SecProbe.io

April 5, 2018

Via E -mail
Jonathan Cohen
Chief Executive Officer
20/20 GeneSystems, Inc.
9430 Key West Ave.
Rockville, MD 20850

Re: 20/20 GeneSystems, Inc.
Offering Statement  on Form 1-A
Filed  March 9, 2018
  File No. 024-10816

Dear Mr. Cohen :

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.

Risk Factors, page 6

1. We note the discussion on page 17 regarding different options for ong oing reporting.
Please revise where appropriate to clarify your reporting if your shares become quoted on
the OTCQB.

Description of Business , page 25

2. We note the statement that you believe Paula’s Test is the “first combinatorial blood test
… that incorporates a machine learning algorithm.”  We also note the statement that “no
marketed product currently competes with our proposed OneTest multi (pan) can cer test.”
Please revise to clearly differentiate how your current and pending tests differ from ones
provided by other companies.  For example, it appears that some public companies
currently offer tests using machine learning and algorithms, and some te sts appear to
screen for multiple types of cancer.

Jonathan Cohen
20/20 GeneSystems, Inc.
 April 5, 2018
 Page 2

 Our Commercial Approach, page 29

3. We note statements that you “expect to eventually” make your products available to large
national clinical laboratory testing chains such as LabCorp or Quest Diagnostics.   Please
clarify the expected timeline for any existing or planned arrangements with such third
parties to the extent material.  Please also revise to clarify the status of your tests.  For
example, the first paragraph on page 1 suggests that your products  currently include
OneTest; however, you state on page 28 that OneTest is “late stage” without providing an
approximate timeline for commercialization.  You also (1) refer to BioCheck as a
“legacy” product without explaining the extent to which it is expec ted to generate more
than de minimis revenues and (2) refer to “Lung Cancer Detection (China)” on page 28
without providing an approximate timeline for commercialization.

Management’s Discussion and Analysis of Financial Condition and Results of Operati ons, page
33

4. We note that you do not expect to have a predictable revenue stream in the near future
and that you recently transitioned to a “potentially more profitable self -pay model.”  We
also note the statement that you have “payment obligations and ob ligations to pursue
development and commercialization of diagnostic tests.”  Please revise  to address these
topics to the  extent they  represent  trends, demands, commitments or events that are
reasonably likely to have a material effect on your net sales or revenues.  In this reg ard, if
material, please address period -to-period changes to the average selling price of Paula’s
test, which you state on page 3 is about $149.  Refer to Item 9(d) of Part II of Form 1 -A.

5. We note your disclosure related to your sources of revenue.  We al so note that your
website states that BioCheck “generates revenues of about $500,000 per year with Gross
Profit margins of about 80%.”  It also states that the company “has brought in
approximately $7.5 million in grant funding.”  Please advise us how thes e statements
reconcile with the disclosure in the Form 1 -A, and, as necessary, enhance your disclosure
to more specifically address how the company earns revenue from grants and sales of
BioCheck and other services.

Compensation of Directors and Executive Officers, page 42

6. We note your disclosure that certain directors are awarded options that vest over time.
Please revise this section to provide all information required by Item 11(d) of Form 1 -A.

Interest of Mana gement and Others in Certain Transactions, page 44

7. We note your disclosure on page F -12 regarding various Investment LLCs and
arrangements with immediate family members of the CEO.  Please revise this section to
provide all information required by Item 13  of Form 1 -A and file any related agreements.

Jonathan Cohen
20/20 GeneSystems, Inc.
 April 5, 2018
 Page 3

 Part III - Exhibits

8. Please file the escrow agreement as an exhibit to the offering statement.  Refer to Item
17(8) in Part III of Form 1 -A.

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.

 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.   We also remind you that, following qualification of your F orm 1 -A, Rule 257
of Regulation  A requires you to file periodic and current reports , including a Form 1 -K which
will be  due within 120 calendar days after the end of the fiscal year covered by the report .

You may contact Linda Cvrkel at (202) 551 -3813  or Rufus Decker , Accounting Branch
Chief,  at (202) 551 -3769  if you have questions regarding comments on the financial statements
and re lated matters.  Please contact Hillary Daniels at (202) 551 -3959  or James Lopez, Legal
Branch Chief, at (202) 551 -3536  with any other questions.

Sincerely,

 /s/ James Lopez (for)

John Reynolds
Assistant Director
Office of Beverages, Apparel, and
Mining

cc: Louis A. Bevilacqua, Esq.
Bevilacqua PLLC