United States securities and exchange commission logo





                             June 2, 2020

       Christopher Schreiber
       Executive Chairman
       Akers Biosciences, Inc.
       201 Grove Road
       Thorofare, NJ 08086

                                                        Re: Akers Biosciences,
Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed May 22, 2020
                                                            File No. 333-238631

       Dear Mr. Schreiber:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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.

       Registration Statement on Form S-3 filed May 22, 2020

       Prospectus Summary
       Overview, page 2

   1.                                                   We note your disclosure
that Premas Biotech PVT Ltd, your partner company, has
                                                        successfully completed
its COVID-19 vaccine prototype. Please update your disclosure to
                                                        clarify the current
clinical or pre-clinical stage of development of the vaccine product
                                                        candidate and the
jurisdiction. Make clear the possibility that the FDA may not accept
                                                        clinical trials
performed in other jurisdictions and may require additional testing. Please
                                                        also balance your
disclosure by stating that you will need to submit an IND to the FDA
                                                        and complete all phases
of clinical trials before you can apply to receive marketing
                                                        approval for this
product candidate.
 Christopher Schreiber
Akers Biosciences, Inc.
June 2, 2020
Page 2
2.    If true, please also clarify that Premas has responsibility to develop
the product candidate
      through proof of concept.
3.    Please disclose the scope, jurisdiction and expiry date for each of the
patents that are
      related to the COVID-19 vaccine product candidate. To the extent that
neither you nor
      Premas have any patents related to the COVID-19 product candidate, please
disclose.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Alan Campbell at 202-551-4224 or Celeste Murphy at
202-551-3257 with
any questions.



                                                            Sincerely,
FirstName LastNameChristopher Schreiber
                                                            Division of
Corporation Finance
Comapany NameAkers Biosciences, Inc.
                                                            Office of Life
Sciences
June 2, 2020 Page 2
cc:       Rick A. Werner, Esq.
FirstName LastName