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April 12, 2024

Jessica
Dickerson, Staff Attorney

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

100 F
Street, NE

Washington,
D.C. 20549

  Re:
  Sibannac, Inc.

Offering Statement on Form 1-A

Post-qualification Amendment No. 1

Filed February 2, 2024

File No. 024-12159

Dear Ms.
Dickerson:

We are in
receipt of your letter dated February 29, 2024, setting forth certain comments to the Offering Statement on Form 1-A which was filed
on February 2, 2024, by Sibannac, Inc., a Nevada corporation (the “Company”). In response to your comments, the Company can
provide you with the following information in response to your comments:

Post-qualification
Amendment No. 1 to Offering Statement on Form 1-A, filed February 2, 2024 Cover Page

 1. We note your statement that the offering will terminate on the
earlier of the date on which the maximum offering amount is sold or when you elect to terminate the offering for any reason. Please revise
your disclosure to clarify that the offering will terminate no later than the third anniversary of the initial qualification date of
the original offering statement, identifying that date. Refer to Rule 251(d)(3)(F) of Regulation A. Please make similar revisions to
the same disclosure on page 24. Additionally, please further revise the cover page to:

 • identify which disclosure format is being followed. Refer to
Part II(a)(1) of Form 1-A; and

 • include a cross reference to “Description of Securities.”
Refer to Part II, Item 1(d) of Form 1-A.

Response:
The Company has made the requested revisions.

Summary

Company
Information, page 2

 2. We note your disclosure on pages 3 and 33 that James Staudohar
resigned from all positions with the Company on July 15, 2022. Please clarify whether this includes his position as a director with the
Company and revise your disclosures throughout the offering statement as appropriate. In this regard, we note James Staudohar’s
signature as a director on the signature page of the offering statement, as well as your disclosure on page 51 that you have three directors.
However, this statement on pages 3 and 33 and other disclosures throughout the offering statement indicate that David Mersky and Booker
Evans, Jr. are your only two directors.

Response:
The Company has updated and clarified that there are only two directors and that Mr. Staudohar is a Former Director.

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 3. We note your disclosure on pages 3 and 33 that you agreed to issue
50,000,000 warrants to NOHO shareholders of record as of July 29, 2022 and that the warrants are redeemable no later than one year after
the registration statement to be filed by the buyer becomes effective. Please revise your disclosure to:

 • clarify whether these warrants have been issued;

 • describe your obligations, if any, to file a registration statement
in connection with these warrants and the related transaction with NOHO, Inc.; and

 • describe the material terms of the warrants and the redemption,
including whether you are obligated to redeem the warrants.

Please
also file the form of warrant as an exhibit to the offering statement. Refer to Part III, Item 17, paragraph 3 of Form 1-A.

Response:
As of this Offering the NOHO Warrants have not been issued and there is no obligation of the Company to file a Registration Statement
in connection with the NOHO Warrants. As the Company has not issued the NOHO Warrants there is no form of warrant and the material terms
of the NOHO Warrants have not been defined. If the Company does not file a Registration Statement then the Company is not obligated to
redeem the NOHO Warrants.

 4. We note your disclosure on pages 3 and 33 that, on March 28, 2023,
you entered into a share purchase agreement with Immersive Brand Concepts, Inc. pursuant to which you purchased 51% of Immersive’s
outstanding shares and that the agreement provides an opportunity for Immersive to earn back up to 21% of the shares you received in
the transaction. Please revise your disclosure to further explain the material terms of this agreement and your relationship with Immersive,
including to address the items highlighted below.

 • Reconcile your disclosure with the transaction described in the
share purchase agreement filed as Exhibit 6.4 to the offering statement. In this regard, the agreement indicates that it was the intention
of the parties that, upon closing, Immersive would become your 100% owned subsidiary and that you would assume ownership and title to
the assets of Immersive. However, you disclose that you only purchased 51% of Immersive’s outstanding shares.

 • If you did not acquire 100% of Immersive’s outstanding
shares, please clarify the number of Immersive’s outstanding preferred shares and the number of Immersive’s outstanding common
shares that you acquired. If you acquired preferred shares and common shares, please clarify which shares Immersive has the opportunity
to earn back.

 • Disclose the intended spin-out of Immersive shares and clarify
who will own the new entity referenced in Section 1.03 of the agreement.

