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Acqusalut

Filed: 2 Jun 19, 8:00pm
                                                            June 3, 2019

I. Andrew Weeraratne
Chief Executive Officer
Acqusalut Inc.
7135 Collins Ave
No.624
Miami Beach, Florida 33141

       Re: Acqusalut Inc.
           Offering Statement on Form 1-A
           Filed May 7, 2019
           File No. 024-10996

Dear Mr. Weeraratne:

       We have reviewed your 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.

Offering Statement on Form 1-A filed May 7, 2019

No Escrow, page ii

1.    We note your disclosure that "the Company . . . in its sole discretion,
may issue the
      Securities under this Offering for cash, promissory notes, services,
and/or other
      consideration without notice to subscribers." Please, confirm through
additional
      disclosure that you will value any non-cash consideration according to
the Note to Rule
      251(a)(1) of Regulation A. In this regard, please clearly disclose that
the the aggregate
      offering price is based on the for-cash price and the valuation of any
non-cash
      consideration will be "reasonable at the time made."
 I. Andrew Weeraratne
Acqusalut Inc.
June 3, 2019
Page 2
Part III - Exhibits
Exhibit 4, page 29

2.       We note that paragraph 2 of Section IV of your subscription agreement
includes a
         mandatory arbitration provision. Please revise your subscription
agreement and offering
         circular to clearly disclose whether this provision applies to claims
arising pursuant to the
         U.S. federal securities laws and the rules and regulations promulgated
thereunder. Please
         also include disclosure in your filing describing this provision.
Provide related risk factor
         disclosure including, but not limited to, increased costs to bring a
claim, limited access to
         information and other imbalances of resources between the company and
shareholders,
         and that this provision can discourage claims or limit shareholders'
ability to bring a claim
         in a judicial forum that they find favorable.
3.       We note that Paragraph 1 of Section IV of your subscription agreement
includes an
         exclusive forum provision. Please discuss this provision of the
subscription agreement in
         the offering circular and specifically state whether this provision
applies to actions arising
         under the federal securities laws.
        We will consider qualifying your offering statement at your request. In
connection with
your request, please confirm in writing that at least one state has advised you
that it is prepared
to qualify or register your offering. If a participant in your offering is
required to clear its
compensation arrangements with FINRA, please have FINRA advise us that it has
no objections
to the compensation arrangements prior to qualification.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

      You may contact Katherine Bagley, Staff Attorney, at 202-551-2545 or
Jennifer L pez-
Molina, Staff Attorney, at 202-551-3792 with any questions.



FirstName LastNameI. Andrew Weeraratne                          Sincerely,
Comapany NameAcqusalut Inc.
                                                                Division of
Corporation Finance
June 3, 2019 Page 2                                             Office of
Consumer Products
FirstName LastName