SecProbe.io

May 12, 2026
Dr. Glynn Wilson
Chief Executive Officer
Caring Brands, Inc.
130 S Indian River Drive
Suite 202 pbm# 1232
Fort Pierce, FL 34950
Re: Caring Brands, Inc.
Registration Statement on Form S-1
Filed May 6, 2026
File No. 333-295571
Dear Dr. Glynn Wilson:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that
the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Margaret Sawicki at 202-551-7153 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and Services
cc: Arthur Marcus, Esq.

CORRESP
1
filename1.htm

Caring
Brands, Inc.

130
S Indian River Drive,

Suite
202 pbm# 1232,

Fort
Pierce, FL 34950

(561)
896-7616

May
12, 2026

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Industrial Applications and Services

100
F Street N.E.

Washington,
D.C. 20549

    Re:
    Caring
    Brands, Inc.

    Registration
    Statement on Form S-1

    File
    No. 333-295571

Ladies
and Gentlemen:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date for
the Registration Statement referred to above be accelerated so that it will be declared effective at 4:30 p.m., Eastern Time on Thursday,
May 14, 2026, or as soon thereafter as practicable.

Please
contact Arthur Marcus, of Sichenzia Ross Ference Carmel LLP at (646) 810-0592, as soon as the Registration Statement has been declared
effective, or if you have any other questions or concerns regarding this matter.

    Very
    truly yours,

    CARING
    BRANDS, INC.

    By:

    /s/
    Dr. Glynn Wilson

    Dr.
    Glynn Wilson

    Chief
    Executive Officer

CORRESP
 1
 filename1.htm

 D.
Boral Capital LLC

 590
Madison Avenue, 39 th Floor

 New
York, NY 10022

 April
9, 2025

 Via
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 100
F Street, N.E.

 Washington,
D.C. 20549

 Re:
 Caring
 Brands, Inc.

 Registration
 Statement on Form S-1, as amended (File No. 333-285964)

 Request
 for Acceleration of Effective Date

 Requested
 Date:
 Wednesday,
 April 9, 2025

 Requested
 Time:
 5:15
 PM Eastern Time

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the "Securities Act"), D.
Boral Capital LLC, as representative of the underwriters of the offering, hereby joins the request of Caring Brands, Inc. that the effective
date of the above-referenced Registration Statement on Form S-1 be accelerated so that it may become effective at 5:15 p.m., Eastern
Time, on Wednesday, April 9, 2025, or as soon thereafter as practicable.

 Pursuant
to Rule 60 of the General Rules and Regulations under the Securities Act, please be advised that there will be distributed to each underwriter
or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary
prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

 The
undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating
dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended.

 D.
BORAL CAPITAL LLC

 Very
 truly yours,

 By:
 /s/
 Philip Wiederlight

 Name:
 Philip
Wiederlight

 Title:
 Chief
Operating Officer

CORRESP
 1
 filename1.htm

 CARING BRANDS, INC.

 1061 E. Indiantown Rd

 Suite 110, Jupiter, FL 33477

 Tel: (561) 896-7616

 April 9, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

 Re: Caring Brands, Inc.
 Registration Statement on Form S-1
 File No. 333-285964

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated
under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date for the Registration Statement
referred to above be accelerated so that it will be declared effective at 5:15 p.m., Eastern Time on April 9, 2025, or as soon thereafter
as practicable.

 Please contact Arthur Marcus,
Esq. of Sichenzia Ross Ference Carmel LLP at (516) 459-8161, as soon as the Registration Statement has been declared effective, or if
you have any other questions or concerns regarding this matter.

 Very truly yours,

 Caring Brands, Inc.

 By:
 /s/
 Dr. Glynn Wilson

 Dr. Glynn Wilson

 Chief Executive Officer

CORRESP
 1
 filename1.htm

 April
7, 2025

 Securities
and Exchange Commission

 Division
of Corporate Finance

 100
F Street, NE

 Washington,
D.C. 20549

 Attn:
Mr. Robert Augustin and Ms. Jane Park

 Re:
Caring Brands, Inc.

 Registration
Statement on Form S-1

 Filed
March 20, 2025

 File
No. 333-285964

 Dear
Mr. Augustin and Ms. Park:

 Please
find below our responses to the questions raised by the staff (the " Staff ") of the Securities and Exchange Commission
(the " Commission ") in its letter of comments dated April 2, 2025 (the " Comment Letter") relating
to the registration statement on Form S-1, which was filed with the Commission by Caring Brands, Inc. (the " Company "
or " we ") on March 20, 2025.

 The
Company's responses are numbered to correspond to the Staff's comments. For your convenience, each of the Staff's comments
contained in the Comment Letter has been restated in bold .

 We
have also updated the Registration Statement on Form S-1 (" Registration Statement ") which is submitted to the Commission
simultaneously together with this letter.

 Registration
Statement on Form S-1 filed March 20, 2025

 Index
to consolidated financial Statements page F-1

 1.
 As
 the financial statements are now as of a date after the merger and given the nature of the two companies and the transaction, it
 appears appropriate to include one set of consolidated financial statements for the combined entity. In presenting operations prior
 to the merger, we remind you that the determination of the accounting acquirer under ASC 805 is different from the determination
 of whether there is a predecessor entity pursuant to Rule 405 of Regulation C. Because of the insignificant operations of CBI NV
 and the change in focus to the ongoing business of CBI FL, it appears that CBI FL would be the predecessor entity prior to the September
 2024 transaction. As a result, we would expect the premerger historical financial statements of the consolidated entity to be the
 historical financial statements of CBI FL only. The premerger results of operations of CBI NV should no longer be presented. The
 pro forma financial statements would appear to no longer be required. Please revise the financial statements as necessary or provide
 a comprehensive analysis of how you determined that CBI FL would not be the predecessor entity pursuant to Rule 405 of Regulation
 C.

