SecProbe.io

CORRESP
1
filename1.htm

    February
    16, 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†

    Kelly
    P Pfeiffer†

    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. 5 to Offering Statement on Form 1-A

    Filed
    February 2, 2024

    File
    No. 024-12349

Ladies
and Gentlemen:

On
behalf of Alternative Ballistics Corporation (the “Company”), we are responding to the comment (the “Comment”)
of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
contained in its letter dated February 9, 2024 (the “Comment Letter”), relating to the above-referenced Offering
Statement on Form 1-A (the “Offering Statement”).

Set
forth below is the Company’s response to the Comment. 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. 5 to Offering Statement on Form 1-A

Part
III. Exhibits

Exhibit
Index

12.1
Opinion of FitzGerald Kreditor Bolduc Risbrough, LLP, page 1

 1. We
                                            note that 2,510,000 shares being qualified are currently issued and outstanding. Please have
                                            counsel revise its opinion to state that these shares are legally issued, fully paid and
                                            non-assessable. For guidance, refer to Section II.B.2.h of Staff Legal Bulletin 19.

Response:
We have filed an exhibits only amendment containing the revised opinion of counsel that includes the opinion that the 2,510,000 shares
of common stock being sold by the Selling Stockholders are legally issued, fully paid, and non-assessable.

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