SecProbe.io

Mail Stop 3030

November 2 , 2018

Harry Simeonidis
President
Glucose Biosensor Systems (Greater China) Holdings, Inc.
733 Third Avenue, Floor 15
New York, New York 10017

Re: Glucose Biosensor Systems (Greater China) Holdings, Inc.
Offering Statement  on Form 1-A
Filed October 22, 2018
  File No. 024 -10911

Dear Mr. Simeonidis:

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

Lock -Up Agreement, page 97

1. If, as indicated by your response  to prior comment  3, the issuer  is subject to a six -month
lock up, please revise the reference to “we” in the first sentence to eliminate the
implication that the duration of the issuer ’s lock up is one year.

Consolidated Financial Statements

Report of Independent Registered Public Accounting Firm, page F -3

2. Please amend the filing to have your auditor include an audit report that covers both
periods presented in the audited financial  statements in the format required by PCAOB
Auditing Standard 3101.   Refer to Rule 2 -02 of Regulation S -X and SEC Release 34 -
81916.

Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
November 2 , 2018
Page 2

 Consolidated Statement of Operations, page F -5

3. Please revise to round loss per share to two decimal places to avoid giving  the impression
of more precision than exists.

Exhibit Index

4. Please re vise to comply with General Instruction III(b) to Form 1 -A.

We will consider qualifying your offering statement at your request.  If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.

 We remind you that the company and its management are responsible for the accuracy
and adequacy of the ir disclosures, notwithstanding any review, comments, action or absence of
action by the staff.  We also remind you that, following qualification of your Form 1 -A, Rule 257
of Regulation  A requires you to file periodic and current reports , including a Form  1-K which
will be  due within 120 calendar days after the end of the fiscal year covered by the report .

You may contact Michael Fay  at (202) 551 -3812 or Gary Todd, Senior Accountant, at
(202) 551 -3605 if you have questions regarding comments on the financial statements and
related matters.  Please contact Geoff Kruczek  at (202) 551 -3641 or me at (202) 551 -3617 with
any other questions.

Sincerely,

 /s/ Russell Mancuso

Russell Mancuso
Branch Chief
Office of Electronic s and Machinery

cc:  Gary J. Simon —Hughes Hubbard & Reed LLP