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                                                             July 12, 2024

Suzanne Bird
Co-Trustee
Libertas Trust
7639 Davidson Road
Chattanooga, TN 37421

       Re: Libertas Trust
           BioRegenx, Inc.
           Schedule 13D Filed by Libertas Trust et al.
           Filed April 29, 2024
           File No. 005-94500
Dear Suzanne Bird:

       We have reviewed the above-captioned filing and have the following
comments.

       Please respond to this letter by amending the filing or by providing the
requested
information. If you do not believe our comments apply to your facts and
circumstances or that an
amendment is appropriate, please advise us why in a response letter.

        After reviewing any amendment to the filing and any information
provided in response to
these comments, we may have additional comments.

Schedule 13D Filed April 29, 2024
General

1.     We note that the cover page of the Schedule 13D does not include the
date of the event
       requiring the filing of the Schedule 13D. Please revise to specify the
reported event date.
       Rule 13d-1(a) of Regulation 13D-G requires the filing of a Schedule 13D
within five
       business days after the date beneficial ownership of more than five
percent of a class of
       equity securities specified in Rule 13d-1(i)(1) was acquired. If the
Schedule 13D was not
       filed within the required five business days after the date of the
acquisition, please advise
       us why the Schedule 13D was not timely filed.
2.     On the cover pages and under Item 5 of the Schedule 13D, we note that
each reporting
       person has disclosed its beneficial ownership of both BioRegenx, Inc.'s
common shares
       and its Series A preferred shares. Rule 13d-1(a) of Regulation 13D-G
only requires the
       filing of a Schedule 13D when a person acquires beneficial ownership of
more than five
       percent of any equity security of a class which is specified in Rule
13d-1(i)(1). The Series
 July 12, 2024
Page 2

       A preferred shares do not appear to be a class of equity securities
under Rule 13d-1(i)(1).
       Please revise to remove references to the beneficial ownership of Series
A preferred
       shares to avoid the impression that they are a separate class of
reportable equity securities,
       or otherwise advise. If such Series A preferred shares are convertible
into BioRegenx,
       Inc.'s common stock within sixty days, please also revise the reported
beneficial
       ownership of common shares to reflect this right to acquire common
shares. See Rule
       13d-3(d)(1)(i) of Regulation 13D-G.
Item 2, page 5

3.     As required by the terms of Item 2(c) and Item 2(f) of Schedule 13D,
please revise this
       section to specify Mr. and Ms. Bird's citizenship and "[p]resent
principal occupation or
       employment and the name, principal business and address of any
corporation or other
       organization in which such employment is conducted."
        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

      Please direct any questions to Shane Callaghan at 202-551-6977 or
Nicholas Panos at
202-551-3266.

                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Mergers
& Acquisitions
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