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                              September 26, 2022

       John G. Grdina
       President and Chief Executive Officer
       Adamas One Corp.
       17767 N. Perimeter Dr., Ste B115
       Scottsdale, Arizona 85255

                                                        Re: Adamas One Corp.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed September 14,
2022
                                                            File No. 333-265344

       Dear Mr. Grdina:

             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 June
28, 2022 letter.

       Amendment No. 1 to Registration Statement on Form S-1 filed September
14, 2022

       Cover Page

   1.                                                   We note your response
to prior comment 8. As previously requested, clarify what do you
                                                        mean by "after the
closing of this initial public offering."
   2.                                                   Please expand your
response to prior comment 2 to address the conversion price, which
                                                        appears to be fixed at
a discount to the as-yet undetermined public offering price, and the
                                                        true-up provisions
included in your exhibits.
 John G. Grdina
FirstName LastNameJohn   G. Grdina
Adamas One  Corp.
Comapany 26,
September NameAdamas
              2022      One Corp.
September
Page 2    26, 2022 Page 2
FirstName LastName

Inflationary Pressures, page 48

3.       We note your revisions in response to prior comment 3. Please expand
to identify the
         "industrial equipment, raw materials, services, and shipping"
materials whose costs have
         increased and quantify the amount of the increase and impact on your
business, results of
         operation and liquidity.
Principal Stockholders, page 80

4.       Please identify the natural person(s) who have or share voting and/or
dispositive powers
         with respect to the shares held by the entities listed in the table
here and the table on page
         82.
Selling Stockholders, page 81

5.       Please revise the disclosure to clarify the relationship between
Target Capital 3 LLC and
         Alchemy Advisory LLC. In this regard, it appears from: (1) page 5 of
the amended side
         letter agreement filed as exhibit 10.19(N) that Dmitriy Shapiro is the
managing partner of
         Target Capital 3 LLC; and (2) page 4 of the amended consulting
agreement filed as
         exhibit 10.20(E) that Dmitriy Shapiro is the founder of Alchemy
Advisory LLC.
6.       Please disclose the material terms of the fifth extension agreement
with Target Capital 3,
         LLC filed as exhibit 10.9(i) and the amended consulting agreement with
Alchemy
         Advisory LLC filed as exhibit 10.20(E), such as the "True-Ups"
provisions in section 5 of
         of exhibit 10.9(i) and 10.20(E).
7.       Please include footnotes to the table to disclose the amount of shares
of common stock
         that each selling stockholder received as: (1) an additional incentive
for their investment;
         and (2) an additional incentive for the execution of their extension
agreements. In this
         regard, we note the disclosure in the fourth paragraph on page 87
about the issuance of
         shares of common stock as an additional incentive for investment and
the issuance for
         shares of common stock for the execution of extension agreements.
8.       Please reconcile the information in note (3) on page 82 about
1,085,263 shares of common
         stock issuable upon conversion of a note with the reference to
1,145,556 shares of
         common stock issuable upon conversion of a note in the Calculation of
Filing Fee Table
         filed as exhibit 107.
       You may contact Charles Eastman, Staff Accountant, at 202-551-3794 or
Andrew Blume,
Senior Accountant, at 202-551-3254 if you have questions regarding comments on
the financial
statements and related matters. Please contact Thomas Jones, Staff Attorney, at
202-551-3602 or
Geoff Kruczek, Senior Attorney, at 202-551-3641 with any other questions.



                                                                Sincerely,
 John G. Grdina
Adamas One Corp.
September 26, 2022
Page 3

FirstName LastNameJohn G. Grdina
                                   Division of Corporation Finance
Comapany NameAdamas One Corp.
                                   Office of Manufacturing
September 26, 2022 Page 3
cc:       Raymond A. Lee, Esq.
FirstName LastName