 Response :
The Company has revised its financial statements to reflect the appropriate Predecessor and Successor information consistent
with the comment of the staff. The Company referred to Section 1170 of the SEC Reporting Manual to make its modifications.

 In
addition, we have added language as to the Company's belief with respect to the statistical significance of the p-values
in the clinical studies discussion on page 42. Should you have any questions regarding the foregoing, please do not hesitate to
contact me or our counsel with any questions or comments regarding this correspondence on the revised and updated Registration Statement.

 Very
 truly yours,

 By:
 /s/
 Glynn Wilson

 Name:
 Glynn
 Wilson

 Chief
 Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 2, 2025

Glynn Wilson
Chief Executive Officer
Caring Brands, Inc.
1061 E. Indiantown Rd.
Suite 110
Jupiter, FL 33477

 Re: Caring Brands, Inc.
 Registration Statement on Form S-1
 Filed March 20, 2025
 File No. 333-285964
Dear Glynn Wilson:

 We have reviewed your registration statement and have the following
comment.

 Please respond to this letter by amending your registration 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 registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-1 filed March 20, 2025
Index to Consolidated Financial Statements, page F-1

1. As the financial statements are now as of a date after the merger and
given the nature
 of the two companies and the transaction, it appears appropriate to
include one set of
 consolidated financial statements for the combined entity. In presenting
operations
 prior to the merger, we remind you that the determination of the
accounting acquirer
 under ASC 805 is different from the determination of whether there is a
predecessor
 entity pursuant to Rule 405 of Regulation C. Because of the
insignificant operations of
 CBI NV and the change in focus to the ongoing business of CBI FL, it
appears that
 CBI FL would be the predecessor entity prior to the September 2024
transaction. As a
 result, we would expect the premerger historical financial statements of
the
 consolidated entity to be the historical financial statements of CBI FL
only. The
 premerger results of operations of CBI NV should no longer be presented.
The pro
 April 2, 2025
Page 2

 forma financial statements would appear to no longer be required. Please
revise the
 financial statements as necessary or provide a comprehensive analysis of
how you
 determined that CBI FL would not be the predecessor entity pursuant to
Rule 405 of
 Regulation C.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Nudrat Salik at 202-551-3692 or Terence O'Brien at
202-551-3355 if
you have questions regarding comments on the financial statements and related
matters. Please contact Robert Augustin at 202-551-8483 or Jane Park at
202-551-7439 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Arthur Marcus
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 March
20, 2025

 Securities
and Exchange Commission

 Division
of Corporate Finance

 100
F Street, NE

 Washington,
D.C. 20549

 Attn:
Mr. Robert Augustin and Ms. Jane Park

 Re:
Caring Brands, Inc.

 Amendment
No. 3 to Draft Registration Statement on Form S-1

 Submitted
February 11, 2025

 CIK
0002020737

 Dear
Mr. Augustin and Ms. Park:

 Please
find below our responses to the questions raised by the staff (the " Staff ") of the Securities and Exchange Commission
(the " Commission ") in its letter of comments dated February 26, 2025 (the " Comment Letter") relating
to the Amendment No. 3 to the draft registration statement on Form S-1, which was submitted to the Commission by Caring Brands, Inc.
(the " Company " or " we ") on February 11, 2025.

 The
Company's responses are numbered to correspond to the Staff's comments. For your convenience, each of the Staff's comments
contained in the Comment Letter has been restated in bold .

 We
have also updated the Registration Statement on Form S-1 (" Registration Statement ") which is submitted to the Commission
simultaneously together with this letter.

 Amendment
No. 3 to Draft Registration Statement on Form S-1 submitted February 11, 2025

 Prospectus
Summary, page 1

 1.
 We
 note your revised disclosure in response to prior comment 1 relating to the prevalence rates of psoriasis and vitiligo treatments
 in India. Please revise here and elsewhere in the registration statement to disclose the estimated market sizes for the phototherapy,
 psoriasis and vitiligo treatments in India accordingly.

 Response : As
discussed with the Staff, the Company was not able to obtain statistics on the overall market size for the phototherapy market and
the two conditions in India. For the information included in the Registration Statement, we have hyperlinked the articles and
formalized the citations to allow a user to identify and review the sources. As per our discussions with the Staff, we have
clarified which market we are discussing and confirmed that there can be no assurance that the Company's products will be able
to address the total market. We further confirm that no reports referred to in the Registration Statement were commissioned by
the Company for inclusion. As per our call, please advise if you would like us to supplementally provide you with any of the
articles.

 Clinical
Trials of Our Products, page 42

 2.
 We
 note your response to our prior comment 4 and reissue it in part. Please revise your characterization of your trials to discuss the
 data, such as explaining the pre and post-treatment averages in Trial 1, rather than drawing conclusions from the results.

 Response :
We acknowledge the comment and respectfully advise the Staff that we have revised the relevant disclosures to address the comment.

 Research
and Development and License Agreements, page 44

 3.
 We
 note your revised disclosure in response to prior comment 5, which we reissue in part. Please revise to clarify the current status
 of NOVODX's patent applications, including whether NOVODX has submitted its patent applications.

