TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo February 3, 2022 Neil J. Laird Chief Financial Officer NovAccess Global Inc. 8834 Mayfield Road, Suite C Chesterland , Ohio 44026 Re: NovAccess Global Inc. Form 10-K for the year ended September 30, 2021 Filed January 13, 2022 File No. 000-29621 Dear Mr. Laird: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the year ended September 30, 2021 Item 9A. Controls and Procedures, page 8 1. We note in the first paragraph of this section that your disclosure controls and procedures were effective as of September 30, 2021. We also note in the third paragraph of this section that you indicated that your disclosure controls and procedures were not effective as of September 30, 2021 due to a material weakness instead of disclosing your conclusion on the effectiveness of your internal control over financial reporting. Please revise your disclosures to provide the following in future filings: Please revise your disclosures to clearly state your conclusion regarding the effectiveness of your disclosure controls and procedures; Please specifically state your conclusion regarding the effectiveness of your internal control over financial reporting; and We refer you to Sections II.D and E of SEC Release 33-8238, in which the Commission recognizes that there is substantial overlap between disclosure controls Neil J. Laird NovAccess Global Inc. February 3, 2022 Page 2 and procedures and internal control over financial reporting. Given the reference to your material weakness, please consider the impact on your overall conclusion regarding the effectiveness of your disclosure controls and procedures. Refer to Items 307 and 308 of Regulation S-K. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Ernest Greene, Staff Accountant at 202-551-3733 or John Cash, Accounting Branch Chief at 202-551-3768 with any questions. FirstName LastNameNeil J. Laird Sincerely, Comapany NameNovAccess Global Inc. Division of Corporation Finance February 3, 2022 Page 2 Office of Manufacturing FirstName LastName