December 4, 2019

Don Bosch
Chief Executive Officer
Cocannco, Inc.
11 West Hampden Ave.
Suite L100
Englewood, CO 80110

       Re: Cocannco, Inc.
           Amendment No. 1 to Offering Statement on Form 1-A
           Filed November 22, 2019
           File No. 024-11098

Dear Mr. Bosch:

      We have reviewed your amended 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. Unless
we note
otherwise, our references to prior comments are to comments in our November 7,
2019 letter.

Amendment No. 1 to Offering Statement on Form 1-A filed November 22, 2019

Risk Factors, page 7

1.    We note your response to comment 4. We reissue the comment in part.
Please revise
      your risk factor discussion to disclose material risks to your business
as a result of your
      cannabis-related business plan, including regulatory risks, such as
possible consequences
      of law enforcement under federal and state laws related to the cannabis
industry. Refer to
      Item 3 of Part II of Form 1-A.
 Don Bosch
Cocannco, Inc.
December 4, 2019
Page 2
Plan of Distribution , page 13

2.       We note your response to comment 2, but it does not appear that you
have revised your
         offering circular in response to the comment. We reissue the comment.
We note the
         references throughout your offering circular to your company being a
"public company,"
         providing periodic reports to your investors under the Exchange Act,
and conducting this
         offering though a "direct public offering." Unless you plan on
registering your common
         stock pursuant to Section 12 of the Securities Exchange Act of 1934,
your company will
         have no continuing reporting obligation under the Exchange Act
following qualification of
         this Tier II Regulation A offering, and you should remove all
references to your company
         being a "public company" and conducting this offering as a "directed
public offering."
Part III - Exhibits
Exhibit 4 Sample Subscription Agreement, page 29

3.       We note that your Subscription Agreement includes an exclusive forum
provision. Please
         revise the disclosure in your offering circular to state, as you do in
the exhibit, that the
         provision does not apply to claims under the federal securities laws.
       You may contact Stephen Kim at 202-551-3291 or Doug Jones at
202-551-3309 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jacqueline Kaufman at 202-551-3797 or Jennifer L pez at 202-551-3792
with any other
questions.



FirstName LastNameDon Bosch                                    Sincerely,
Comapany NameCocannco, Inc.
                                                               Division of
Corporation Finance
December 4, 2019 Page 2                                        Office of Trade
& Services
FirstName LastName