SEC Comment Letter 0000000000-22-012222 to Adamas One Corp. (JEWL) (CIK 0001884072)
Adamas One Corp. (JEWL) (CIK 0001884072)
Date: Nov. 9, 2022 · CIK: 0001884072 · Accession: 0000000000-22-012222
AI Filing Summary & Sentiment
File numbers found in text: 333-265344
Letter
United States securities and exchange commission logo November 9, 2022 John G. Grdina President and Chief Executive Officer Adamas One Corp. 17767 N. Perimeter Dr., Ste B115 Scottsdale, Arizona 85255 Re:Adamas One Corp. Amendment No. 3 to Registration Statement on Form S-1 Filed November 3, 2022 File No. 333-265344 Dear John G. Grdina: We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our October 31, 2022 letter. Amendment No. 3 to Registration Statement on Form S-1 filed November 3, 2022 Government Regulations, page 63 1.We note your disclosure in this section, such as "In August 2018, the FTC amended its Jewelry Guides to help prevent deception in jewelry marketing." Please ensure that you have updated the disclosure about government regulation to the extent practical. Also, tell us the extent to which you have considered FTC regulations given the references in the bullet points on pages 4 and 58 to "environmentally friendly" diamonds and the reference to "Eco Friendly" under the phrase "Benefits of Lab-Grown Diamonds" on your website.
FirstName LastNameJohn G. Grdina Comapany NameAdamas One Corp. November 9, 2022 Page 2 FirstName LastName John G. Grdina Adamas One Corp. November 9, 2022 Page 2 General 2.Please file a final legal opinion. Currently, Exhibit 5.1 is merely a "form" of opinion, is undated and has numerous blanks. You may contact Charles Eastman, Staff Accountant, at 202-551-3794 or Andrew Blume, Senior Accountant, at 202-551-3254 if you have questions regarding comments on the financial statements and related matters. Please contact Thomas Jones, Staff Attorney, at 202-551-3602 or Geoff Kruczek, Senior Attorney, at 202-551-3641 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Raymond A. Lee, Esq.
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United States securities and exchange commission logo
November 9, 2022
John G. Grdina
President and Chief Executive Officer
Adamas One Corp.
17767 N. Perimeter Dr., Ste B115
Scottsdale, Arizona 85255
Re:Adamas One Corp.
Amendment No. 3 to Registration Statement on Form S-1
Filed November 3, 2022
File No. 333-265344
Dear John G. Grdina:
We have reviewed your amended registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our October 31, 2022 letter.
Amendment No. 3 to Registration Statement on Form S-1 filed November 3, 2022
Government Regulations, page 63
1.We note your disclosure in this section, such as "In August 2018, the FTC amended its
Jewelry Guides to help prevent deception in jewelry marketing." Please ensure that you
have updated the disclosure about government regulation to the extent practical. Also, tell
us the extent to which you have considered FTC regulations given the references in the
bullet points on pages 4 and 58 to "environmentally friendly" diamonds and the reference
to "Eco Friendly" under the phrase "Benefits of Lab-Grown Diamonds" on your website.
FirstName LastNameJohn G. Grdina
Comapany NameAdamas One Corp.
November 9, 2022 Page 2
FirstName LastName
John G. Grdina
Adamas One Corp.
November 9, 2022
Page 2
General
2.Please file a final legal opinion. Currently, Exhibit 5.1 is merely a "form" of opinion, is
undated and has numerous blanks.
You may contact Charles Eastman, Staff Accountant, at 202-551-3794 or Andrew Blume,
Senior Accountant, at 202-551-3254 if you have questions regarding comments on the financial
statements and related matters. Please contact Thomas Jones, Staff Attorney, at 202-551-3602 or
Geoff Kruczek, Senior Attorney, at 202-551-3641 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Raymond A. Lee, Esq.