 Response:
 We acknowledge the comment and respectfully advise the Staff that we have revised relevant disclosures to include the following language:

 " As
of the date of this prospectus, NOVODX has not yet submitted any patent applications. NOVODX is in the process of preparing these applications
and evaluating entry into specific jurisdictions. "

 Should
you have any questions regarding the foregoing, please do not hesitate to contact me or our counsel with any questions or comments regarding
this correspondence on the revised and updated Registration Statement.

 Very
 truly yours,

 By:
 /s/
 Glynn Wilson

 Name:
 Glynn
 Wilson

 Chief
 Executive Officer

February 26, 2025
Glynn Wilson
Chief Executive Officer
Caring Brands, Inc.
1061 E. Indiantown Rd.
Suite 110
Jupiter, FL 33477
Re:Caring Brands, Inc.
Amendment No. 3 to
Draft Registration Statement on Form S-1
Submitted February 11, 2025
CIK No. 0002020737
Dear Glynn Wilson:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. 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 the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our February 4, 2025 letter.
Amendment No. 3 to Draft Registration Statement on Form S-1 submitted February 11, 2025
Prospectus Summary, page 1
1.We note your revised disclosure in response to prior comment 1 relating to the
prevalence rates of psoriasis and vitiligo treatments in India. Please revise here and
elsewhere in the registration statement to disclose the estimated market sizes for the
phototherapy, psoriasis and vitiligo treatments in India accordingly.

February 26, 2025
Page 2
Clinical Trials of Our Products, page 42
2.We note your response to our prior comment 4 and reissue it in part. Please revise
your characterization of your trials to discuss the data, such as explaining the pre and
post-treatment averages in Trial 1, rather than drawing conclusions from the results.
Research and Development and License Agreements, page 44
3.We note your revised disclosure in response to prior comment 5, which we reissue in
part. Please revise to clarify the current status of NOVODX’s patent applications,
including whether NOVODX has submitted its patent applications.
            Please contact Nudrat Salik at 202-551-3692 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related
matters. Please contact Robert Augustin at 202-551-8483 or Jane Park at 202-551-7439 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Arthur Marcus

February 4, 2025
Glynn Wilson
Chief Executive Officer
Caring Brands, Inc.
1061 E. Indiantown Rd.
Suite 110
Jupiter, FL 33477
Re:Caring Brands, Inc.
Amendment No. 2 to
Draft Registration Statement on Form S-1
Submitted January 17, 2025
CIK No. 0002020737
Dear Glynn Wilson:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. 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 the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our January 6, 2025 letter.
Amendment No. 2 to Draft Registration Statement on Form S-1 submitted January 17, 2025
Prospectus Summary, page 1
1.We note your revised disclosure in response to prior comment 2 that Photocil will
address “a very small fraction of the market in the US and India.” Please revise here
and elsewhere in the registration statement to disclose the Indian market size in the
phototherapy, vitiligo, and psoriasis markets.
We note your revised disclosure in response to prior comment 5 that the new
formulation of NoStingz includes a combination of rubidium iodide and menthol, 2.

February 4, 2025
Page 2
which has "demonstrated promising results in a small trial conducted in the Florida
Keys." Please expand your disclosure, where appropriate, to discuss in greater detail
the trial conducted in the Florida Keys, including but not limited to, who conducted
the trial, the design and scope of the trial, the statistical significance of the results,
whether any adverse events were observed, and the potential effects of rubidium
iodide and menthol.
3.We note your response to prior comment 11 that "[y]our licensee in India" disclosed
on page 40 relates to Cosmofix and San Pellegrino Cosmetics and the license
agreement entered into with Safety Shot in September 2022. Please revise to clarify
your references to your "licensee in India" throughout the registration
statement accordingly.
Clinical Trials of Our Products, page 42
4.We note your revised disclosure in response to prior comment 3. Please revise your
disclosure to address the following comments:

•We refer to your revised disclosure that all trials were independently conducted
and funded. Please revise to clearly specify who conducted each trial and provide
greater detail of the design and scope of Trials 1 and 3;
•Please revise your characterization of Trial 1 to discuss the data, such as the pre-
and post-treatment averages, rather than drawing conclusions from the results;
•Please clarify the meaning and significance of technical terms the first time they
are used in this section to ensure that all investors will understand the disclosure.
For example, please explain what you mean by OD and unpaired two-tailed
student’s t-test; and
•Please revise your disclosure to clarify whether Caring Brands’ employees were
involved in the publications referenced in this section.
Research and Development and License Agreements, page 44
5.We note your revised disclosure in response to prior comment 13 that NOVODX is
currently in the process of applying for patents and that such licenses will only be
valid in the jurisdictions where NOVODX obtains valid claims through the patent
applications. Please revise to disclose the jurisdictions in which NOVODX has
applied or intends to submit its patent applications.
Government Regulations, page 49
6.We note your revised disclosure in response to prior comment 16, which we reissue in
part. Please expand your disclosure relating to the regulatory requirements for your
products in India, including any approvals from the Central Drugs Standard Control
Organization (CDSCO).
Index to Consolidated Financial Statements, page F-1
We note your response to prior comment 21. The financial statements are presented as
of a date after September 24, 2024, when CBI NV acquired all of the equity of CBI
FL. CBI NV had no operations since inception and appears to have been created to 7.

