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                               December 16, 2022

       John Morgan
       Chief Executive Officer
       Lee Pharmaceuticals, Inc.
       11 N Water Street
       Mobile, AL 36602

                                                        Re: Lee
Pharmaceuticals, Inc.
                                                            Amendment No. 2 to
Offering Statement on Form 1-A
                                                            Filed December 1,
2022
                                                            File No. 024-11991

       Dear John Morgan:

             We have reviewed your amended offering 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 offering 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 offering 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 1, 2022 letter.

       Amendment No. 1 to Form 1-A filed December 1, 2022

       Risk Factors
       Risks Related to the Company and Its Business, page 10

   1.                                                   To the extent material,
please provide risk factor disclosure regarding your transactions
                                                        involving
cryptocurrency. Describe any material risks to your business from the
                                                        possibility of
regulatory developments related to crypto assets. Please also describe any
                                                        material risks related
to the safeguarding your or your customers    crypto assets. Describe
                                                        any material risks to
your business and financial condition if the third party provider that
                                                        you use for payments
has ineffective policies and procedures surrounding the
                                                        safeguarding of crypto
assets, conflicts of interest, or comingling of assets.
 John Morgan
Lee Pharmaceuticals, Inc.
December 16, 2022
Page 2
We are not considered a "Covered Entity"..., page 10

2.    Notwithstanding your assertion that there is no material risk that HIPAA
or other similar
      laws related to the storage of health information could apply to your
business, please
      revise your discussion here to clarify that this position reflects the
belief of your
      management. Address the applicability of other rules and regulations
relating to your
      storage and tracking of unique health information of potential users, and
discuss any
      related risks to the company and to investors. If there are no such
material risks, consider
      moving this disclosure to your Description of Business section. See Item
7(a)(1)(vi) of
      Form 1-A.
Description of Business
Corporate History, page 22

3.    We note your response to prior comment 2. Please add the information set
forth in your
      response letter describing the rationale for the acquisition of
Accelerate Global Market
      Solutions Corp. to the disclosure in the offering statement.
Description of Securities
Series A Preferred Stock, page 29

4.    We note your response to prior comment 5. Please revise your disclosure
in the offering
      statement to include the information set forth in your response letter
explaining the
      mechanism by which holders of the Series A Preferred Stock control 60% of
the voting
      power.
       You may contact Lauren Pierce, Staff Attorney, at (202) 551-3887 or
Joshua Shainess,
Legal Branch Chief, at (202) 551-7951 with any questions.



                                                            Sincerely,
FirstName LastNameJohn Morgan
                                                            Division of
Corporation Finance
Comapany NameLee Pharmaceuticals, Inc.
                                                            Office of
Technology
December 16, 2022 Page 2
cc:       Jeff Turner
FirstName LastName