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June 5, 2024
Larry Powalisz
Chief Executive Officer
Adia Nutrition, Inc.
4421 Gabriella Lane
Winter Park, Florida 32792
Re:Adia Nutrition, Inc.
Amendment No. 2 to Offering Statement on Form 1-A
Filed May 24, 2024
File No. 024-12427
Dear Larry Powalisz:
            We have reviewed your amended offering statement and have the following comments.
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a 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 letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our May 16, 2024 letter.
Amendment No. 2 to Offering Statement on Form 1-A
Offering Summary, page 3
1.We note your response to comment 6, including the removal of "Inventory" from the Use
of Proceeds section. We continue to note your disclosure here, and elsewhere, that you
will apply the proceeds of this offering to "build [y]our inventory levels." Please advise or
revise.
Business Plan
Growth and Expansion, page 19
2.We note your response to comment 14 and we note your disclosure that "[i]n the long
term, [you] intend to explore opportunities to expand [y]our market reach and geographic
presence by entering new regions and establishing partnerships with healthcare providers
and distributors worldwide." We re-issue our comment in part. Please provide further
details regarding the applicable international regulatory landscape for your intended

 FirstName LastNameLarry Powalisz
 Comapany NameAdia Nutrition, Inc.
 June 5, 2024 Page 2
 FirstName LastName
Larry Powalisz
Adia Nutrition, Inc.
June 5, 2024
Page 2
geographic expansion worldwide, or otherwise advise.
Plan of Business, page 19
3.We note your response to comment 16 and re-issue. We note your disclosure that you
“anticipate” beginning to generate revenues over the next twelve months. Please revise to
clarify, if true, that this is a goal, or otherwise advise.
Regulatory Considerations, page 20
4.We note your response to comment 11, including that the autologous hematopoietic stem
cell transplants and natural supplements do not require FDA approval, and that you will
not be required to submit a premarket safety notification to the FDA with respect to the
nutritional supplements. Please expand your disclosure to clarify whether you will be
subject to manufacturing, labeling, or marketing regulations, including non-FDA
regulations, or otherwise advise.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Background, page 21
5.We note your response to comment 10, including your disclosure that you assigned the
ownership of Hydration Foundation, Inc. to Mr. Greene on January 22, 2024. With respect
to the reference to your sole subsidiary on page 1 and your current subsidiary on page 8,
please clarify whether Hydration Foundation, Inc. is a current subsidiary of your
company.
            Please contact Eric Atallah at 202-551-3663 or Kevin Vaughn at 202-551-3494 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jimmy McNamara at 202-551-7349 or Joshua Gorsky at 202-551-7836 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Eric Newlan