the purchase order,
                                            including if any purchase orders are non-binding.

Response:
On page 9, we clarified that we have not yet begun to generate “material” revenues, and on page 38, we included
additional disclosures regarding our first purchase order in Florida which was fulfilled in June 2023 with a non-material invoice amount
of $2,300 and that we have generated purchasing interest from departments in South America that have resulted in non-binding purchase
orders.

Management—Directors
and Executive Officers

 13. Please
                                            revise to briefly discuss the specific experience, qualifications, attributes or skills that
                                            led to the conclusion that each of your directors should serve as your director.

Response:
We have revised the directors’ biographies to include a brief description of the experience, qualification, and attributes that
led to the conclusion that each of our directors are qualified to serve as a director.

Certain
Relationships and Related-Party Transactions

 14. We
                                            note the related party transactions disclosed on pages F-9 and F-10. Additionally, we note
                                            your disclosure that Vanessa Luna’s consulting firm provided consultation services
                                            to you. Please revise to include the disclosures required by Item 13 of Form 1-A, including
                                            the dollar amount of each transaction.

Response:
On page F-11, we added a section, titled “Related Party Transaction” to disclose the specific issuances made to Luna Consultant
Group. In addition, we included such disclosures in the section titled “Certain Rela