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Ilustrato Pictures International, Inc.

26 Broadway, Suite
934

New York, NY 10004

Via EDGAR

December 13, 2023

United States Securities and Exchange Commission

100 F Street, N.E. Mailstop 3720

Washington D.C., 20549-7010

Attention: Thomas Jones

 Re: Ilustrato Pictures International, Inc.

Amendment No. 5 to Registration Statement on Form
10-12G

Filed September 12, 2023

File No. 000-56487

Dear Mr. Jones:

I write on behalf of Ilustrato Pictures International,
Inc. (the “Company”) in response to Staff’s letter of September 27, 2023, by the Division of Corporation Finance of
the United States Securities and Exchange Commission (the “Commission”) regarding the above-referenced Amendment No. 5 to
Registration Statement on Form 10-12G, filed September 12, 2023 (the Comment Letter”).

Paragraph numbering used for each response corresponds
to the numbering used in the Comment letter.

Amendment No. 5 to Registration
Statement on Form 10-12G filed September 12, 2023

Business Overview, page 1

 1. We note the disclosure about your focus on acquisitions of
businesses and your July 21, 2023, press release and your plans to spin out the Quality Industrial Corporation and Emergency Response
Technologies subsidiaries and to pay special equity dividends to shareholders of Ilustrato. Please provide us your analysis as to why
you would not be an investment company under the Investment Company Act of 1940. Also, please provide us your analysis as to how your
acquisition strategy will not cause you to be an investment company under the Investment Company Act of 1940.

In response to this comment. The Company is not an issuer which is
or holds itself out as being engaged primarily, or proposes to engage primarily, in the business of investing, reinvesting, or trading
in securities. On the contrary, ILUS has acquired and maintains control of its subsidiaries and is actively engaged in the operating businesses,
providing strategic guidance and support to enable their growth. Further ILUS provides access to financial and managerial resources to
aid in the expansion of the operating businesses, with the purpose of increasing long term growth and value add for ILUS shareholders.

Legal Proceedings, page 28

 2. Please clarify the new disclosure concerning “the amount of $3.772 million for the historic note
with a principal amount of $4,000.”

In response to this commen, the Company amended the registration statement
to clarify the legal proceeding with Black Ice Advisors LLC, regarding a historic note entered into by the previous CEO, Larson Elmore,
with a principal amount of $4,000. The company disputes the legitimacy of the note and as to whether ILUS ever actually received the $4,000.
At a hearing on November 3, 2023, the Court adopted its tentative ruling as the final ruling and denied the motion for summary judgement
from Black Ice Advisors LLC. The case has received a trial date for March 8, 2024.

Risk Factors, page 31

 3. Please include a risk factor to disclose the extent to which you have not been able to service your debt
obligations as requested in prior comment 3. Also tell us, with a view to disclosure, the status of the (1) convertible note with AJB
Capital Investment LLC in the amount of $1,200,000 that matured on June 1, 2023, mentioned on page 83; and (2) convertible note with Jefferson Street Capital
in the amount of $100,000 that matured on July 26, 2023, mentioned on page 83.

In response to this comment, the company made an exchange note with
AJB Capital on October 23, 2023, of 1,450,000 maturing on May 1, 2024 and this has been filed as an exhibit. The Jefferson Street Capital
note in the amount of $100,000 has been partially converted. The company amended the risk factor on page 34 to include the notes.

Our ability to generate the significant amount of cash,
page 32

 4. We note your response to prior comment 4. Please tell us with specificity where the guarantee mentioned
in the second paragraph on page 32 has been filed as an exhibit.

In response to this comment, the Shareholder Guarantee for the legacy
assets in accounts receivables has been filed as an exhibit to this registration statement.

Certain of our officers and directors have other business
pursuits, page 45

 5. Please disclose the extent to which Nicolas Link has voting control over Dear Cashmere Holding Co. and
CGrowth Capital, Inc. as requested in the last sentence of prior comment 8.

In response to this comment, the company disclosed that Nicolas Link
has voting control over CGrowth Capital, Inc. Nicolas Link does not have the voting control in Dear Cashmere Holding Co.

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Industrial & Manufacturing Division, page 56

 6. Please reconcile the disclosure in this section that the funding obligations for acquisitions such as
Quality International Co Ltd FCZ, “are currently funded by QIND itself as are the ongoing obligations for future acquisitions by
the subsidiary” with the disclosure in your Form 8-K filed on August 25, 2023, about the Subscription Buy-Back Agreement and the
Guarantee & Indemnity Agreement. In this regard, we note the disclosure in the Form 8- K that you are a guarantor.

