Axim Biotechnologies, Inc.
45 Rockefeller Plaza, 20th Floor, Suite 83
New York, NY 10111
(212) 751-0001
September 11, 2017
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.E.
Washington, D.C. 20549
Re: | Axim Biotechnologies, Inc. |
| Registration Statement on Form S-3 |
| File No. 333-220155 (the “Registration Statement”) |
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REQUEST FOR ACCELERATION OF EFFECTIVENESS |
Ladies and Gentleman:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Axim Biotechnologies, Inc. respectfully requests that the effective date of the above-referenced Registration Statement be accelerated by the Securities and Exchange Commission so that the same will become effective at 5:30 p.m., Washington D.C. time, on September 13, 2017, or as soon thereafter as is practicable.
Please call John P. Cleary of Procopio, Cory, Hargreaves & Savitch LLP at (619) 515-3221 as soon as the Registration Statement has been declared effective.
| Very Truly Yours, |
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| Axim Biotechnologies, Inc. |
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| By: /s/ Dr. George Anastassov |
| Name: Dr. George Anastassov |
| Title: President |
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