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    ATTORNEYS
    AT LAW

    January
    12, 2024

    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

    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. 2 to Offering Statement on Form 1-A

    Filed
    December 14, 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 January 3, 2024 (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 headings and page numbers in this letter correspond to the headings
and page numbers 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.

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

    January 12, 2024

Page 2 of 3

Amendment
No. 2 to Offering Statement on Form 1-A

Cover
page

  1.
  We note your response to prior comment 2. Given that you
intend to file an application for quotation of your common stock on the OTC Markets, please remove references to the NASDAQ listing rules
throughout the offering circular.

  Response:
We have removed all references to the NASDAQ listing rules throughout the offering circular.

Capitalization,
page 26

  2.
  We note the changes made in response to comment 7. Please
revise the titles of the columns added to the table to indicate that each also reflects pro forma as adjusted data, or revise to place
the “Pro Forma As Adjusted(3)” over all of the four columns reflecting the varying amounts of possible sales. Further, revise
the second bullet of the introductory paragraph to explain what the pro forma as adjusted columns are showing, instead of only addressing
the effect of the maximum offering.

  Response:
We have revised the titles of the columns to place the “Pro Forma As Adjusted(3)” heading over all of the four columns reflecting
the varying amounts of possible sales. Further, we revised the bullet points in the introductory paragraph to explain that the “Pro
forma” and “Pro forma as adjusted” columns include the assumption of the issuance of 9,411,280 shares of common stock
issued following debt conversions that occurred after June 30, 2023.

Certain
Relationships and Related-Party Transactions, page 52

  3.
  We note your response to prior comment 14 and reissue in
part. We also note the related party transactions disclosed on pages F-9 and F-10. Please revise to include the information required
by Item 13 of Form 1-A or tell us why you are not required to do so.

  Response:
We have revised Item 13 in the offering circular to include details related to the related party transactions that were disclosed on
pages F-9 and F-10 of the financial statements.

Plan
of Distribution, page 62

  4.
  We note your response to prior comment 16. Please revise
your offering circular to disclose that the offering will commence within two calendar days after qualification. Further, please revise
the offering circular to clarify the maximum time period during which investor funds could be held pending a closing without being accepted
or rejected.

  Response:
We have revised the offering circular to disclose that the offering will commence within two calendar days after qualification. Further,
we have revised the offering circular to clarify that the maximum time period which investor funds may be held pending a Closing without
being accepted or rejected is 30 calendar days from the date the Company receives both the investor’s Subscription Agreement and
subscription funds.

    January 12, 2024

Page 3 of 3

Lastly,
in response to a verbal comment from the Staff, we have updated the Executive Compensation table to reflect compensation as of December
31, 2023.

Please
direct any questions or comments concerning this response letter to the undersigned at (949) 788-8900 or by email at lbolduc@FKBRlegal.com.

    Very
    truly yours,

    /s/
    Lynne Bolduc

    Lynne
    Bolduc

    cc:
    Steven
    Luna, CEO, Alternative Ballistics Corporation