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 March 21, 2025

Naveen Krishnarao Kulkarni
Chief Executive Officer and President
Quantumzyme Corp.
15656 Bernardo Center Drive Suite 801
San Diego, CA 92127

 Re: Quantumzyme Corp.
 Amendment No. 1 to Registration Statement on Form 10-12G
 Filed March 10, 2025
 File No. 000-56725
Dear Naveen Krishnarao Kulkarni:

 We have reviewed your filing and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response and any amendment you may file in
response to this
letter, we may have additional comments.

Amendment No. 1 to Form 10-12G, filed March 10, 2025
Item 1. Description of Business, page 4

1. We note your revisions in response to prior comments 2 and 3. We note
your
 disclosure that "commercialization of your enzyme will be by and through
third party
 manufacturers, who will ultimately supply the product to the consumer,
such
 manufacturers will be required to comply with required all governmental
regulatory
 issues, including the FDA and similar governmental agencies." We also
note that you
 state "initially" you will not be subject to any regulatory or
compliance issues. Please
 revise to clarify if regulatory approval will be needed by the Company
or any third
 party. If so, please briefly describe the regulatory approval process
that your products
 will need to complete, including any review required by regulators for
enzymes used
 in biopharmaceutical applications.
2. We note your statement on page 4: "As of the date hereof, we have
engineered our
 first product, which is an enzyme for use in pharmaceutical API
production of
 Ibuprofen. Specifically, our initial product is targeted at select
pharmaceutical
 March 21, 2025
Page 2

 companies who produce generic drugs." We also note your statement on
page 17: "We
 anticipate that we will file and prosecute patent applications and
endeavor to maintain
 trade secrets in an ongoing effort to protect our intellectual property
rights as we move
 the business forward." Please revise to state whether you have patent
protection for
 your first product or any other products. If so, for each material
patent please provide
 (i) the type of patent protection, (ii) the product the patent relates
to, (iii) whether such
 patent is owned or licensed, (iv) the jurisdiction and (v) the
expiration date.
Item 1A. Risk Factors, page 14

3. We note your revisions in response to prior comment 4 that you pay for
the use of
 testing facilities on an as needed basis, with no formal written
agreement in place.
 Please also provide a separate risk factor regarding the risks
associated with
 conducting all of your testing in these off-site locations with no
formal agreements.
4. We note that you only have one employee. Please revise to describe how
you plan to
 accomplish your business objectives in the near-term through the efforts
of your one
 employee, noting whether you intend to hire independent contractors or
other
 employees. Please include risk factor disclosure regarding the risks of
employing only
 one employee.
Item 4. Security Ownership of Certain Beneficial Owners and Management, page 22

5. We note your statement on page 23: "Conversion of the Series A and
Series B Shares
 is voluntary at the discretion of the holder and the Series A and Series
B Preferred
 Stock carry other rights, preferences, and privileges customary with
series of preferred
 stock of this nature." We also note that your controlling stockholder,
who is also your
 CEO and President, currently holds all outstanding preferred stock.
Please revise to
 describe the rights, preferences and privileges of your preferred stock.
Refer to Item
 202(a)(4) of Regulation S-K.
Exhibits

6. We note your response to prior comment 11. It appears that the Asset
Purchase
 Agreement shown in the Exhibit Index as Exhibit 10.1 links to the
Employment
 Agreement filed as Exhibit 10.2. Please revise or advise.
 March 21, 2025
Page 3

 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 Christie Wong at 202-551-3684 or Jeanne Baker at
202-551-3691 if
you have questions regarding comments on the financial statements and related
matters. Please contact Nicholas O'Leary at 202-551-4451 or Margaret Sawicki at
202-551-
7153 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Jessica Lockett, Esq.
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