Impairment

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it evaluates the status of all of its legal proceedings in each reporting period, including the patent infringement complaint filed against the Company by Teva Pharmaceutical Industries (“Teva Complaint”), to assess whether accruals are appropriate under ASC 450-20-25-2 and to determine whether an estimate of possible loss or a range of possible losses can be made under ASC 450-20-50. During this evaluation, the Company’s management considers all existing and new matters, including, but not limited to, (i) the nature and status of each matter; (ii) the advice of legal counsel and other advisors related to each matter; (iii) the Company’s experience or that of other entities in similar matters; (iv) the Company’s belief in whether it has meritorious and valid substantive defenses against the allegations…

The Company respectfully acknowledges the Staff’s comment and has accordingly revised pages 56 and 57 of the Amendment. Asiana Trading Corporation, page 97

The Company has amended disclosure on page 16 in response to the Staff’s comments. Should you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please contact me at +852.5600.0188. Very truly yours, /s/ Lawrence S. Venick Lawrence Venick Partner

We will revise our accounting to comply with ASC 350-30-35-19 and conform our disclosure related to digital currency fair value impairment testing. We will remove the reference to a “nightly” measurement when determining fair value for impairment testing and instead reference Bitcoin intraday lows as the measurement used for fair value testing. 8. Digital Currencies, page F-30 Comment No.

Prior to filing, we inspected the Bitcoin miners that are installed at the hosting facility in Texas and observed the following: · We were not restricted from accessing our mining equipment at the hosting facility in Texas; · The Bitcoin miners were inspected and appeared to be in good condition; · At the reporting date we were in discussions with operator of the facility to energize the equipment to allow us to begin mining operations; and · At the time of the filing management fully intended and expected the miners to begin mining within two to four weeks. Based on the above, we expected the mining equipment to be operational within a reasonable timeframe, which did not trigger an interim impairment assessment. * * * Should you have any questions regarding the foregoing, please do not hesitate to contact the undersigned at (949) 444-5464 or our General Counsel, Henry Nisser at (646)…

The Company acknowledges the Staff’s comment and submits that, taking into account guidance provided in Questions 100.01 and 102.03 of the Compliance and Disclosure Interpretations (as updated on December 13, 2022), it clarified in its non-GAAP measures disclosure in the Quarterly Report to state that some of the excluded items involve cash outlays and some of them recur on a regular basis but that management does not believe any such items are normal operating expenses necessary to generate bitcoin related revenues. The Company also notes that it removed any disclosure implying that all such adjustments were non-recurring. The Company further submits that the new disclosure specifically identifies each adjustment to Adjusted EBITDA, including each non-cash line item, and each such item is quantified in the reconciliation table. The Company further notes that similarly modified the…

The Company acknowledges the Staff’s comment and respectfully submits that the Company will include further details about facts and circumstances leading to material goodwill impairments. Bitcoin, page F-17

The Company acknowledges the Staff’s comment and respectfully submits that the Company values each bitcoin (or fraction thereof) individually at the fair value on the date it was mined. Each of these individual bitcoins which are held at the quarter end are then evaluated for impairment based on their respective carrying basis. The impairment analysis on bitcoin, performed quarterly, compares the carrying amount of each bitcoin to the lowest daily closing bitcoin price during such quarter. The fair value of bitcoin pricing is derived daily from NASDAQ.com and the Company compares the quoted price from NASDAQ.com to other sources to ensure there is no material variance in quoted pricing. The Company selected NASDAQ.com due to its consistent daily activity, whereas other sources were not as reliable on a daily basis. The Company utilizes quotes from NASDAQ.com to impair its bitcoin…

The Company respectfully acknowledges the Staff’s comment and advises the Staff that the Company performs a quarterly qualitative goodwill impairment assessment to confirm whether it is more likely than not (i.e., a likelihood of greater than 50 percent), that the fair values of its reporting units are less than their carrying values. This is completed for all three of the Company’s operational business segments: Corporate Finance (“CF”), Financial and Valuation Advisory (“FVA”), and Financial Restructuring (“FR”), in accordance with ASU 2017-04. At a high level, this analysis includes assessing relevant events and circumstances pertaining to CF, FVA, and FR. If management determines the reporting unit’s fair value is more likely than not less than its carrying value, a quantitative analysis will be performed to compare the fair value of a reporting unit with its corresponding carrying…

In response to the Staff’s comment, the Company respectfully notes that it intends to describe such risks due to disruptions in the crypto asset markets, by including the following risk factors in the Company’s upcoming annual report on Form 20-F: Market volatility of the INX Token may affect the value of investment by token holders The trading price of INX Tokens may be affected by any number of factors including volume traded, volatility in the broader market for blockchain assets, changes in analyst earnings estimates, fluctuations in our results of operations, shifting investor perceptions, dilution (in both monetary and percentage amounts) from future sales or issuances of INX Tokens by the Company, large purchases or sales by a significant INX Token holders, or the announcement of new products. Any of these factors could affect the trading price of INX Tokens. Market volatility of…

Comment: Tell us why you have not presented for the predecessor the combined balances of the twenty entities that you have identified as comprising the predecessor operations at the dates that each was conveyed and or derecognized by Golar LNG Limited; and why you have not presented for the successor the equity balances as of the beginning of the year and separate lines for the financing and investing transactions that occurred and impacted the equity balances during the interim period. In response to the Staff’s comment, the Company notes that as described in Note 1 of the interim financial statements on pages F-39 and F-40 and pursuant to the Vessel SPA and ManCo SPA, CoolCo acquired thirteen legal entities from Golar on various acquisition dates during the period from March 3, 2022 to June 30, 2022. As further described in the following paragraph, the Company has revised the…

