AXIM Biotechnologies, Inc.

6191 Cornerstone Court, E. Suite 114

San Diego, CA 92121

 

June 21, 2021

 

VIA EDGAR

 

Division of Corporation Finance

Office of Life Sciences

U.S. Securities & Exchange Commission (the “Commission”)

100 F Street, N.E.

Washington, D.C. 20549

 

Attention:	David Gessert
Re:	AXIM Biotechnologies, Inc.
	Registration Statement on Form S-1/A
	Filed June 9, 2021
	File No. 333-256162

 

 

Ladies and Gentlemen:

 

Pursuant to Rule 461 under the Securities Act of 1933, as amended, AXIM Biotechnologies, Inc. (the “Company”) hereby requests that the effective date for the above-referenced Amendment No. 1 to the Registration Statement on Form S-1 (File No. 333-256162) be accelerated so that it will be declared effective at 5:00 PM Eastern Standard Time on June 22, 2021, or as soon thereafter as is practicable.

 

The undersigned, on behalf of the Company, acknowledges the following:

 

·should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; 

 

·the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and 

 

·the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States 

 

Sincerely,

AXIM BIOTECHNOLOGIES, INC.

/s/ John W. Huemoeller II

John W. Huemoeller II

President