United States securities and exchange commission logo October 31, 2022 Edward E. Jacobs, Jr. Chief Executive Officer Bioadaptives, Inc. 2620 Regatta Drive Suite 102 Las Vegas, NV 89128 Re: Bioadpatives, Inc. Amendment No. 1 to Post-Qualification Amendment No. 1 to Offering Statement on Form 1-A Filed October 28, 2022 File No. 024-11819 Dear Edward E. Jacobs: We have reviewed your amendment and have the following comment. Please respond to this letter by amending your offering statement and providing the requested information. If you do not believe our comment applies 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 this comment, we may have additional comments. Amendment No. 1 to Post-Qualification Amendment No. 1 to Offering Statement on Form 1-A Management's Discussion and Analysis of Financial Condition and Results of Operations, page 21 1. We note your revisions in response to prior comment 1 and reissue in part. Please revise this section to discuss your financial condition, changes in financial condition and results of operations for each period for which financial statements are required, including the causes of material changes from period to period in financial statement line items. Refer to Item 303(c) of Regulation S-K. We will consider qualifying your offering statement at your request. 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. Edward E. Jacobs, Jr. Bioadaptives, Inc. October 31, 2022 Page 2 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 Ada Sarmento at 202-551-3798 or Laura Crotty at 202-551-7614 with any questions. Sincerely, FirstName LastNameEdward E. Jacobs, Jr. Division of Corporation Finance Comapany NameBioadaptives, Inc. Office of Life Sciences October 31, 2022 Page 2 cc: J. Stephen Mills, Esq. FirstName LastName