In response to this comment, the company is a guarantor along with
QIND and the other shareholders of Quality International. QIND however pays the interest and intends to repay the full amount, as per
the Agreement. Once fully repaid the issued shares will be returned to treasury, as per the Agreement.

Management’s Discussion and Analysis of Financial Condition
and Results of Operations Recent Developments and Plan of Operations, page 57

 7. We note your disclosures regarding the change in the status of the production of electric vehicles in
Serbia on pages 37 and 52. Please update your discussions of your operations in Serbia in this section to provide consistent information.

In response to this comment, the company updated its disclosures to
provide consistency regarding production of electric vehicles in Serbia.

Report of Independent Registered Public Accounting Firm,
page F-1

 8. We note your response to comment 16 and the revisions made to the audit report. Your response to comment
38 in your letter dated June 27, 2023, indicated that your auditor determined it was not necessary to reference another auditor in its
report due to the subsidiary’s immateriality. However, the second and fourth paragraphs of the audit report continue to refer to your
auditor’s reliance on the report of another auditor. The report also continues to refer to the “review” of the other auditors.
Please address the following:

 ● Clarify for us whether the other auditors (i) audited the financial statements of Bull Head Products
Inc. and Georgia Fire & Rescue Supply LLC in accordance with the standards of the PCAOB or United States Generally Accepted Auditing
Standards, or (ii) performed a review of the financial statements
of the entities as defined in AICPA AR-C 90.

 ● If the latter, considering the fact that a review of financial statements is substantially less in
scope than an audit, have your auditor explain to us why it would be appropriate to rely on a review of these entities by another auditor
in forming its opinion. Tell us how that is consistent with the guidance in PCAOB Auditing Standard 1205.

 ● If the other auditors performed an audit of Bull Head Products Inc. and Georgia Fire & Rescue Supply
LLC, revise the filing to include their audit reports and have your auditor revise its report to indicate the periods covered by the reports
of the other auditors.

In response to this comment, the Company’s principal auditor
Pipara revised their audit report upon which they audited the financial statements for Bull Head Products Inc. and Georgia Fire &
Rescue Supply LLC. See comment 9.

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 9. We note the substantive revisions made to your financial statements, including the segment information
and disclosures added to Note 23 - Subsequent Events, but note that the audit report continues to be dated April 6, 2023. Tell us whether
your auditors have audited the changes and added disclosure to your financial statements. Please have your auditor explain to us how it
considered the guidance in PCAOB Auditing Standard 3110 in determining the appropriate date of its report.

In response to this comment, the Company’s auditor has audited
the changes and issued a new audit report as per date of this amended registration statement.

Business Segments, page F-12

 10. We note your response to comment 24. Please refer to the guidance in ASC 280-10-50- 12 which indicates
that you should report separately information for an operating segment that meets any one of the quantitative thresholds outlined.
We further note from page 62 that for fiscal year 2022 the revenues of Emergency & Response Division or operating segment exceeded
10 percent of your total revenues; the threshold outlined in ASC 280- 10-50-12.a. Please revise the note to identify the Emergency &
Response operating segment as a reportable segment and to provide the required disclosures for that segment. In addition, disclose the
measure of profit or loss used by your CODM to assess segment performance and to allocate resources. Lastly, revise the note to include
the reconciliations required by ASC 280-10-50-30, including reportable segment revenues to consolidated revenues, the reportable segment
measure of profit or loss to consolidated income before income taxes or net income, as appropriate, and reportable segment assets to consolidated
assets.

In response to this comment, the Company revised the registration statement
in accordance with ASC 280-10-50-12.

    11.
    We note your response to comment 25 and the revisions made to the discussion on page 61. We reissue the comment. Pursuant to ASC 280-10- 50-41, please revise your notes to financial statements to disclose revenue from external customers attributable to the United States and attributed to all foreign countries in total. Further, if revenues from external customers attributed to an individual foreign country are material, those revenues shall be disclosed separately. Disclose the basis for attributing revenues to individual countries. Similarly, disclose your long-lived assets located in the United States and located in all foreign countries in total. If assets in an individual foreign country are material, those assets shall be disclosed separately. Consider also including in this note the pertinent information currently presented on page 61.