February 4, 2025
Page 3
effect a recapitalization. As such, it appears CBI FL is the accounting acquirer and the
transaction should be accounted for as a reverse acquisition or recapitalization of CBI
FL. In this case, the assets and liabilities of the two companies should be combined at
their historical bases, the accumulated deficit of CBI FL should be carried forward
and the accumulated deficit of CBI NV should be eliminated against paid-in capital.
The results of operations of CBI FL would become those of the combined entity and
the premerger results of operations of CBI NV should no longer be presented. The pro
forma financial statements would appear to no longer be required in this scenario.
Please revise the financial statements as necessary or provide us with an explanation
as to the basis for continuing to provide separate financial statements of the entities
after the date of merger.
Note 1 - Organization and Business Operations, page F-16
8.We note your response to comment 22. We continue to believe that you should
expand your disclosures to discuss the basis of presentation of the carve-out financial
statements, specifically how you determined which operations should be included in
the carve-out financial statements. For example, your disclosures indicate that Caring
Brands Florida may have represented a separate legal entity, which may mean that the
carve-out financial statements reflect the full financial statements of this legal entity.
Income Taxes, page F-18
9.We reissue comment 24. Please clearly disclose in the notes to the financial
statements whether you are using the separate return approach. If the historical
statements of operations do not reflect the tax provision on a separate return basis,
please present pro forma financial information reflecting a tax provision calculated on
the separate return basis. Refer to Question 3 of SAB Topic 1.B.
Note 6 - Investment in NovoDX - a Related Party, page F-29
10.We note your response to comment 26. It appears that you have chosen to use the fair
value option to account for your investment in NovoDX Corporation in accordance
with ASC 321. Please clearly disclose that you have chosen the fair value option, if
true. Please also expand your disclosures pursuant to ASC 825-10-50, which include
disclosing the method and significant assumptions used to estimate fair value as well
as management's reasons for electing the fair value option.
Condensed Consolidated Statement of Changes in Shareholders Equity, page F-32
11.We note your response to comment 27. Please better explain to us how you
determined the fair value of the common stock underlying your recent equity
issuances, including the 400,000 shares issued for services. Please also address the
reasons for any differences between the recent valuations of your common stock used
to determine these fair value amounts and the estimated offering price of $4 per share.
We note that you indicate that the 400,000 shares were valued based on the most
recent common stock sale price. Please specify which transaction you are referring to
and when this sale took place.

February 4, 2025
Page 4
            Please contact Nudrat Salik at 202-551-3692 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related
matters. Please contact Robert Augustin at 202-551-8483 or Jane Park at 202-551-7439 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Arthur Marcus

January 6, 2025
Glynn Wilson
Chief Executive Officer
Caring Brands, Inc.
1061 E. Indiantown Rd.
Suite 110
Jupiter, FL 33477
Re:Caring Brands, Inc.
Amendment No. 1 to
Draft Registration Statement on Form S-1
Submitted December 20, 2024
CIK No. 0002020737
Dear Glynn Wilson:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. 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 the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our November 15, 2024 letter.
Amendment No. 1 to Draft Registration Statement on Form S-1 submitted December 20,
2024
Prospectus Summary
Company Overview, page 1
We note your revised disclosure in response to comment 2, which we reissue in
part. We refer to your disclosure on page 1 that Photocil was briefly launched in the
United States prior to its Q3 2022 commercial launch in India as a treatment for
vitiligo and psoriasis. However, you also disclose that Photocil entered the U.S. 1.

January 6, 2025
Page 2
market in Q4 2022 on Amazon and was subsequently removed from the U.S. market
on Q2 2023. Please revise to clearly state when Photocil was launched in the United
States, why Photocil was removed from the U.S. market in Q2 2023, and whether the
product's formulation has been changed since its removal in 2023.
2.We note your revised disclosure relating to the global phototherapy, vitiligo, and
psoriasis treatment markets in response to prior comment 4, which we reissue in part.
Please revise your disclosure to address the following comments:

•We refer to your disclosure that Photocil has initially been launched in the United
States and Indian markets to date. Please clarify the proportion that the U.S. and
Indian markets comprise of the phototherapy, vilitigo, and psoriasis global
markets. Please also disclose the range of products and services that are covered
by these global market figures and clarify, if true, that you only provide products
representing a small fraction of such market figures. Please make conforming
changes to your Market Opportunity section; and

•We refer to a certain report disclosed as the source for your estimated global
vitiligo market size. Specifically, we note that the forecast period used to calculate
the vitiligo treatment market size is from 2018 to 2032. To provide investors with
additional context about recent growth in the industry, please revise to provide the
market size and growth rate over a more recent time period.
3.Please revise to provide clear descriptions of the primary endpoints for your clinical
trials and revise your characterizations of the trials to discuss the data, rather than
drawing conclusions from the results. Please also revise to provide a brief explanation
regarding how p-values are used to measure statistical significance, the p-value that
you have to achieve to conclude a statistically significant result, and clearly state
whether the data for Trial 3 was found to be statistically significant. Please also
consider including your revised discussion of these clinical trials under an appropriate
heading in the Business section.
4.We note that JW-700 has been clinically shown to increase the enzymes needed for
minoxidil, which appears to be a third-party FDA-approved over-the-counter
medication used to treat hair loss. Please revise your disclosure throughout the
registration statement to clarify, if true, that JW-700 does not independently treat hair
loss and promote hair regrowth as a standalone product and must be used in
conjunction with a third-party product.
5.We note your revised disclosure in response to prior comment 8 that NoStingz was
previously commercialized and is currently being re-formulated under Caring Brands
as a sunscreen product designed to provide protection against both UV rays and
jellyfish stings. Please expand your disclosure to discuss when and the jurisdictions in
which NoStingz was previously commercialized. Please also disclose when the
product was removed from the market, the reasons for its removal, and the key
differences between the prior commercialized version and the reformulation of the
product.

