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SEC Company Response from Functional Brands Inc. (MEHA) (CIK 0001837254) (MEHA) — Sep 19, 2025

Functional Brands Inc. (MEHA) (CIK 0001837254)
Date: Sept. 19, 2025 · CIK: 0001837254 · Accession: 0001213900-25-089357

AI Filing Summary & Sentiment

File numbers found in text: 333-284180

Referenced dates: August 28, 2025, September 17, 2025

Date
September 19, 2025
Author
/s/ Barry P. Biggar
Form
CORRESP
Company
Functional Brands Inc. (MEHA) (CIK 0001837254)

Letter

Via EDGAR Division of Corporation Finance Office of Life Sciences Re: Functional Brands Inc. Amendment No. 11 to Registration Statement on Form S-1 Filed September 19, 2025 File No. 333-284180

Dear Mr. Crawford, Ms. Crotty, Mr. Newberry and Ms. Robertson

On behalf of Functional Brands Inc. (the “Company”), we are filing today with the Securities and Exchange Commission (the “SEC”) Amendment No. 11 (the “Amendment”) to the Company’s Registration Statement on Form S-1 (the “Form S-1”) as noted above.

The Amendment includes revised Exhibits that address certain concerns raised by the staff of the Division of Corporation Finance of the SEC (the”Staff”) in comment 2 of the Staff’s letter dated August 28, 2025 and revises the Company’s disclosure regarding the “Qualified Event” referenced in the Staff’s letter of September 16, 2025. The Amendment also corrects the inconsistencies described in our letter to the Staff dated September 17, 2025.

Should you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please contact me at (646) 838-4433.

Sincerely,
/s/ Barry P. Biggar

Show Raw Text
CORRESP
1
filename1.htm

September 19, 2025

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Mr. Daniel Crawford/ Ms. Laura Crotty/Mr. Gary Newberry/ Ms. Vanessa Robinson

    Re:
    Functional Brands Inc.

    Amendment No. 11 to Registration Statement on Form S-1

    Filed September 19, 2025

    File No. 333-284180

Dear Mr. Crawford, Ms. Crotty, Mr. Newberry and
Ms. Robertson

On behalf of Functional Brands Inc. (the “Company”),
we are filing today with the Securities and Exchange Commission (the “SEC”) Amendment No. 11 (the “Amendment”)
to the Company’s Registration Statement on Form S-1 (the “Form S-1”) as noted above.

The Amendment includes revised Exhibits that address
certain concerns raised by the staff of the Division of Corporation Finance of the SEC (the”Staff”) in comment 2 of
the Staff’s letter dated August 28, 2025 and revises the Company’s disclosure regarding the “Qualified Event”
referenced in the Staff’s letter of September 16, 2025. The Amendment also corrects the inconsistencies described in our letter
to the Staff dated September 17, 2025.

Should you have any questions relating to the
foregoing or wish to discuss any aspect of the Company’s filing, please contact me at (646) 838-4433.

    Sincerely,

    /s/ Barry P. Biggar

    Barry P. Biggar, Esq.

    Sichenzia Ross Ference Carmel LLP

Cc:Eric Griptentrog

CEO-Functional Brands Inc.

1185 AVENUE OF THE AMERICAS | 31ST FLOOR | NEW
YORK, NY | 10036

T (212) 930-9700 | F (212) 930-9725 | WWW.SRFC.LAW