 • Disclose the further earn-back of Immersive shares described
in Section 1.05 of the agreement.

In addition,
please clarify whether the proposed transaction contemplated by the offering statement violates the terms of the agreement. In this regard,
we note that Section 1.05 of the agreement provides that both parties agree that you cannot and will not issue any common stock for one
year.

Response:
The Company has updated its disclosure to reconcile the disclosure with the transaction. The portion of Section 1.05 that states both
parties agree that the Company will not issue any common stock for one year was an error and was meant to state that Immersive will not
issue any common stock for one year.

 5. We note your disclosure on pages 3 and 33 that you and two other
parties entered into an operating agreement for Curidol Holdings, LLC, which intends to, and is in the process of, developing a multifunctional
retail space used as a tea bar/retail shop. We further note related disclosure on pages F-10 and F-26 that you own 40% of Curidol. Please
revise your disclosure to identify the other two parties to the operating agreement. Please also file the agreement as an exhibit to
the offering statement or otherwise advise. Refer to Part III, Item 17, paragraph 6 of Form 1-A.

Response:
The Company has included the other two parties’ names and has filed the agreement as an exhibit.

 6. We note your disclosure in the penultimate paragraph on page 3
that you are committed to bringing your customers the highest-grade products on the market, accompanied by certificates of analysis following
testing from independently certified labs. We note similar disclosure on page 34. Please revise your disclosure to clarify what you mean
by “highest-grade products,” “certificates of analysis,” and “independently certified labs” and to
describe the type of testing that will be done on your products, including whether such testing will be done by you, third parties, or
a combination of the two now that you have your own manufacturing facility. In addition, please clarify whether you consider any of your
existing products to be of the “highest-grade products” and whether they are accompanied by certificates of analysis from
independently certified labs. Please also describe any testing of your existing products and the results of such tests.

Response:
The Company has further described the testing of products as requested.

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Risk
Factors

Risks
Relating to Our Financial Condition

Our management
has limited experience operating a public company . . . , page 7

 7. We note your references in this risk factor about being a “public
company.” We note similar references throughout the offering statement. For example, on page 9, you disclose that you expect to
incur substantial expenses to meet your reporting obligations as a public company and to maintain the proper management and financial
controls for your filings required as a public company. It appears that you will not have any continuing reporting obligations following
this Tier 1 Regulation A offering and that your references to being a public company with reporting obligations and controls required
for public companies are not appropriate. Please revise these references to remove any indication that you are a public company subject
to ongoing reporting obligations and public company controls and procedures.

Response:
The Company has removed the referenced statements.

Procedures
for Subscribing, page 24

 8. In the last paragraph on page 24, you discuss subscription funds
being transferred to an escrow account prior to your review and acceptance or rejection of any subscriptions. Given your other disclosures
in the offering statement that there will be no escrow account and your disclosure on page 25 that the funds will be deposited into the
Company’s bank account upon the approval of any subscription, please revise your disclosure to clarify where subscription funds
will be held prior to your review and your acceptance or rejection of the subscriptions.

Response:
The Company has removed the reference to using an escrow account.

Management's
Discussion and Analysis of Financial Condition and Results of Operations Plan of Operations for the Next Twelve Months, page 26

 9. We note your disclosure that you believe the proceeds of this
offering will satisfy your cash requirements for the next 12 months. Please clarify what percentage of the offering would need to be
subscribed for the proceeds to satisfy such cash requirements. Please also describe the level of operations that you will be able to
perform with your existing capital resources and liquidity.

Response:
The Company has updated the disclosure to describe the minimum percentage and what the operations would look like at that level of fundraising.

Business,
page 34

 10. Please revise your disclosures as appropriate to clarify the current
state of your business and operations. In this regard, we note your disclosures on page 34 and elsewhere in the offering statement that
you are in the business of developing, producing, marketing, and selling nutraceutical products, functional drink products, white label
products, and end consumer products. We further note your disclosures that you sell your products to numerous consumer markets and that
your products are recommended by physicians, therapists, chiropractors, and veterinarians and distributed by many of their offices. However,
you appear to have minimal sales revenues, making it unclear whether you are currently producing, marketing, and selling one, more, or
all of the products described in the offering statement. It is also unclear whether you are currently engaged, or plan to engage, in
any research and development efforts.