January 6, 2025
Page 3
Unaudited Pro Forma Condensed Combined Financial Statements, page 31
6.We note your response to comment 21. It is not clear where additional disclosures
have been provided as your response indicates. We note your disclosures on page 34
regarding certain services that will be provided under the separation agreement and
also disclosure regarding costs you expect to incur to replace certain services
previously provided by Jupiter Wellness. Please tell us what consideration was given
to reflecting the additional costs including those associated with the separation
agreement in your pro forma financial information. Please also disclose the terms of
the separation agreement, including the consideration that you will pay for these
services. Please refer to Rule 11-02(a)(6)(ii) of Regulation S-X.
7.We note your response to comment 22. It is not clear where additional disclosures
have been provided as your response indicates. We note your disclosures regarding
the Taisho License, including that it will be transferred to the company from Safety
Shot pursuant to the Separation and Exchange Agreement. Please tell us what
consideration you gave to reflecting this transaction in the pro forma financial
information.
Management's Discussion and Analysis, page 34
8.We note your response to comment 23. It is not clear where additional disclosures
have been provided as your response indicates. As previously requested, please
provide a more clear description of the status of your current operations and your plan
of operations for the next twelve months. For example your disclosures elsewhere
including on page 1 indicate that you currently offer several over-the-counter
cosmetic, consumer products and your product pipeline includes a diverse range of
products, such as hair loss treatments, eczema and psoriasis treatments, vitiligo
solutions, jellyfish sting protective suncare line and women’s sexual wellness
products. In addition, one of your more recent transactions in June 2024 was related to
a license agreement with NOVODX Corporation for licenses to use, market, and sell
Ebola Rapid Tests. In the discussion of each of your planned activities, include
specific information regarding each material event or step required to pursue each of
your planned activities, including any contingencies, and the timelines and associated
costs accompanying each proposed step in your business plan.
Critical Accounting Policies and Estimates, page 37
The disclosures provided for each of your identified critical accounting policies
appear to provide investors with a discussion as to how you are accounting for these
items in accordance with US GAAP and are similar to your significant accounting
policies disclosures rather than providing investors with an understanding as to what
the critical estimates being made are and how the uncertainty associated with those
estimates may impact your consolidated financial statements. Please revise the
disclosures for each of your critical estimates made in preparing your consolidated
financial statements to sufficiently explain to investors what each critical estimate is;
the uncertainties associated with the critical estimates; the methods and assumptions
used to make the critical estimates, including an explanation as to how you arrived at
the assumptions used; the events or transactions that could materially impact the
assumptions made; and how reasonably likely changes to those assumptions could 9.

January 6, 2025
Page 4
impact your consolidated financial statements. Provide investors with quantified
information to the extent meaningful and available. Please refer to Section 501.14 of
the Financial Reporting Codification.
Business, page 40
10.We note your revised disclosure in response to prior comment 25 and reissue the
comment in part. Specifically, we note your disclosure that dimethicone is the USP
monographed ingredient used in your Photocil product. Please further revise your
disclosure to describe the use and effect of dimethicone in your Photocil product, how
the technology used in Photocil differs from technology used in other OTC
sunscreens, and whether dimethicone is used in other OTC sunscreen products.
11.We note your revised disclosure in response to prior comment 29 and reissue the
comment in part. Specifically, we note your disclosure that your licensee in India is
currently exploring additional sub-licensing opportunities in various countries,
although no formal agreements have been entered into at this time. Please revise to
identify the licensee in India and confirm whether you have entered into a license
agreement with such licensee, and if so, please provide a brief description of the
material terms of the license agreement and file the agreement as an exhibit to the
registration statement or explain to us why you believe you are not required to do so.
Refer to Item 601(b)(10) of Regulation S-K.
Intellectual Property, page 42
12.We refer to your revised disclosure in response to prior comment 32. We note that you
have deleted the column for “Product/Technology” in your table. Please restore this
disclosure accordingly.
Research and Development, page 42
13.We note your revised disclosure in response to prior comment 33 and reissue the
comment in part. We note your disclosure on pages 2 and 3 that the research and
commercial license agreements are valid only in jurisdictions where NOVODX has a
valid claim. Please revise your disclosure to clarify these jurisdictions in which
NOVODX has a valid claim.
Our Market Opportunity, page 43
14.We refer to your revised disclosure in response to prior comment 34 that JW-700 was
soft-launched on Amazon in Q4 2024 and that you anticipate sales pursuant to your
Sales Agent Agreement with NOVODX Corporation to begin by the end of the year.
Please disclose the date on which JW-700 was launched in the United States on
Amazon and clarify the current status of your sale of your JW-700 product on
NOVODX's e-commerce platform.
Competition, page 44
We note your revised disclosure in response to comment 37 and reissue the comment.
Please revise your disclosure in this section to identify your competitors within the
various markets in which you will compete and discuss how your products differs
from those of your competitors and how you plan to compete with the existing well-15.

