SecProbe.io

CORRESP
 1
 filename1.htm

 Correspondence

 NEWLAN LAW FIRM, PLLC

 2201 Long Prairie Road, Suite 107-762

 Flower Mound, Texas 75022

 March 11, 2026

 Marion Graham

 Office of Technology

 Division of Corporation Finance

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 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 Ms. Graham:

 This is in response to the
letter of comment of the Staff dated March 5, 2026, relating to the captioned Post-Qualification Amendment No. 2 to the Offering Statement
on Form 1-A of Exousia Pro, Inc. (the "Company"). Each of the Staff's comments is addressed below, seriatim :

 Post Qualification Amendment No. 2 to Offering
Statement on Form 1-A

 Selling Shareholders, page 12

 Comment No. 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.

 Please be advised the subject disclosure has been
revised, in response to such comment, such that "fixed" has been inserted prior to "offering price" where appropriate.

 Comment No. 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."

 Please be advised the subject table has been revised, in response to
such comment.

 General

 Comment No. 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.

 Please be advised the pro forma financial information has been included
in the Post-Qualification Amendment No. 3 filing.

 Comment No. 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.

 As stated in the revised disclosure, the transaction with L A M Y did
not alter the Company's business. Rather, the Company believes that the transaction serves as an enhancement of its business objectives.
Also, an organization graphic has been added to the disclosure.

 _________________________________

 Please be advised that, with
respect to the selling shareholder disclosure, such disclosure has been updated to reflect the most recent disclosure standards, as discussed
by the Staff and the undersigned.

 Please be further advised
that, in light of recent discussions between the Staff and the undersigned, the Company confirms that it understands each of the provisions
of Rule 253(b), including the notes to such paragraph.

 _________________________________

 We believe that this filing
is now in order for qualification.

 Please feel free to contact
the undersigned at (940) 367-6154, should you have any questions regarding this letter or the Amendment.

 Thank you for your attention
in this matter.

 Sincerely,

 NEWLAN LAW FIRM, PLLC

 By: /s/ Eric Newlan

 Eric Newlan

 Managing Member

 cc: Exousia Pro, Inc.