December 23, 2019
Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences.
Re: AXIM Biotechnologies, Inc. (the “Company”)
Form 10-K for the Fiscal Year Ended December 31, 2018 Filed April 8, 2019
File No. 000-54296
Dear Messrs. Vaugn and Sundwall:
Please allow the following to respond to your letter dated October 23, 2019.
Form 10-K for the Fiscal Year Ended December 31, 2018
Item 15. Exhibits, Financial Statement Schedules, page 20
1.You disclose a May 11, 2015 license agreement with CanChew Biotechnologies, LLC, whom you have disclosed on page 20 is a related party. It appears that a significant amount of your research and development activities may be derived from intellectual property included in this license agreement, including development activities that may be included in your September 3, 2018 Letter of Intent or subsequent agreements with Impression Health Limited. These agreements do not appear to have been filed as exhibits. Please confirm to us that you will file these agreements as exhibits, or provide your analysis demonstrating why you do not consider these agreements to be material contracts under Regulation S-K, Rule 601(b)(10).
The Company intends to file the May 11, 2015 license agreement with CanChew Biotechnologies, LLC with its annual report for the year ending December 31, 2019.
Should you have any comments or questions, please do not hesitate to contact the undersigned.
AXIM Biotechnologies, Inc.
/s/ Robert Malasek
45 Rockerfeller Place, 20th Floor | Suite 83 | New York, NY 10111 | (212) 751-0001