January 6, 2025
Page 5
known brands in the industries. In this regard, please explain in greater detail the
"unique mechanism of action that offers clinical benefits not provided by traditional
products."
Government Regulations, page 44
16.We note your revised disclosure in response to prior comment 38, which we reissue in
part. Please revise your disclosure to include a discussion of the regulatory
requirements for your cosmetic products in the U.S. and other relevant jurisdictions.
Executive and Director Compensation, page 50
17.We note your response to prior comment 39. Please update your executive
compensation table for the fiscal year ended December 31, 2024. Refer to Item 402 of
Regulaton S-K and Question 117.05 of Regulation S-K Compliance and Disclosure
Interpretations.
Certain Relationships and Related Party Transactions, page 51
18.We note your revised disclosure throughout the registration statement describing
NOVODX Corporation as a related party. Please revise your disclosure here and
elsewhere in the registraiton statement to include the information required by Item
404 of Regulation S-K relating to your relationship with NOVODX.
Relationship with Safety Shot
Historical Relationship with Safety Shot, page 52
19.We note your disclosure on page 52 that "following the Separation Agreement, there
are no services being provided by Safety Shot to Caring Brands Florida" in response
to prior comment 41. However, you continue to disclose elsewhere, such as on page
31 that "Safety Shot currently provides certain services to us, and costs associated
with these functions have not been allocated to us," and on page 34, you state that you
"may agree with Safety Shot to extend the service periods for a limited amount of
time" and that "certain services will be provided under the Separation Agreement."
Please revise your disclosure to clarify what, if any, services are or will be provided
by Safety Shot to the Company under the Separation Agreement.
Security Ownership of Certain Beneficial Owners and Management, page 57
20.We note your disclosure on pages 7 and 57 that you issued 3 million shares of
common stock to the stockholders of Safety Shot, of which 2 million shares of
common stock will be distributed to the shareholders of Safety Shot following the
effectiveness of this registration statement. However, you disclose on page Alt-11 that
Safety Shot beneficially owns 2 million shares of common stock prior to the
effectiveness of the registration statement. We also note your disclosure on page Alt-
11 that NOVODX Corporation beneficially owns 1 million shares of common stock
prior to the offering, but is not disclosed elsewhere in the registration statement.
Please reconcile and revise your disclosures accordingly.

January 6, 2025
Page 6
Index to Consolidated Financial Statements, page F-1
21.Based on disclosure on page 40, it appears CBI NV acquired all of the equity of CBI
FL on September 24, 2024, and they were entities under common control prior to the
transaction. CBI NV had no operations since inception and appears to have been
created to effect a recapitalization. Please explain to us your basis for presenting the
financial statements included in this document and how their inclusion meets the
requirements of Regulation S-X. Explain why the financial statements of the registrant
required by Article 8 would not reflect the combined accounts of the two entities as a
single set of financial statements, with the historical periods reflecting the operations
of CBI FL and the recapitalization reflected for all periods presented.
Note 1 - Organization and Business Operations, page F-16
22.We note your response to comment 43.  It is not clear where additional disclosures
have been provided as your response indicates. Please explain and disclose the basis
of presentation for the carve-out financial statements, specifically how you
determined which operations should be included in the carve-out financial statements.
We note your disclosures that you were an operating segment of Safety Shot;
however, there are no disclosures in the Form 10-K for the year ended December 31,
2023, of Safety Shot indicating that there are different operating segments. We also
note other disclosures indicating that the company has operated as a wholly owned
subsidiary of Safety Shot.
23.We note your response to comment 44.  Please address the following pursuant to SAB
Topic 1.B.1:
•Please clearly disclose, if true, that the financial statements provided reflect all of
the costs of doing business related to these operations, including expenses
incurred by other entities on your behalf;
•In a similar manner to your response, please disclose that you do not believe that
there would be a material difference in expenses if you had been on a stand-alone
basis; and
•Please provide an analysis of the intercompany account with Safety Shot, Inc. as
well as the average balance due to Safety Shot, Inc.

November 15, 2024
Glynn Wilson
Chief Executive Officer
Caring Brands, Inc.
1061 E. Indiantown Rd.
Suite 110
Jupiter, FL 33477
Re:Caring Brands, Inc.
Draft Registration Statement on Form S-1
Submitted October 18, 2024
CIK No. 0002020737
Dear Glynn Wilson:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. 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 the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1 submitted October 18, 2024
Cover Page
We note your disclosure on pages 4 and 24 that you are currently a “controlled
company” within the meaning of the Nasdaq rules and that your officers and directors
are the beneficial owners of approximately 59.6% of your outstanding voting
securities. We also refer to your disclosure on page 52 identifying Safety Shot as your
controlling stockholder and that following the completion of this offering, Safety Shot
will beneficially own 21.26% of the outstanding shares of common stock. Please
revise your cover page and in the prospectus summary to disclose your “controlled
company” status, identify the controlling shareholder and the voting power percentage
of such controlling shareholder, and disclose that your officers and directors will have 1.

