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October 28, 2021

Glenn Sandgren
Chief Executive Officer
IKONICS Corp.
4832 Grand Avenue
Duluth, MN 55807

Re: IKONICS Corp.
Amendment No. 4 to
Registration Statement on Form S-4
Filed October 12,
2021
File No. 333-258335

Dear Mr. Sandgren:

We have reviewed your amended registration 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 registration
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 registration 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
October 6, 2021 letter.

Amendment No. 4 to Registration Statement on Form S-4

The Mergers, page 12

1. We note your response
to prior comment 8. Please revise to add a section addressing all
conflicts of interest
of the executive officers and directors of the HoldCo
("Terawulf") after the
business combination. As part of your disclosure, include a
discussion of any other
companies to which the officers or directors will have a fiduciary
duty. Finally, disclose
that Mr. Prager may have financial interests that are not aligned
with the shareholders
of the combined entity.
Unaudited Pro Forma Condensed Combined Financial Information, page 25

2. We continue to evaluate
your response to prior comment 2 and may have further
Glenn Sandgren
IKONICS Corp.
October 28, 2021
Page 2
comments.
Background to the Mergers, page 55

3. We note your response to prior comment 4 that each of the potential
targets initially
contacted IKONICS directly but your disclosure indicates that a
therapeutic biotech
company and a cell therapy biotechnology company were "introduced to
IKONICS
through a third-party representative" in February 2021. Please disclose
the third-party
representatives who were involved in
Management's Discussion and Analysis of TeraWulf's Financial Condition and
Results of
Operations of TeraWulf
Limited History; Need for Additional Capital, page 137

4. We continue to evaluate your response to prior comment 9 and may have
further
comments.
You may contact Morgan Youngwood, Senior Staff Accountant, at (202)
551-3479 or
Stephen Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have
questions regarding
comments on the financial statements and related matters. Please contact
Matthew Derby, Staff
Attorney, at (202) 551-3334 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other
questions.



Sincerely,
FirstName LastNameGlenn Sandgren
Division of
Corporation Finance
Comapany NameIKONICS Corp.
Office of Technology
October 28, 2021 Page 2
cc: W. Jason Deppen
FirstName LastName