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                              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