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 March 5, 2026

Matthew Dwyer
Chief Executive Officer
Exousia Pro, Inc.
7901 4th Street N #23494
St. Petersburg, Florida 33702

 Re: Exousia Pro, Inc.
 Post-Qualification Amendment No. 2 to Offering Statement on Form
1-A
 Filed February 19, 2026
 File No. 024-12629
Dear Matthew Dwyer:

 We have reviewed your amendment 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.

Post Qualification Amendment No. 2 to Offering Statement on Form 1-A
Selling Shareholders, page 12

1. We note your disclosure that your selling shareholders intend to sell
the Remaining
 Selling Shareholder Offered Shares in market transactions or in
negotiated private
 transactions at the per share offering price for all of the Offered
Shares. Please revise to
 clarify that the selling security holders will sell their shares
pursuant to your Regulation
 A offering at a fixed price. At the market offerings are not permitted
under Regulation A.
 Refer to Rule 251(d)(3)(ii) of Regulation A.
2. Please revise the table and/or related footnotes to reflect the
11,329,431 shares being
 offered for resale as the Remaining Selling Shareholder Offered
Shares.
General

3. Please include pro forma financial information pursuant to Part F/S,
Section (b)(7)(iv) to
 reflect the transaction with L A M Y, or provide us an analysis
supporting why they are
 not required.
 March 5, 2026
Page 2

4. Please disclose whether your acquisition of L A M Y will change your
business
 operations. If so, provide additional information about your business
operations and
 ensure that the cover page includes complete information as to your
 current business operations. Please refer to Part II, Item 1 and Item 7
of Form 1-A.
 Additionally, please include an organizational chart detailing your
structure prior to the
 acquisition and an organizational chart reflecting your structure after
the consummation
 of the acquisition.
 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.

 Please contact Marion Graham at 202-551-6521 or Jan Woo at 202-551-3453
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Eric Newlan
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