BIOSTEM TECHNOLOGIES, INC.
2836 Center Port Circle
Pompano Beach, FL 33064
October 28, 2025
VIA
EDGAR
Securities and Exchange Commission
Division of
Corporation Finance
100 F Street NE
Washington, D.C.
20549-3561
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| Attention: |
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Eric Atallah |
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Angela Connell |
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Laura Crotty |
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Tamika Sheppard |
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Suzanne Hayes |
Application for Withdrawal of Registration Statement on Form 10-12(b)
Initially filed September 27, 2024
File No. 001-42292
Ladies and Gentlemen:
Pursuant to Rule 477
under the Securities Act of 1933, as amended, BioStem Technologies, Inc., a Florida corporation (the “Company”), hereby requests withdrawal of the Company’s Registration Statement on Form 10, initially filed with the
Commission on September 27, 2024, together with all exhibits and amendments thereto (the “Registration Statement”). The Company is in the process of revising its registration statement and accompanying financial statements to
adequately address certain comments received from the Commission. No securities were sold in connection with the Registration Statement.
It is our understanding that this application for withdrawal of the Registration Statement will be deemed granted as of the date that it is
filed with the Commission unless, within fifteen days after such date, the Company receives notice from the Commission that this application will not be granted.
If you have any questions or comments with respect to this matter, please call counsel for the Company, Flora Perez, at (954) 768-8210.
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| Very truly yours, |
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| BioStem Technologies, Inc. |
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| By: |
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/s/ Jason Matuszewski |
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Name: Jason Matuszewski |
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Title: Chairman and Chief Executive Officer |
