SecProbe.io

November 13, 2024
Tamara Jovonovich
Chief Executive Officer
Jabez Biosciences, Inc.
6393 Blackstone Dr.
Zionsville, IN 46077
Re:Jabez Biosciences, Inc.
Amendment No. 1 to Offering Statement on Form 1-A
Filed October 29, 2024
File No. 024-12509
Dear Tamara Jovonovich:
            We have reviewed your amended offering statement and have the following
comments.
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies 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 offering statement and the information you
provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our October 18, 2024 letter.
Amendment No. 1 to Offering Statement on Form 1-A
Dilution, page 16
1.Please tell us how you calculated the as adjusted net tangible book value per share
after the offering.
Our Business, page 21
2.We note your statement that "[p]re-clinical data supports further testing of the Jabez
molecule . . . ." Accordingly, we reissue prior comment 18. Please include a detailed
discussion of the pre-clinical studies referenced here and state whether such studies
were conducted by you or a third-party.
3.Please revise your disclosure to define the terms "OBD" and "PK" at first use.

November 13, 2024
Page 2
Regulatory Process, page 23
4.We note your response to prior comment 19 and your revised disclosure on page 23.
Please expand your disclosure to provide further details regarding the clinical trials
that are required for the FDA to approve a new drug application. We also note your
disclosure that you plan to "pursue FDA fast track, priority review, and orphan status
for JBZ-001 for qualifying disease states[.]" Accordingly, please revise your
disclosure further to provide a description of these regulatory pathways.
Intellectual Property, page 24
5.We note your response to prior comment 22 and your revised disclosure on page
24 separating your patents into "Pending National Stage Applns" and "Allowed/Issued
Applns" and providing the estimated remaining patent terms. Please revise to
disclose the expiration date for the issued patent application and clarify that the
remaining pending applications' patent terms are applicable only if the applications
are approved or, alternatively, please advise.
Technology Rights, page 24
6.Please revise your disclosure to provide further details regarding the items listed in
this section. With respect to the items in this section that do not appear in the
"Intellectual Property" section, please explain whether they refer to patents that have
been licensed to the Company pursuant to the License Agreement. If so, please
provide further details about these patents, such as the type of patent protection
obtained, the specific product(s) to which the patent relates, the expiration dates, and
the applicable jurisdictions.
Directors, Executive Officers, and Significant Employees
Directors and Executive Officers, page 29
7.Please revise your disclosure regarding the backgrounds of Brian Cogley, Robert
Lewis, Bruce A. Cassidy, and Martin Lewis to state, if true, that each of these
individuals holds a role with N ӦK Therapeutics, Inc.
8.We note that Brian Cogley is serving as the company's Chief Financial Officer in a
part-time capacity and is currently the full-time CFO of Coeptis Therapeutics
Holdings, Inc. Please include an appropriate risk factor discussing any risks associated
with only having a part-time CFO.
Security Ownership of Management and Certain Securityholders, page 32
9.Please revise your disclosure to include the addresses for MFV, LLC and JMCQ
Holdings, LLC.

November 13, 2024
Page 3
            Please contact Christine Torney at 202-551-3652 or Mary Mast at 202-551-3613 if
you have questions regarding comments on the financial statements and related
matters. Please contact Doris Stacey Gama at 202-551-3188 or Joshua Gorsky at 202-551-
7836 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Jim Byrd