Alliance BioEnergy Plus, Inc.
3710 Buckeye Street
Suite 120
Palm Beach Gardens, FL 33410
April 23, 2021
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporate Finance
Office of Life Sciences
100 F Street, N.E.
Washington, D.C. 20549
Attn: Joe McCann
| Re: | Alliance BioEnergy Plus, Inc. | |
| Registration Statement on Form 10-12G/A (Third Amendment) | ||
| Filed April 7, 2021 | ||
| File No. 000-54942 |
Ladies and Gentlemen:
On behalf of the Company, we are responding to oral comments from Joe McCann relative to the disclosure of the terms of a License Agreement between the Company and Vertimass, LLC (“Vertimass”).
Specifically, the Company has received a letter from Vertimass wherein they have demanded that the Company not disclose the content of the License Agreement. Vertimass further stated that they consider the terms of the License Agreement to be confidential and they have insisted that the Company not publish the information. The Company believes that it has no alternative other than to maintain the confidentiality of the License Agreement. We have attached a copy of the Vertimass letter as Attachment A.
On behalf of the Company, we acknowledge that:
● 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.
| Very truly yours, | ||
| Alliance BioEnergy Plus, Inc. | ||
| By: | /s/ Benjamin Slager | |
| Benjamin Slager | ||
| Chief Executive Officer | ||
| cc: | Robert L. B. Diener, Esq. |
Appendix A
