SecProbe.io

Mail Stop 3720

December 2, 2016

Iuliia Gitelman
President
Lazex Inc.
68/29 Husitska St.
Zizkov, Prague
Czech Republic 13000

Re: Lazex Inc.
Registration Statement on Form S -1
Filed  November 7, 2016
  File No. 333 -214463

Dear Ms. Gitelman :

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

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

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.

General

1. A shell company, as defined under Rule 405 of the Securities Act of 1933, is a registrant
that has no or nominal operations and either: (i) no or nominal assets; (ii) assets
consisting solely of cash and cash equivalents; or (iii) assets consisting of any amount of
cash and cash equivalents and nominal other assets. As it appears that you are a shell
company, please prominently disclose at the onset of your prospectus that Lazex, Inc. is
currently a shell company. Disclose the consequences of that status th roughout the
prospectus and risk factor disclosure, such as the limitations on the ability of your
security holders to use Rule 144, the restrictions on your ability to use registration

Iuliia Gitelman
Lazex Inc.
December 2, 2016
Page 2

 statements on Form S -8, the potential reduced liquidity or illiquidity  of your securities,
and the potential impact on your ability to attract additional capital.

2. Please disclose whether the company, its executive, any company promoters or their
affiliates intend for the company, once reporting, to be used as a vehicle for a private
company to become a reporting company. Also disclose, if true, that you do not believe
the company is a blank check company because the company has no plans or intentions
to engage in a merger or acquisition with an unidentified company, companie s, entity or
person.

3. It appears that, in addition to your principal executive office being located in the Czech
Republic, your sole officer and director and the company’s assets will all be located in
the Czech Republic. Please include a risk factor headi ng and disclosure to disclose these
facts and provide a discussion of the risks specific to effecting service of process,
enforcing judgments, and bringing original actions in the Czech Republic. Please also
discuss where you intend to conduct business, wh ere you intend focus your marketing
efforts, and what language will be used on your proposed website.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comment s, action or absence of
action by the staff.

Refer to Rules 460 and 461 regarding requests for  acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

You may contact Christie Wong, Staff Accountant, at (202) 551 -3684 or Ivette Leon ,
Assistant Chief Accountant, at (202) 551 -3351  if you have questions regarding comments on the
financial statements and related matters.  Please contact William Mastrianna, A ttorney -Adviser,
at (202) 551 -3778, Celeste M. Murphy, Legal Branch Chief, at (202) 551 -3257, or me at (202)
551-3810 with any other questions.

Sincerely,

 /s/ Celeste M. Murphy for

 Larry Spirgel
Assistant Director
AD Office 11 – Telecommunications