ABEONA THERAPEUTICS INC

Securities Trading Arrangements of Directors and Executive Officers

During the fiscal quarter ended March 31, 2024, the following officers, as defined in Rule 16a-1(f) under the Exchange Act, as amended, adopted a “Rule 10b5-1 trading arrangement” as defined in Regulation S-K Item 408, as follows:

On February 9, 2024, Vishwas Seshadri, the Company’s President and Chief Executive Officer and a member of the Company’s board of directors, adopted a Rule 10b5-1 trading arrangement providing for the sale from time to time of an aggregate of (i) up to 20,000 shares of our common stock and (ii) up to (a) 100% of the shares of our common stock issued upon the settlement of 2,700 outstanding restricted stock units, (b) up to 21% of the shares of our common stock issued upon the settlement of 23,280 outstanding restricted stock units and (c) up to 30% of the shares of our common stock issued upon the settlement of 134,730 outstanding restricted stock units, in each case, less the number of shares traded to cover tax withholding obligations in connection with the vesting and settlement of such restricted stock units. The duration of the trading arrangement is until October 30, 2025, or earlier if all transactions under the trading arrangement are completed.

Joseph Vazzano, the Company’s Chief Financial Officer, adopted two Rule 10b5-1 trading arrangements on February 9, 2024 and February 12, 2024:

Each trading arrangement described is intended to satisfy the affirmative defense in Rule 10b5-1(c).