Axium Pharmaceuticals, Inc.
265 Eastchester Drive,
Suite 133
High Point, NC 27262
December 28, 2017
United States Securities and Exchange Commission
Washington, DC 20549
| Re: | Axium Pharmaceuticals Inc. Amendment No. 4 to Registration Statement on Form S-1 Filed December 13, 2017 File No. 333-220076 |
Dear Sir or Madam:
Please see below our responses to your letter dated December 28, 2017:
Part II – Information not Required in Prospectus, page II-1
Comment 1: Please re-locate your financial statements so that they precede Part II of your registration statement.
Response 1. The Registration Statement has been revised accordingly.
Exhibits
Comment 2. Please revise your Exhibit 23.2 to include a currently signed and dated consent letter from your auditor.
Response 2. The Registration Statement has been revised accordingly.
Sincerely,
/s/ Anthony Harrelson
Anthony Harrelson, CEO
