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   PO Box 281077

 Nashville, TN 37228

 315 Deadrick Street

 Nashville, TN 37203

 615-476-1151

 Steve@SteveMillslaw.com

 November 29, 2022

 Securities and Exchange Commission

 Division of Corporate Finance

 Office of Trade and Services

 Washington, DC 20549

 Dear Sir or Madam:

 We are submitting this letter on behalf of Universal Systems, Inc. (“UVSS” or “the Company”) in response to comments from the staff (“Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter on October 5, 2022, relating to the Company’s Registration Statement filed on August 18, 2022 and amended on September 12, 2022 with the file number 024-11969. The numbered paragraphs below correspond to the numbered comments in the Staff’s letter. We are including as an attachment to this letter a copy of the Registration Statement that has been marked to show changes from the Registration Statement as originally filed.

 Comment 1.

 Amendment No. 1 to Offering Statement on Form 1-A filed September 12, 2022. We note that in response to comment 1 you have revised your disclosure to remove references to investing and now state that you intend to engage in film development and production, and may create joint ventures to further the potential of revenues through acquisitions and partnerships. However, we note press releases issued by the company indicating that it is currently involved in, or has entered into agreements related to, various projects. The press releases suggest that the company is actively involved in production and film development through a platform known as SeeMyNFT, the launch of an event ticketing system, posting articles on a site known as TheDailyCrypto.io, consulting with metaverse technology companies, co-production of a feature film called “Man in the White Van,” and allowing clients to mint and place NFTs on a proprietary marketplace. Please revise your Form 1-A to provide a materially complete description of the status of your business and describe the principal products and services you offer, as well as a description of all ongoing or contemplated material projects. Please describe your precise role in such projects, how you are or plan to generate revenue from such projects, your material obligations, and material investments you have made or will be required to make to support such projects. Please also explain what it means that you are developing a “library of assets that provides a 15–20-year stream of royalties,” as stated in your press releases. Please file any material contracts related to such projects or joint ventures as exhibits to the Form 1-A.

  1

 Amended Version:

 The Company’s purpose is to develop, produce, create and distribute a library of digital media costing from $50,000 to $5 million dollars for the entertainment and sports marketplace. We expect to use all the proceeds from this offering in the development and production of this media content to include motion pictures and television network industries. We may also create joint ventures to further the potential of revenues through acquisitions and partnerships.

 On page 5, we have amended the filing and replaced as follows:

 Current Version:

 “On September 21st, 2021, Universal Systems, Inc., filed an amendment with the State of Washington, pursuant to Washington CORP § 307 for the creation of 100 shares of Special 2021 Series A Preferred stock shares, and 2 shares of Special 2021 Series B Preferred stock shares. The Special 2021 Series B Preferred shares are only authorized, have not been issued, and are not currently outstanding.

 The Company’s purpose is to develop, produce, create and distribute a library of digital media costing from $50,000 to $5 million dollars for the entertainment and sports marketplace. We expect to use substantially all the proceeds from this offering in the development and production of this media content to include motion pictures and television network industries. We may also create joint ventures to further the potential of revenues through acquisitions and partnerships.”

 Amended version:

 “On September 21st, 2021, Universal Systems, Inc., filed an amendment with the State of Washington, pursuant to Washington CORP § 307 for the creation of 100 shares of Special 2021 Series A Preferred stock shares, and 2 shares of Special 2021 Series B Preferred stock shares.

  2

 The Company’s purpose is to create, develop, and produce a library of digital media assets (film, video, music, motion graphics, and artwork) costing from $50,000 to $5 million dollars for the entertainment, sports, healthcare, and publishing industries. The digital media assets can be distributed via traditional distribution channels i.e., movie theatres, cable tv, satellite tv, radio, websites and/or the digital media assets are developed and distributed for metaverses, and web3 content channels. The company also provides consulting and digital production services for companies and projects that wish to convert existing content distribution businesses into Web 3 business models of which the Company’s services may include artwork for NFTs, film/video content appropriate for Web3 use, and music production to create Digital Media Experiences that complement, inform, and/or entertain within traditional websites or metaverses. We expect to use all the proceeds from this offering in the development and production of this media content to include motion pictures, musical soundtracks and productions, motion graphics, website development, and artwork. The company also owns and operates www.TheDailyCrypto.io, an online website with daily updates of the blockchain, metaverse, crypto, and regulatory headlines combined with the updates of music, film, sports, and financial markets as these markets are experiencing transformation as the result of the integration of various blockchains and metaverse opportunities.

 The Company is focused to being a premium creator of digital content that can be used in traditional or advanced web3 distribution channels. We rely on our technology partners to implement, create, and program the technology that distributes the content and media that we develop. We may also create joint ventures to further the potential of revenues through acquisitions and partnerships.”

 On page 6, we have amended the filing and replaced as follows:

 Current version:

 The Company’s purpose is to develop, produce, create and distribute a library of digital media costing from $50,000 to $5 million dollars for the entertainment and sports marketplace. We expect to use substantially all the proceeds from this offering in the development and production of this media content to include motion pictures and television network industries. We may also create joint ventures to further the potential of revenues through acquisitions and partnerships.

  3

 Amended version:

 “The Company’s purpose is to create, develop, and produce a library of digital media assets (film, video, music, motion graphics, and artwork) costing from $50,000 to $5 million dollars for the entertainment, sports, healthcare, and publishing industries. The digital media assets can be distributed via traditional distribution channels i.e., movie theatres, cable tv, satellite tv, radio, websites and/or the digital media assets are developed and distributed for metaverses, web3 content channels. The company also provides services for companies and projects convert existing content distribution businesses into Web 3 business models of which the Company’s services may include artwork for NFTs, film/video content appropriate for Web3 use, and music production to create Digital Media Experiences that complement, inform, and/or entertain within traditional websites or metaverses. We expect to use all the proceeds from this offering in the development and production of this media content to include film, video, musical soundtracks and productions, motion graphics, website development, and artwork.