In response to this comment, the Company revised its notes to financial
statements in accordance with ASC 280-10-50-41 and disclosed revenue from external customers attributable to the United States and attributed
to all foreign countries.

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Leases, page F-13

 12. We note your response to comment 26. Please tell us with specificity where you provided the disclosures
required by ASC 842-20-50-4 and ASC 842-20-50-6, or revise to comply.

In response to this comment, the company provided disclosure in the
financial footnotes as required by ASC 842-20-50-4 and ASC 842-20-50-6.

Note 11: Non-Current Liabilities, page F-20

 13. We note the disclosures related to your warrants included in Note 14 - Non-Current Liabilities to the
interim financial statements in your Form 10-Q for the six-month period ended June 30, 2023. Please revise this filing to include similar
disclosures in a note to the financial statements.

In response to this comment, the company revised this filing to include
similar disclosures to the interim financial statements in our Form 10-Q for the six-month period ended June 30, 2023.

 14. As part of your Form 10-Q disclosure, you indicate that in accordance with ASC 470 you have credited
the portion of the proceeds assigned to your warrants to paid-in capital. We also note the information provided in your response to comment
10 indicating that you may not have sufficient authorized common stock for potential conversion of your convertible preferred stock, convertible
notes, and the exercise of outstanding warrants. Please tell us in detail how you considered the guidance
in ASC 815-40-25, in particular ASC 815-40-25-10(b), in concluding on the classification and accounting of your outstanding warrants.
Tell us why the warrants should not be classified and accounted for as liabilities.

In response to this comment, the Company chose not
to record warrants in its financial books if the exercise price is significantly higher than the current market price and classifies it
as a contingent liability. For example, the common stock purchase warrant to Discover Growth Fund, LLC described below has an exercise
price of $0.275. As of December 31, 2022, the market price was $0.07, and by March 15, 2023, it had further decreased to $0.04 when the
Consolidated Financial Statements were being audited. The Company’s management classifies these warrants as a contingent liability,
given the decline in prices, making it unlikely that the warrants will be exercised in the future. The management reserves warrant shares
with its transfer agent. If the warrants should be exercised in the future the warrants will be accounted for in accordance with ASC 480.

 15. Further, in your June 27, 2023, letter when responding to prior comment 66 of our letter dated April
1, 2023, you indicated that the warrants are only deemed valid and enforceable in the event of default on a specific fund. You also indicated
that you had reached an agreement with the fund manager,
wherein they have agreed not to convert the warrant amount into equity unless a default occurs, and as a result no accounting was
required. To the extent you continue to believe that you are not required to account for the warrants based on these agreements,
please provide us with the details of the “specific” fund and explain how it is related to the debt to the warrant
holders. Provide us with a copy of your agreements with the fund manager or tell us where these terms are reflected in the warrant
agreements and the related amendments you have filed as exhibits.

In response to this comment, the Company has amended the
registration statement to include specific information about the accounting treatment for warrants.

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Note 12: Common stock and Preferred
Stock, page F-21

 16. We note your response to comment 27 that you have classified the redeemable preferred shares as permanent
equity rather than temporary equity as agreed with your auditor. Please provide us with a detailed analysis with appropriate references
to supporting accounting guidance on which you relied in concluding that the redeemable preferred shares should be classified in permanent
equity. As applicable, highlight for us any relevant terms of the Class E preferred stock, and any circumstances surrounding the legal
matters regarding your ownership of FB Fire Technologies Ltd and related lien-marked shares, that you considered pertinent and persuasive
in reaching your conclusion.

In response to this comment, in accordance with ASC 480, this instrument
possesses a hybrid nature; initially categorized as mezzanine equity, it is now deemed as temporary equity due to an ongoing case with
FB Fire Technologies Ltd. With reference to the designation certificate - the characteristics of the Preferred Class E are as follows:

No fixed Maturity date.

No voting rights and annual Dividends - 6% a year commencing
one year after issuance.

Redeemable at $1.00 dollar per share with 2.25 percent to be redeemed
per quarter, commencing one year after issuance, at 130% premium to the redemption value.

Note 18: Consolidation Basis of Mergers & Acquisitions,
page F-24

 17. We note the revised disclosure provided in response to comment 28, which highlights the significance
of Quality International Co LTD FCZ. Please tell us where you filed separate financial statements of Quality International Co LTD FCZ
for the two most recent fiscal yea