In response to the Staff’s comment, the Company has revised footnote 2 in Note 12 on page F-56 of the Registration Statement to note that the depreciation and amortization reflects the impact of remeasurement to fair value of the LNGCs acquired pursuant to the Vessel SPA. This update indicates that the depreciation charged during the Predecessor period of $5,745 thousand is depreciation charged by the Predecessor based on the net book value of the Original Vessels before the revaluation of such vessels and as per the respective accounting policy of the Predecessor as noted in Note 2d on page F-50 of the Registration Statement. Depreciation charged during the Successor Period is based on the revised fair value of such vessels upon acquisition by the Company as described under the vessels and equipment accounting policy disclosed in Note 2c. As explained above, the Company believes that…

In response to the Staff’s comment, the Company has revised the disclosures regarding Critical Accounting Policies and Estimates on page 219 of the Amended Registration Statement to add goodwill impairment as a critical accounting estimate. The Company respectfully advises the Staff that Tranglo represents a separate reporting unit, and impairment testing of the goodwill arising from the acquisition of Tranglo includes only Tranglo operations. Results of Operations, page 220

The Company respectfully acknowledges the Staff’s comment and has accordingly revised pages [56] of the Amendment. 2 Note 20. Intangibles assets, page F-26

The Company respectfully acknowledges the Staff’s comment and advises the Staff that the Company has revised the risk factor beginning on page 74 of the Proxy Statement to contemplate the above-listed risks. Risks Related to Government Regulation and Privacy Matters, page 57

The Company respectfully acknowledges the Staff’s comment and advises the Staff as follows: • Bitcoin Depot did not have a formal investment policy or express purpose with respect to acquiring, holding or transacting for investment purposes; rather, it purchased quantities of Cryptocurrencies in excess of its then current operational needs to take advantage of favorable market trends at the time of purchase. The Company has revised the subject disclosure to remove reference to “once the investment purpose has been achieved.” “Once the investment purpose has been achieved” referred to Bitcoin Depot’s decision to liquidate the excess position once it was determined that there was no additional likely future benefit (e.g., probable market price increases) from continuing to hold the excess Cryptocurrencies. Cryptocurrencies held by Bitcoin Depot are and have been for the periods presented…

The Company acknowledges the Staff’s comment and respectfully advises the Staff that for cryptocurrency held for investment, the investment is initially recorded at cost and subsequently measured at cost, net of any impairments incurred since acquisition. Bitcoin Depot performs an analysis each quarter to identify whether there has been a decrease in the market price relative to the carrying value of each cryptocurrency held for investment. If the carrying value exceeds the lowest market price at any time since acquiring the specific cryptocurrency held for investment, an impairment is recorded in the amount equal to the difference between its carrying value and such lowest market price. The cryptocurrency held for investment on Bitcoin Depot’s consolidated balance sheets during 2022 related solely to Ethereum. The cost basis of these investments in Ethereum was reduced by impairments…

The disclosure on page 323 has been updated in response to the Staff’s comment. Beneficial Ownership of Securities, page 358

The ADESA tradename has a book value of $122.8 million. The tradename continues to generate cash flows from our continuing operations and, pursuant to the purchase and commercial agreements with Carvana Group, LLC ("Carvana") and its affiliates, Carvana now pays a fee to the Company for use of the tradename for the ADESA U.S. physical auctions for a defined period. In addition, the Company expects to utilize the ADESA tradename to generate revenue and cash flows indefinitely from its remaining operations. As noted on page 69 of the 2021 Form 10-K, indefinite-lived tradenames are assessed for impairment, in accordance with ASC 350, annually in the second quarter or more frequently as impairment indicators arise. At the end of each assessment, a determination is made as to whether the tradenames still have an indefinite life. Following the sale of the ADESA U.S. physical auction business…

In response to the Staff’s comment, we have revised the pipeline tables in Amendment No. 17 to shorten the arrows for the Friederich’s Ataxia Phase II/III study and MCI/Early Alzheimer’s Disease Phase II study. If the Staff has any further comments regarding Amendment No. 17 to the registration statement on Form S-1, or any subsequent amendments to the Company’s registration statement on Form S-1, please feel free to contact the undersigned. Anthony L.G., PLLC By: /s/ Laura Anthony Laura Anthony, Esq. cc: Christie Wong/U.S. Securities and Exchange Commission Angela Connell/U.S. Securities and Exchange Commission Margaret Schwartz/U.S. Securities and Exchange Commission Christine Westbrook/U.S. Securities and Exchange Commission Christer Rosén/Jupiter Neurosciences, Inc. Craig D. Linder, Esq./Anthony L.G., PLLC 625 N. FLAGLER DRIVE, #600 ● WEST PALM BEACH, FLORIDA ● 33401 ● PHONE:…

We note the Staff’s comment, and in response thereto, respectfully advise the Staff that we added the risk factor “We may face several risks due to disruptions in the crypto asset markets, including but not limited to the risk from depreciation in our stock price, financing risk, risk of increased losses or impairments in our investments or other assets, risks of legal proceedings and government investigations, and risks from price declines or price volatility of crypto assets” on page 13 in the Amendment No. 1 to the Registration Statement.

The Company has revised its disclosure on pages 119, F-10, and F‑14 to address the Staff’s comments by disclosing the intangible impairment, including where the amount was recorded in the results of operations. * * * 2 Should you have any questions or comments concerning the Revised Registration Statement or this response letter, please contact Michael E. Mariani at 212-474-1007. Sincerely, /s/ Michael E. Mariani Michael E. Mariani Abby Adams Dorrie Yale Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 VIA EDGAR Copy to: Thibaut Mongon Kenvue Inc. 199 Grandview Road Skillman, NJ 08558 VIA E-MAIL 3