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                             November 9, 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. 3 to
Registration Statement on Form S-1
                                                            Filed November 3,
2022
                                                            File No. 333-265344

       Dear John G. 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
October 31, 2022 letter.

       Amendment No. 3 to Registration Statement on Form S-1 filed November 3,
2022

       Government Regulations, page 63

   1.                                                   We note your disclosure
in this section, such as "In August 2018, the FTC amended its
                                                        Jewelry Guides to help
prevent deception in jewelry marketing." Please ensure that you
                                                        have updated the
disclosure about government regulation to the extent practical. Also, tell
                                                        us the extent to which
you have considered FTC regulations given the references in the
                                                        bullet points on pages
4 and 58 to "environmentally friendly" diamonds and the reference
                                                        to "Eco Friendly" under
the phrase "Benefits of Lab-Grown Diamonds" on your website.
 John G. Grdina
FirstName LastNameJohn   G. Grdina
Adamas One   Corp.
Comapany 9,
November  NameAdamas
             2022        One Corp.
November
Page 2    9, 2022 Page 2
FirstName LastName
General

2.       Please file a final legal opinion. Currently, Exhibit 5.1 is merely a
"form" of opinion, is
         undated and has numerous blanks.
       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,

                                                                Division of
Corporation Finance
                                                                Office of
Manufacturing
cc:      Raymond A. Lee, Esq.