SecProbe.io

CORRESP
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filename1.htm

Katherine A. Beck

Tel 602.445.8349

Fax 602.445.8729

Email: beckk@gtlaw.com

November 14, 2022

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F. Street, NE

Washington, D.C. 20549

 Attention: Thomas Jones / Geoff Kruczek, Legal

Charles Eastman / Andrew Blume, Accounting

 Re: Adamas One Corp.

Amendment No. 4 to Registration Statement on Form S-1

Filed November 10, 2022

File No. 333-265344

Ladies and Gentlemen:

On behalf of Adamas One Corp., a Nevada corporation
(the “Company”), we express our appreciation for your prompt review of the above-referenced Amendment No. 4 to Registration
Statement on Form S-1 (the “Registration Statement”) filed with the U.S. Securities and Exchange Commission (the “Commission”)
on November 10, 2022. We are responding to the comment letter addressed to John G. Grdina, President and Chief Executive Officer
of the Company, dated November 14, 2022 (the “Comment Letter”), provided by the staff (the “Staff”) of the Commission.

The Company’s responses are indicated
below, directly following a restatement of each Staff comment in bold, italicized type. The numbers of the Company’s responses coincide
with the comment numbers set forth in the Comment Letter.

Amendment No. 4 to Registration Statement
on Form S-1 filed November 10, 2022

Cover Page

 1. Staff Comment: 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.

Company Response: The
Company acknowledges the Staff’s comment and respectfully advises the Staff that the number of shares being offered by White Bear
Group, LLC (“White Bear”) as set forth on the selling stockholder table on page 83 should be 600,000 shares instead of 400,000
shares, which then reconciles to the aggregate number of shares offered by the selling stockholders set forth on the cover page. The
Company will update the disclosure on page 83 accordingtly in its prospectus filed pursuant to Rule 424(b)(4) following the effectiveness
of the Company’s Registration Statement.

    Greenberg
    Traurig, LLP | Attorneys at Law

    2375
    East Camelback Road  |  Suite 800  |  Phoenix, Arizona 85016  |  T +1
    602.445.8000  |  F +1 602.445.8100

    ACTIVE 683320241v1
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    U.S. Securities and Exchange Commission

November 14, 2022

Page 2

General

 2. Staff Comment: 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.

Company Response: The Company
acknowledges the Staff’s comment and respectfully advises the Staff that the reference to 40,000 shares received by White Bear on
page 90 should be 400,000 shares, which will then reconcile with the numbers disclosed on pages 83 and 84 and in Exhibit 10.32. The Company
will update the disclosure on page 90 accordingly in its prospectus filed pursuant to Rule 424(b)(4) following the effectiveness of the
Company’s Registration Statement.

* * * * *

Your prompt attention to the enclosed is greatly
appreciated. If you have any questions regarding this filing or the Company’s responses, please do not hesitate to contact me at
(602) 445-8349 or Raymond A. Lee of our office at (949) 732-6510.

Very truly yours,

/s/ Katherine A. Beck

Katherine A. Beck

Shareholder

  cc:
  John G. Grdina, Adamas One Corp.

Raymond A. Lee, Greenberg Traurig, LLP

John A. Shumate, Greenberg Traurig, LLP

    Greenberg
    Traurig, LLP | Attorneys at Law

    ACTIVE
    683320241v1
    www.gtlaw.com