November 15, 2024
Page 2
the ability to substantially influence all matters submitted to your stockholders for
approval and to substantially influence or control your management and affairs.
Prospectus Summary
Company Overview, page 1
2.We note your disclosure here and throughout the prospectus that Photocil was
launched commercially in India in 2022 as a treatment for vitiligo and psoriasis and
that you plan to "re-launch Photocil in the US in 2024." Please revise to identify
Photocil’s target indications in the United States and clarify whether Photocil was
previously launched in the US or in any other jurisdictions. We refer to Safety Shot,
Inc.’s (formerly known as Jupiter Wellness Inc.) Form 8-K filed July 9, 2021 relating
to its exclusive license to manufacture and sell Applied Biology Inc.’s proprietary
product, Photocil, and its Form 8-K filed June 28, 2022 relating to Safety Shot’s
acquisition of all of Applied Biology Inc.’s assets pursuant to an asset purchase
agreement on June 20, 2022. Please revise to disclose the timeline of the development
and commercialization of Photocil, including but not limited to, when Safety Shot
licensed and purchased Photocil from Applied Biology Inc. and the regulatory status
of Photocil in India, the U.S. and in other jurisdictions, as applicable.
3.We note your disclosure that your "product pipeline includes a diverse range of
products." Please expand your disclosure with respect to each of your product
candidates in addition to addressing the following comments:

•We note your disclosure relating to Photocil that "additional licensing
opportunities are being pursued primarily in development markets with lower
direct access to physicians." Please expand your disclosure, where appropriate, to
discuss the licensing opportunities and identify the applicable jurisdictions;
•We refer to your disclosure on page 15 that the labeling of your Minoxidil
Booster product was approved by Indian regulatory authorities. Please clarify
whether your JW-700 product is also known as Minoxidil Booster and disclose
when you received labeling approval in India. Please revise to disclose, if true,
that JW-700 was initially developed by Applied Biology Inc. and acquired by
your parent, Safety Shot. Please also revise to disclose the timeline of the
development and commercialization of JW-700; and
•We note your disclosure of your plans to launch JW-700 in the US in the fourth
quarter of 2024, Taisho’s plan to launch JW-700 commercially in 2025, and the
launch of your CB-101 eczema treatment in the third quarter of 2024 with a new
formulation to be launched in the fourth quarter of 2024. Please revise to update
your disclosure in regard to these recent developments accordingly.
We note your disclosure that the "vitiligo treatment market was valued at $1.5 billion
in 2022 and is expected to grow to $2.57 billion by 2032" and that the "psoriasis
treatment market was valued at $26.5 billion in 2022 and is expected to grow to $60.5
billion by 2032." Additionally, on page 43, you disclose that you have a unique
portfolio that may be able to address a combined market size of approximately $70
billion. Please expand your disclosure to identify each of the target markets included
in your estimated $70 billion combined market size. For each total market opportunity 4.

November 15, 2024
Page 3
referenced, please revise to discuss how you calculated the estimates of the total
market opportunity, including the sources, methodology, and the assumptions and
limitations you relied on for these estimates, and specify the relevant jurisdiction(s)
for your estimates. Please balance your disclosure by addressing the current market
share of your products (such as phototherapy treatments) in each such target
market. Additionally, when referring to a statistic, study, or research article that is not
common knowledge please provide a full citation to the source of the information,
provide the date of the information, and, at first instance, provide a summary of the
material findings. In this regard, footnotes may be helpful.
5.We note your disclosure on page 1 and elsewhere in the prospectus that Photocil is an
OTC cosmetic product that uses a USP monographed ingredient and that you
anticipate your CB-101 treatment for eczema to be available in the US as an OTC
product under a USP monograph. You also disclose on page 44 that you “believe that
[y]our sunscreen products fall within the FDA monograph and that FDA premarket
approval and testing is not required” and that JW-700 and NoStingz do not require
FDA approval. Please revise your disclosure to clearly specify the regulatory status
for each of your products, including whether FDA pre-market approval is required,
and clarify which products will be OTC monograph products. Please also revise to
address the risk that you may not receive OTC approval for your products and the
impact this would have on such proposed products and operations, as applicable.
6.We refer to your disclosure that the results of clinical trials on Photocil, JW-700 and
JW-100 have previously been published in various journals. You also disclose that
JW-700 has been "clinically shown to increase the enzymes needed for minoxidil to
work." Please revise your disclosure to provide the material facts and findings of each
clinical trial. For example, revise to clarify the scope, size and design of each trial
(including who conducted the trial); whether the studies were powered to show
statistical significance; the primary endpoints and whether any adverse events were
observed in the studies, as applicable; and discuss the data and the significance of the
results. Please also disclose, if true, whether you funded or sponsored the clinical
studies and if your employees were involved in both the trials and publications.
7.We refer to your disclosure on page 1 and elsewhere in the prospectus that Photocil
provides patients with “safe and effective” phototherapy and that your product “safely
and effectively” permits phototherapy treatments at home by blocking harmful
radiation and permitting the passage of therapeutic UV radiation. You also explain on
page 44 that your products fall within the FDA monograph and are not subject to pre-
market approval by the FDA. Please revise your disclosure in the Summary to clarify
that your products are unapproved cosmetic products. For any product that has not
been approved by the FDA or a similar regulatory authority, please remove all such
claims of safety and efficacy, or alternatively, explain why such claims can be
substantiated and revise to provide such substantiation.
8.Given the limited disclosure regarding your NoStingz product and the status of its
development, it seems premature to highlight this product prominently in the
Summary. Please expand your disclosure relating to the NoStingz product here and in
the Business section or balance your disclosure to highlight the early stage of
development in the Summary accordingly.