 The company also owns and operates www.TheDailyCrypto.io, an online website with daily updates of the blockchain, metaverse, crypto, and regulatory headlines combined with the updates of music, film, sports, and financial markets as these markets are experiencing transformation as the result of the integration of various blockchains and metaverse opportunities.

 The Company is focused to being a premium creator of digital content i.e., film, video, music that can be used in traditional or advanced web3 distribution channels. The Company is a content developer, and we rely on our technology partners to implement, create, and program the technology that distributes the content. We may also create joint ventures to further the potential of revenues through acquisitions and partnerships.”

 On page 11, we have amended the filing and replaced as follows:

 Current version:

 Our success depends on external factors in the motion picture and television industry.

  Generally, the popularity of our content depends on many factors, including the critical acclaim they receive, the format of their initial release, their talent, their genre and their specific subject matter, audience reaction, the quality and acceptance of content that our competitors release into the marketplace at or near the same time, critical reviews, the availability of alternative forms of entertainment and leisure activities, general economic conditions and other tangible and intangible factors, many of which we do not control and all of which may change. In addition, because a performance in ancillary markets, such as home video and pay and free television, is often directly related to its box office performance or television ratings, poor box office results or poor television ratings may negatively affect future revenue streams. Our success will depend on the experience and judgment of our management to select and develop new production opportunities.

  4

 We compete with other programming services, including cable programming, national broadcast television, local broadcast television stations and digital services to secure desired programming, the competition for which has increased as the number of programming services has increased. Increased competition may drive up talent and production costs and may force some programming services to commit to straight-to-series orders for programming instead of a pilot order. If we commit to straight-to-series orders and those series do not meet anticipated production or quality standards or are otherwise not accepted by audiences, revisions to the programming may be necessary, which could increase production costs. The increased financial commitment for a straight-to-series order also could increase the risks associated with such an order. Other programming services that are affiliated with programming sources such as movie or television studios or film libraries may have a competitive advantage over us in this area. Some of these competitors have exclusive contracts with motion picture studios or independent motion picture distributors or own film libraries.

 Amended Version:

 Our success depends on external factors in the motion picture, television, and music industry.

  Generally, the popularity of our content depends on many factors, including the critical acclaim they receive, the format of their initial release, their talent, their genre and their specific subject matter, audience reaction, the quality and acceptance of content that our competitors release into the marketplace at or near the same time, critical reviews, the availability of alternative forms of entertainment and leisure activities, general economic conditions and other tangible and intangible factors, many of which we do not control and all of which may change. In addition, because a performance in ancillary markets, such as home video and pay and free television, is often related to its box office performance or television ratings, poor box office results or poor television ratings may negatively affect future revenue streams. Our success will depend on the experience and judgment of our management to select and develop new production opportunities.

 We compete with other programming services, including cable programming, national broadcast television, local broadcast television stations and digital music services to secure desired programming, the competition for which has increased as the number of programming services has increased. Increased competition may drive up talent and production costs and may force some programming services to commit to straight-to-series orders for programming instead of a pilot order. If we commit to straight-to-series orders and those series do not meet anticipated production or quality standards or are otherwise not accepted by audiences, revisions to the programming may be necessary, which could increase production costs. The increased financial commitment for a straight-to-series order or music production also could increase the risks associated with such an order. Other programming services that are affiliated with programming sources such as movie or television studios or film libraries may have a competitive advantage over us in this area. Some of these competitors have exclusive contracts with motion picture studios or independent motion picture distributors or own films, music libraries, and musical scores.

  5

 On page 13, we have amended the filing and replaced as follows:

 Current version:

 Piracy of films and television programs could adversely affect our business over time.

 Piracy is extensive in many parts of the world and is made easier by the availability of digital copies of content and technological advances allowing conversion of films and television content into digital formats. This trend facilitates the creation, transmission and sharing of high-quality unauthorized copies of motion pictures and television content. The proliferation of unauthorized copies of these products has had and will likely continue to have an adverse effect on our business, because these products reduce the revenue we receive from our products. To contain this problem, we may have to implement elaborate and costly security and anti-piracy measures, which could result in significant expenses and losses of revenue. We cannot assure you that even the highest levels of security and anti-piracy measures will prevent piracy.

 Amended version:

 Piracy of films, television programs, and music could adversely affect our business over time.

 Piracy is extensive in many parts of the world and is made easier by the availability of digital copies of content and technological advances allowing conversion of films, television content, and music into digital formats. This trend facilitates the creation, transmission and sharing of high-quality unauthorized copies of motion pictures, television, and music content. The proliferation of unauthorized copies of these products has had and will continue to have an adverse effect on our business, because these products reduce the revenue we receive from our products. To contain this problem, we may have to implement elaborate and costly security and anti-piracy measures, which could result in significant expenses and losses of revenue. We cannot assure you that even the highest levels of security and anti-piracy measures will prevent piracy.

  6

 On page 15, we have amended the filing and replaced as follows:

 Current Version:

 Because the motion picture industry is highly speculative and inherently risky, our motion picture may not be commercially successful, in which case we will not be able to recover our costs or realize anticipated profits.

 The motion picture industry is highly speculative and inherently risky. We cannot assure you that any motion picture we release, distribute, license, acquire or produce will be successful since th