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December 19, 2022
Akinobu Yorihiro
Chief Technology Officer
Sacks Parente Golf, Inc.
551 Calle San Pablo
Camarillo, CA 93012
Re:Sacks Parente Golf, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed December 9, 2022
File No. 333-266610
Dear Akinobu Yorihiro:
            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.
Amendment No. 2 to Registration Statement on Form S-1
Cover Page
1.Please add the number of shares of common stock you will offer on the cover page of the
public offering prospectus and fill in the corresponding blank on the cover page of the
resale prospectus.
2.Disclose whether your offering is contingent upon on final approval of your NASDAQ
listing on your cover page.  Please ensure the disclosure is consistent with your
underwriting agreement.

 FirstName LastNameAkinobu Yorihiro
 Comapany NameSacks Parente Golf, Inc.
 December 19, 2022 Page 2
 FirstName LastName
Akinobu Yorihiro
Sacks Parente Golf, Inc.
December 19, 2022
Page 2
3.To the extent you intend to proceed with your offering if your NASDAQ listing is denied,
revise your cover page to indicate that the offering is not contingent on NASDAQ
approval of your listing application and that if the shares are not approved for listing, you
may experience difficulty selling your shares.  Include risk factor disclosures to address
the impact on liquidity and the value of shares.
Prospectus Summary
Forward Stock Split, page 8
4.You disclosed that on the effective date of this Prospectus, your Board of Directors and
stockholders have approved resolutions authorizing a forward stock split of the
outstanding shares of your common stock on the basis of 1.3333 shares for every one
share of common stock.  If the forward stock split will occur at or immediately before the
effectiveness of your registration statement, we remind you that in accordance with SAB
Topic 4C, you must revise your financial statements and all related disclosures throughout
your filing to retro-actively reflect the forward stock split.  If the forward stock split will
occur after the effectiveness of your registration statement, please provide appropriate pro
forma disclosures throughout your filing. Please advise or revise your disclosures
accordingly.
Risk Factors, page 11
5.We note recent instances of extreme stock price run-ups followed by rapid price declines
and stock price volatility seemingly unrelated to company performance following a
number of recent initial public offerings, particularly among companies with relatively
smaller public floats. Revise to include a separate risk factor addressing the potential for
rapid and substantial price volatility and any known factors particular to your offering that
may add to this risk and discuss the risks to investors when investing in stock where the
price is changing rapidly. Clearly state that such volatility, including any stock-run up,
may be unrelated to your actual or expected operating performance and financial
condition or prospects, making it difficult for prospective investors to assess the rapidly
changing value of your stock.
            You may contact Ernest Greene at 202-551-3733 or Kevin Woody at 202-551-3629 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Alexander King at 202-551-8631 or Erin Purnell at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing