SEC Comment Letter 0000000000-22-012326 to Adamas One Corp. (JEWL) (CIK 0001884072)
Adamas One Corp. (JEWL) (CIK 0001884072)
Date: Nov. 14, 2022 · CIK: 0001884072 · Accession: 0000000000-22-012326
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File numbers found in text: 333-265344
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United States securities and exchange commission logo
November 14, 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. 4 to Registration Statement on Form S-1
Filed November 10, 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 November 9, 2022 letter.
Amendment No. 4 to Registration Statement on Form S-1 filed November 10, 2022
Cover Page
1.We note your response to prior comment 2. Please reconcile the reference on the cover
page to "the selling stockholders identified in this prospectus are offering an additional
4,015,904 shares of [y]our common stock" with 3,815,904 shares being offered by selling
stockholders based on the sum of the shares being offered per the table on page 83.
General
2.On page 90, you disclose that White Bear received 40,000 shares, contrary to the numbers
in Exhibit 10.32 and page 83. Please reconcile.
FirstName LastNameJohn G. Grdina
Comapany NameAdamas One Corp.
November 14, 2022 Page 2
FirstName LastName
John G. Grdina
Adamas One Corp.
November 14, 2022
Page 2
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.