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                              January 3, 2023

       Heng Fai Ambrose Chan
       Chief Executive Officer
       Impact BioMedical, Inc.
       275 Wiregrass Pkwy
       West Henrietta, NY 14586

                                                        Re: Impact BioMedical,
Inc.
                                                            Amendment No. 6 to
Registration Statement on Form S-1
                                                            Filed December 7,
2022
                                                            File No. 333-253037

       Dear Heng Fai Ambrose Chan:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
August 31, 2022 letter.

       Amendment No. 6 to Form S-1 filed December 7, 2022

       Capitalization, page 17

   1.                                                   We note that your
capitalization table is presented as of December 31, 2021. Please
                                                        update your table to
disclose your capitalization as of your most recent balance sheet date
                                                        included in the filing,
September 30, 2022.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Liquidity and Capital Resources, page 25

   2.                                                   Please update your
liquidity and capital resources discussion as of your most recent
                                                        balance sheet included
in the filing. Refer to Item 303(c) of Regulation S-K.
 Heng Fai Ambrose Chan
Impact BioMedical, Inc.
January 3, 2023
Page 2
Interim Financial Statements
Note 2. Summary of Significant Accounting and Reporting Policies
Income Taxes , page F-25

3.    We note from your response to prior comment 3 that you recorded a
valuation allowance
      against your deferred tax assets as of September 30, 2022. Please clarify
if you have a full
      valuation allowance against your deferred tax assets as of September 30,
2022. Also
      given the significant impact to your income tax expense for the nine
months ended
      September 30, 2022, revise your footnote to provide detailed disclosure
regarding this
      change. Refer to FASB ASC 740-270-50-1.
       You may contact Eric Atallah at 202-551-3663 or Mary Mast at
202-551-3613 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jordan Nimitz at 202-551-5831 or Tim Buchmiller at 202-551-3635 with
any other
questions.



                                                            Sincerely,
FirstName LastNameHeng Fai Ambrose Chan
                                                            Division of
Corporation Finance
Comapany NameImpact BioMedical, Inc.
                                                            Office of Life
Sciences
January 3, 2023 Page 2
cc:       Darrin M. Ocasio, Esq.
FirstName LastName