November 15, 2024
Page 4
Corporate History, page 3
9.Please expand your disclosure to discuss the operational history of your company,
Caring Brands, Inc. ("Caring Brands Florida") and your parent company, Safety Shot,
Inc. Please also clarify that you were recently incorporated in Nevada in connection
with the separation from Safety Shot Inc. and that you have not historically operated
as a stand-alone company.
The Offering, page 6
10.We note your disclosure that "existing holders of all of our outstanding shares of
common stock, warrants, and options have agreed with the underwriters not to offer
for sale, issue, sell, contract to sell, pledge or otherwise dispose of any of our shares of
common stock or securities convertible into or exercisable for shares of common
stock for 180 days after the closing of this offering as described in further detail in the
prospectus." We also note your disclosure on the cover page of the Resale Prospectus
that "the shares offered by this prospectus may be sold by the Selling Stockholders
from time to time in the open market" and that "sales of the shares of our common
stock registered in this prospectus and the IPO Prospectus will result in two offerings
taking place concurrently. . ." Please revise your disclosure to clarify the lock-up
agreements between the parties and file each lock-up agreement as an exhibit to your
registration statement or explain why you are not required to do so.
Risk Factors, page 9
11.Please revise to include risk factor disclosure to address the risk of dilution related to
the concurrent resale offering, including the effect that the distribution by Safety Shot
may have upon dilution.
12.We note your disclosure on page Alt-1 that the selling stockholders must sell their
shares at a fixed price per share until such time as your shares are listed on a national
securities exchange, and thereafter, the resale shares may be sold by the selling
stockholders from time to time at market prices prevailing at the time of sale or at
negotiated prices. Given that there are two offerings and the offering prices could
differ, include risk factor disclosure to highlight the risk that purchasers in the resale
offering could pay more or less than the price in your primary offering.
Our Certificate of Incorporation contains an exclusive forum provision for certain claims . . .,
page 25
13.We note your disclosure on page 25 that the exclusive forum provision in your
amended and restated certificate of incorporation may limit a stockholder's ability to
bring a claim in a judicial forum that it finds favorable for disputes with you and may
discourage such lawsuits. Please revise this risk factor to include the risk of increased
costs for investors to bring a claim.
Use of Proceeds, page 29
Please revise to provide more specific detail regarding the use of funds to be allocated
to (i) the development of licensed goods, (ii) expansion products design, manufacture
and inventory, (iii) sales and marketing, and (iv) research and development with 14.

November 15, 2024
Page 5
respect to each of your Photocil, JW-700, CB-101, and NoStingz products, including
reference to how far the proceeds from the offering will allow you to proceed with
continued development of each product listed.
Capitalization, page 30
15.Please clearly show in the notes to the capitalization table how you computed each pro
forma amount, including a discussion of any significant assumptions and estimates
used to arrive at the amounts.
Dilution, page 31
16.Please correct the total shares, which appear to total 14,110,000. Please tell us where
you discuss the “other issuance” of 400,000 shares or provide appropriate disclosure
in the filing for this transaction.
Unaudited Pro Forma Condensed Combined Financial Statements, page 31
17.Pursuant to Rule 11-02(a)(2) of Regulation S-X, please provide notes for each
adjustment to explain the nature of the adjustment and correspondingly how the
adjustment amount was determined, including a discussion of any significant
estimates and assumptions used to determine the amount. For example, on the pro
forma balance sheet, there is an adjustment to Loans from Safety Shot. It is not clear if
this is due to the loan being repaid or settled in some other manner.
18.Please also provide a pro forma statement of operations for the year ended December
31, 2023. Refer to Rule 11-02(c)(2) of Regulation S-X.
19.Please present the historical basic and diluted per share amounts and the number of
shares used to calculate such per share amounts on the face of the pro forma
condensed statement of operations. Please disclose in a note to the pro forma financial
information your computation of the number of basic and diluted weighted average
shares to use in determining your pro forma earnings per share amounts. Please also
disclose any shares not included for anti-dilution reasons. Refer to Rule 11-02(a)(9) of
Regulation S-X.
20.In note 1 to the pro forma financial information, you indicate that the founder shares
are assumed to have been issued on January 1, 2024, the private placement shares
issued in May and June, and the Ebola License shares in June for purposes of
calculating the weighted average net loss per share. It appears that the private
placement shares and Ebola License shares have only been reflected in the historical
financial statement amounts based on their actual transaction date not are not being
adjusted for in arriving at your pro forma financial information. Please clarify in your
disclosures.

November 15, 2024
Page 6
21.We note your disclosures on page 34 regarding certain services that will be provided
under the separation agreement and also disclosure regarding costs you expect to incur
to replace certain services previously provided by Jupiter Wellness. Please tell us
what consideration was given to reflecting these additional costs including those
associated with the separation agreement in your pro forma financial
information. Please also disclose the terms of the separation agreement, including the
consideration that you will pay for these services. Please refer to Rule 11-02(a)(6)(ii)
of Regulation S-X.
22.We note your disclosures regarding the Taisho License, including that it will be
transferred to the company from Safety Shot pursuant to the Separation and Exchange
Agreement. Please tell us what consideration you gave to reflecting this transaction in
the pro forma financial information.
Management's Discussion and Analysis, page 34
23.Given that Caring Brands, Inc. (Florida) did not have any reported revenues during six
months ended June 30, 2024, please provide a more clear description of the status of
your current operations and your plan of operations for the next twelve months. For
example your disclosures elsewhere including on page 1 indicate that you currently
offer several over-the-counter cosmetic, consumer products and your product pipeline
includes a diverse range of products, such as hair loss treatments, eczema and
psoriasis treatments, vitiligo solutions, jellyfish sting protective suncare line and
women’s sexual wellness products. In addition, one of your more recent transactions
in June 2024 was related to a license agreement with NO