TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo November 14, 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. 4 to Registration Statement on Form S-1 Filed November 10, 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 November 9, 2022 letter. Amendment No. 4 to Registration Statement on Form S-1 filed November 10, 2022 Cover Page 1. We note your response to prior comment 2. Please reconcile the reference on the cover page to "the selling stockholders identified in this prospectus are offering an additional 4,015,904 shares of [y]our common stock" with 3,815,904 shares being offered by selling stockholders based on the sum of the shares being offered per the table on page 83. General 2. On page 90, you disclose that White Bear received 40,000 shares, contrary to the numbers in Exhibit 10.32 and page 83. Please reconcile. John G. Grdina Adamas One Corp. November 14, 2022 Page 2 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, FirstName LastNameJohn G. Grdina Division of Corporation Finance Comapany NameAdamas One Corp. Office of Manufacturing November 14, 2022 Page 2 cc: Raymond A. Lee, Esq. FirstName LastName