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United States securities and exchange commission logo





                          February 24, 2021

       Heng Fai Ambrose Chan
       Chief Executive Officer
       Impact BioMedical, Inc..
       200 Canal View Boulevard, Suite 104
       Rochester, NY 14623

                                                        Re: Impact BioMedical,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed February 12,
2021
                                                            File No. 333-253037

       Dear Mr. Chan:

               Our initial review of your registration statement indicates that
it fails in numerous
       material respects to comply with the requirements of the Securities Act
of 1933, the rules and
       regulations thereunder and the requirements of the form. More
specifically, we note that the
       registration statement does not contain an audit report for the
FY12/31/2019 financial statements
       as required by Item 11(e) to Form S-1. In addition, we note that you are
not eligible under Item
       12 of Form S-1 to incorporate by reference to either the FY12/31/2018 or
       FY12/31/2019 financial statements contained in a Form 8-K by Document
Security Systems, Inc.

              We will provide more detailed comments relating to your
registration statement
       following our review of a substantive amendment that addresses these
deficiencies.

                                                        Please contact Joseph
McCann at (202) 551-6262 with any questions.





                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Darrin M. Ocasio
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