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CORRESP
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Celexus
Inc.

4695
Chabot Drive, Suite 200,

Pleasanton,
CA 94588

(702)
747-7305

VIA
E-MAIL

Division
of Corporation Finance

Office
of Healthcare & Insurance

United
States Securities and Exchange Commission

Washington,
D.C. 20549

Re:          Celexus,
Inc.

Amendment
No. 2 to Form 10-K for the Fiscal Year Ended March 31, 2019

Filed
March 12, 2020

Form
10-Q for the Fiscal Quarter Ended December 31, 2019

Filed
March 12, 2020

File
No. 000-52069

Dear
Ms. Etheredge:

This
letter sets forth the response of Celexus, Inc. (“CXUS” or the “Company”) to the Staff’s comment
letter dated April 5, 2020.

Form
10-Q for the Fiscal Quarter Ended December 31, 2019

Statement
of Changes in Stockholders’ Deficit, page 6

 1. We
                                         note your response to our prior comment 12. However, it appears that both your par value
                                         and authorized number of shares on pages 4 and 12 were not retroactively adjusted to
                                         account for the 1-90 reverse stock split. Furthermore, it is unclear why you adjusted
                                         the historical balance of your additional paid-in capital as of March 31, 2018 and March
                                         31, 2019 as a result of the stock split. Please revise your filing accordingly.

Response:
Par value and authorized number of shares of common stock has been retroactively adjusted to account for the 1-90 reverse stock
split. The historical balance of the additional paid-in capital as of March 31, 2018 and 2019 has been restored to its former
balances.

Notes
to Condensed Financial Statements

Note
1. Organization and Going Concern, page 8

 2. Please
                                         revise to correct inconsistencies in your disclosures about HempWave. Please clarify
                                         how the May 13, 2019 agreement is different than the February 2019 agreement which was
                                         later amended in July 2019. Furthermore, we note that on December 30, 2019, HempWave
                                         announced an intention to purchase a controlling interest in the Company. The press release
                                         included a quote from Ms. Averbuch in her role as President of Celexus regarding a “partnership”
                                         with HempWave. Please revise your disclosures here and in your MD&A on page 16 to
                                         address the current status of your planned acquisition of or by HempWave. Refer to ASC
                                         805-10-50 and ASC 855-10-50-2.

Response:
The Company has clarified the details of the amendments, the December 30, 2019, announcement and the current status of the acquisition
of HempWave.

 3. We
                                         note inconsistencies in your disclosure related to Mr. Soto and Ms. Averbuch’s
                                         current status as officers and directors of the Company. Please revise your disclosures
                                         accordingly.

Response:
The Company has clarified the disclosure as to Mr. Soto and Ms. Averbuch’s current status as officers and directors, accordingly.

If
you have any questions or require any additional information with respect to the above, please do not hesitate to contact me at
(702) 747-7305 or Andrew Coldicutt of the Law Office of Andrew Coldicutt at (619) 228-4970. Thank you for your attention to this
matter.

Celexus,
Inc.

/s/
Lisa Averbuch

Lisa
Averbuch,

Title:
CEO, CFO, Director

    cc:
    Robert
    Shapiro-Senior Staff Accountant

Lisa
Etheredge-Senior Staff Accountant

Gregory
Dundas-Attorney Advisor

Celeste
Murphy-Legal Branch Chief