HSDTSolana Company

Please amend your filing to include an audit report that is signed by your independent registered public accountant as required by Article 2 of Regulation S-X. Refer to Item 302(a) of Regulation S-T which provides guidance on including signatures in electronic filings. The amendment should also include currently dated Section 302 and 906 certifications that reference the amended Form 10-K.

No reply letter found.

We note that you intend to use the proceeds from warrant exercises for various enumerated purposes. Please disclose whether the proceeds are expected to be sufficient to complete clinical trials and/or other enumerated uses necessary to reach commercialization of your products.

Rest of the question

If they are not expected to be sufficient, please prioritize the enumerated uses and discuss how much additional capital you will need to complete those steps toward commercial readiness.

The Company has revised the disclosure on page 34 in response to the Staff’s comment. Read in the reply ↗

It appears that Messers Deschampes and Sackier may have beneficial ownership of the shares held by MPJ Healthcare, LLC. Revise the table accordingly or advise.

The Company has revised the disclosure on page 82 in response to the Staff’s comment. Read in the reply ↗

Refer to footnote (11). Clarify whether you know the identities of the natural persons who have control over the A&B entities.

The Company has revised the disclosure in footnote 11 on page 83 in response to the Staff’s comment to disclose that Dr. Lam Kong is the sole director and officer of each of A&B (HK) Company Limited and A&B Brother Limited. We respectfully advise the Staff that the disclosure in footnote 11 on page 83 is based entirely upon information in a Schedule 13D filed on March 4, 2016, by A&B

(HK) Company Limited, A&B Brother Limited, and Dr. Lam Kong. Read in the reply ↗

We note that counsel limits its opinion to the laws of the State of Wyoming, but that the warrants are governed by the laws of British Columbia. Please file an opinion of counsel that the warrants are binding obligations under the laws of British Columbia.

The Company acknowledges the Staff’s comment and has filed an opinion of Blake, Cassels

& Graydon LLP that the warrants are binding obligations of the Company under the laws of British Columbia, as Exhibit 5.2 to Amendment No. 1. Read in the reply ↗

We have reviewed your response to prior comment 3. We continue to note, however, that your first full risk factor on page 33 discloses that you have two officers who serve on a full-time basis but that “[a]ll other officers and employees only provide services to [you] on a part-time, limited basis.” Please revise your risk factor disclosure and your disclosure in this section so that they reconcile.

The Company has revised the disclosure in response to the staff’s comment. Please see pages 23 and 33 of the

Amended Registration Statement. Read in the reply ↗

Given your disclosure on the cover page of your Form 10 that you are not a smaller reporting company, please provide the disclosures required by Regulation S-K Item 303(a)(5).

The Company advises the staff that it does not have any of the obligations required to be disclosed by Item 303(a)(5) of Regulation S-K. Please see page 48 of the Amended Registration Statement

Fiscal Quarter Ended December 31, Read in the reply ↗

We note the variances in your net losses for the periods presented. Under a separate caption, please expand your disclosure to clearly explain to investors the reasons for the variances in your net losses for the periods presented. Also disclose any known material trends affecting your net losses for the periods presented. Refer to Item 303(b) of Regulation S-K.

in response to the staff’s comment. Please see pages 43 and 44 of the Amended

Registration Statement. Read in the reply ↗

Given your disclosure on the cover page of your Form 10 that you are not a smaller reporting company, please tell us how your reference to “one percent of the average of our total assets” in the first paragraph complies with Regulation S-K Item 404(a) or revise accordingly.

in response to the staff’s comment. Please see page 58 of the Amended

We hereby acknowledge that:

• the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Read in the reply ↗

Please note that this filing will become effective automatically 60 days after the date you initially filed it. If this filing was made voluntarily, you should consider withdrawing it prior to the effective date if comments remain outstanding. You could then refile when you are prepared to resolve the comments.

Rest of the question

Please tell us whether you intend to file a request for withdrawal before the automatic effectiveness date of this registration statement if comments remain outstanding.

The Company has withdrawn the Initial Registration Statement.

Division of Corporation Finance

U.S. Read in the reply ↗

We note your disclosure on page 19 that your overall goal for submission of the de novo application and FDA clearance is 18 m onths from December 2014. Please revise to your disclosure to clarify whether you have submitted your application or what steps you need to take in order to submit that application .

The Company has revised its disclosure in response to the staff’s comment. Please see page 19 of the Registration Statement. Read in the reply ↗

Please reconcile your disclosure here that you have three full-time employees with your disclosure in the first full risk factor on page 33 which indicates that you only have two employees serving on a full-time basis.

The Company advises the staff that it has three full-time employees, including two full-time officers and one full-time employee who is not an officer. The risk factor on page 33 refers to the two full-time officers, while the disclosure on page 23 refers to all three full-time employees (including the two full-time officers). Read in the reply ↗

Please clarify the reference to “the expected proceeds from this offering.”

The Company has removed the reference to “the expected proceeds from this offering.” Please see page 25 of the

Registration Statement. Read in the reply ↗

Please indicate how many shares of common stock are issuable under your outstanding warrants.

No numbered answer found in the reply. Read the reply ↗

We note from your disclosure in footnote 5 on page 89 that you also have 28,863,048 shares of common stock held in escrow and that all of the common stock in escrow will be released at a rate of 15% every six months. Please also discl ose the shares held in escrow in this section and how and when the escrowed shares were issued and the arrangements governing the release of those shares from escrow.

Rest of the question

Please also make sure that your disclosure under Item 10 addresses the issuances of thos e securities.

in response to the staff’s comment. Please see pages 51, 62 and 63 of the Read in the reply ↗

In light of the consulting agreements referenced on page 58, please clarify how you determined that Messrs. Danilov and Tyler are “independent.”

The Company has revised the disclosure to clarify the Messrs. Danilov and Tyler are not independent. Please see page 59 of the Registration Statement.

We hereby acknowledge that:

the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Read in the reply ↗