Response:
The Company updated its business and operations disclosures. The Company has also added that it only currently sells CBD Topical products,
and is now focused on the functional drink, Kratom and Kava markets. As well as restating that through its history it has sold to numerous
consumers markets.

 11. Please revise your offering statement as appropriate to ensure
that the description of your business includes a description of the business done and intended to be done by you and your subsidiaries.
In this regard:

 • We note from your August 22, 2023 press release that your subsidiary,
Immersive Brand Concepts, Inc., will be offering a white label contract and manufacturing service for select clientele and that it has
a manufacturing plant in Oklahoma. However, the offering statement does not discuss Immersive's products and services or otherwise attribute
any of the existing discussion about products and services to Immersive's business, nor does it include any discussion about the manufacturing
plant in Oklahoma City.

 • We note from your February 7, 2024 press release that you have
launched a new division, “The Campus Community, for the purpose of identifying revenue generating candidates ready to IPO on NASDAQ”,
that you “will act as the parent company and majority stakeholder in each IPO spin off”, and that you “will assist
all targets with filing a S-1 Registration to complete an IPO.” However, we do not see any discussion regarding these plans in
the offering statement.

Response:
The Company has included a discussion on Immersive and its services to the Company as well as included the information on the lease and
warehouse in Oklahoma City as requested.

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 12. We note your disclosure on page 34 that you have leased a retail
location in Old Town, Scottsdale and that the buildout of the space is currently underway as of the fourth quarter of 2021. Please update
this disclosure and clarify whether this retail location is, or is intended to be, the Curidol Holdings, LLC tea bar/retail shop discussed
on page 3 and/or page 38.

Response:
The Scottsdale space is going to be for the Curidol Holdings, LLC tea bar/retail shop and is named “The Kavern.”

Sibannac,
Inc. Products CBD - Cannabidiol, page 35

 13. We note your disclosure in the last sentence of this section that
you carry a full line of all- natural, hemp-based CBD solutions, including CBD oils, CBD gummies, CBD pills, CBD creams, and CBD gels
for topical options. Please confirm here whether any of your CBD solutions or products are considered food, beverages, or dietary supplements
or are otherwise subject to, or potentially in violation of, the Federal Food, Drug, and Cosmetic Act.

Response:
The Company has updated its disclosure to state that it currently only markets and produces non-food CBD products.

Marketing

Brand
Strategy and Marketing Overview Our Growth Strategy, page 36

 14. We note your growth strategy outlined on page 36. Given your disclosures
that you will require additional capital to implement your business plan, please disclose the order of precedence, if any, in which you
plan to pursue these growth strategies. Please also disclose the timeline and anticipated costs for pursuing each strategy, as well as
whether you intend to suspend any of your operations while you pursue a particular strategy. In this regard, we note your disclosure
in the “Management’s Discussion and Analysis of Financial Condition and Results of Operations” that 2023 revenues declined
due to your “focus on developing your Kratom operation and first retail location at the short-term cost of revenues from contract
manufacturing.”

Response:
The Company has responded on its growth strategy and means of implementing the specific strategies.

Functional
Drink Regulations, page 43

 15. We note your disclosure in the first paragraph that you believe
you are in compliance, in all material respects, with existing legislation and that, prior to the operation of your facility, you will
have all the required licenses to operate. Please provide similar disclosures, to the extent true, regarding your CBD products.

Response:
The Company has added the language as requested to the disclosures on CBD Regulations and that the Company believes that it is in compliance
with existing regulations.

Management,
page 45

 16. Please disclose when Eric Stoll and Booker T. Evans, Jr. began
serving as your Chief Marketing Officer and director, respectively. In addition, given your disclosure that your Chief Executive Officer
is your only full-time employee, please describe the arrangement pursuant to which you engage Eric Stoll as your Chief Marketing Officer.

Response:
The Company has disclosed the dates of appointment for the two individuals. Currently, Mr. Stoll is not compensated for his time spent
on the Company.

Principal
Stockholders, page 52

 17. Please confirm whether all of David Mersky’s shares are
included in the table. In this regard, we note the table shows that David Mersky owns Series A Preferred Stock only. However, we note
disclosure on