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 Lakewood-Amedex Biotherapeutics Inc.

 8031 Cooper Creek Blvd,
Unit 103

 University Park, FL
34201

 (941) 225-2515

 May 12, 2026

 Ms. Doris Stacey Gama

 U.S. Securities & Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Lakewood-Amedex Biotherapeutics Inc.

 Registration Statement on Form S-1

 Filed May 1, 2026
 File No. 333-295497

 Acceleration Request:
 Requested Date: May 13,
 2026
 Requested Time: 4:00 P.M.
 Eastern Time

 Dear Ms. Gama:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Lakewood-Amedex Biotherapeutics Inc. (the " Company ") hereby requests that
the above-referenced Registration Statement on Form S-l (File No. 333-295497) (the " Registration Statement ")
be declared effective on the "Requested Date" and at the "Requested Time" set forth above or at such later time
as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities
and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Lucosky
Brookman LLP, by calling Scott Linsky at (732) 395-4408.

 Thank you for your assistance
in reviewing this filing. If you have any questions or comments regarding the foregoing, please contact Kelvin Cooper via email at kcooper@lakewoodamedex.com.

 Very truly yours,

 /s/ Kelvin Cooper

 Kelvin Cooper

 Chief Executive Officer

 Cc: Scott E. Linsky, Esq.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 8, 2026

Kelvin Cooper
Chief Executive Officer
Lakewood-Amedex Biotherapeutics Inc.
8031 Cooper Creek Blvd., Unit 103
University Park, Fl 34201

 Re: Lakewood-Amedex Biotherapeutics Inc.
 Registration Statement on Form S-1
 Filed May 01, 2026
 File No. 333-295497
Dear Kelvin Cooper:
 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 Doris Stacey Gama at 202-551-3188 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Scott Linsky, Esq.
</TEXT>
</DOCUMENT>