SecProbe.io

June 7, 2019
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.
Draft Registration Statement on Form S-1
Submitted May 13, 2019
CIK No. 0001725430
Dear Mr. Simeonidis:
            We have reviewed your draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1 submitted May 13, 2019
Prospectus Summary, page 1
1.If true, please disclose that to date you have not generated any revenues from sales of your
intended products and that to date you have incurred net losses and negative cash flows
from operations.
2.Please balance your disclosure that the SGB produces a signal directly correlated to the
amount of glucose present in saliva with disclosure of whether you have any third-party
clinical validation that supports a meaningful correlation between glucose present in saliva
and glucose present in blood.  If you do not have clinical evidence of a
meaningful correlation at this time, please disclose in an appropriate location in your
prospectus the basis for your belief that the measurement of salivary glucose is a

 FirstName LastNameHarry Simeonidis
 Comapany NameGlucose Biosensor Systems (Greater China) Holdings, Inc.
 June 7, 2019 Page 2
 FirstName LastName
Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
June 7, 2019
Page 2
meaningful proxy for blood glucose levels and include appropriate risk factor disclosure
regarding your beliefs.
3.We note your disclosure that the biosensor technology has been "extensively referenced in
scientific literature."  It is unclear what this disclosure is intended to convey since you also
appear to disclose that you have not generated clinical evidence to support regulatory
clearance.  If you elect to reference scientific literature please briefly indicate the nature of
the references and provide balanced disclosure, including information regarding any
reference with results that may not support that salivary glucose biosensors provide
meaningful information for blood glucose monitoring.
4.Given your disclosure that the Licensor owns all of the intellectual property related to the
biosensor technology, including any improvements made to the technology by you, and all
data and any derivations related to the foregoing, briefly disclose how you intend to
conduct business after your license agreement expires and include appropriate risk factor
disclosure.
5.We note the intended launch of other diagnostics tests.  Briefly explain the status of
development of those products.  Also compare that status with the status of your SGB
product.
License Agreement, page 3
6.Revise the second paragraph to clarify whether you, your affiliates, the Licensor or its
affiliates currently are capable of manufacturing your product.
7.Please briefly explain the reason for the geographic scope limitation of the License
Agreement.  If the Licensor has granted other licenses with different or overlapping
scopes, please also disclose that fact and explain the extent of that scope.  Please also
explain the purpose and intended use of the demographic information and personally
identifiable information, including health information, you are required to assemble.
Risks We Face, page 5
8.Revise your ninth bullet point to disclose, if true, that the Licensor may choose not to
protect the intellectual property and proprietary rights.
Implications of being an Emerging Growth Company, page 6
9.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.

 FirstName LastNameHarry Simeonidis
 Comapany NameGlucose Biosensor Systems (Greater China) Holdings, Inc.
 June 7, 2019 Page 3
 FirstName LastName
Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
June 7, 2019
Page 3
Common Stock to be Outstanding after this Offering, page 7
10.Please tell us how the 1,861,706 outstanding shares of your Series A Convertible
Preferred Stock is reconcilable to the information in your balance sheet as of December
31, 2018 and the information on pages F-15 and F-16.
Our parent company may exert significant influence..., page 30
11.If true, please disclose that your decision not to seek exemption as a "controlled company"
could change.  If your decision could change with respect to relying on the exemptions,
please include appropriate risk factor disclosure.  Please also revise your disclosure in an
appropriate section, such as pages 63-66, to specify the nature of the "controlled
company" exemptions that would be available to you.
Use of Proceeds, page 34
12.Please clarify the extent to which the proceeds to be received will enable you to achieve
the items specified in the first two bullet points.
Liquidity and Capital Resources, page 40
13.We note the references to financial support from the shareholders of your parent entity in
the third paragraph of Note 1 to your financial statements on page F-8.  Please tell us why
you have not included disclosure regarding those arrangements in this section or revise
your disclosure as appropriate.  In this regard, we also note your disclosure on page 10
that you do not currently have any arrangements or credit facilities in place as a source of
funds.  Please ensure that your disclosure is consistent throughout your prospectus.  Please
also file as exhibits the letters relating to the financial support those entities intend to
provide.
Description of Business, page 41
14.We note your disclosure in the second risk factor on page 13.  Please tell us the basis for
your statement above figure 5 on page 44 that the pictured technology allows mass
volume printing at low cost or revise your disclosure as appropriate.  Since you have not
entered the mass production stage, please tell us why it is appropriate to depict this
technology in your prospectus summary.
15.Please provide us your analysis of whether you are a "foreign private issuer," as defined in
Rule 405 of Regulation C.  In this regard, we note that you state your principal executive
offices are in New York, but that such offices are limited in size.  It is also unclear what
functions are performed there, given the geographic scope of the license, location of your
sole stockholder and its affiliates and location of your other management team members.

 FirstName LastNameHarry Simeonidis
 Comapany NameGlucose Biosensor Systems (Greater China) Holdings, Inc.
 June 7, 2019 Page 4
 FirstName LastName
Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
June 7, 2019
Page 4
The Saliva Glucose Biosensor, page 46
16.Please briefly describe the technological claims protected by your patent.  Clarify whether
the China patent relates to similar or identical technological claims as your U.S. patent.
17.Briefly indicate how the biosensor communicates with the smart device and indicate how
the incorporation of the communication technology in the biosensor may impact cost.
Also, your disclosure indicates that you have successfully developed a product that
communicates with a smart device.  If that is not correct, please revise to eliminate that
implication.
Competition, page 62
18.Clarify the basis for the statements in the second paragraph given the status of your
product's development.
Management, page 63
19.We note your disclosure that Mr. Simeonidis has been with Farmaforce since March
2017.  It also appears that Mr. Becker and Mr. Sakiris are also currently employed by
entities other than the registrant.  If Messrs. Simeonidis, Becker and Sakiris will not be
full-time employees, please clarify and include any appropriate risk factor disclosure,
including any conflicts of interest, and reconcile with your disclosure on page 62 that you
have no part-time employees.  Also disclose Mr. Simeonidis' business experience between
April 2015 and March 2017.
20.Disclose Dr. Hei's business experience between February 2015 and August 2018.
Principal Stockholders, page 74
21.Please revise footnote 2 to disclose all natural person or persons who exercise the sole or
shared voting and/or dispositive powers with respect to your shares held by Life Science
Biosensor Diagnostics Pty Ltd.
22.Please expand the information in the table to account for the transactions referenced in the
second paragraph on page 84, as applicable.
Certain Transactions, page 75
23.Please tell us how you determined that any agreements relating to the employee sharing
arrangements discussed here are not required to be filed as exhibits in accordance with
Regulation S-K Item 601(b)(10) or file the agreements as appropriate.
Related Party Policy, page 76
24.Please disclose the standards to be applied in deciding whether to approve or ratify any
related party transaction.  Refer to Regulation S-K Item 404(b)(1)(ii).

 FirstName LastNameHarry Simeonidis
 Comapany NameGlucose Biosensor Systems (Greater China) Holdings, Inc.
 June 7, 2019 Page 5
 FirstName LastName
Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
June 7, 2019
Page 5
Consolidated Financial Statements
Consolidated Balance Sheets, page F-3
25.Please revise to provide the correct date above each of the balance sheets.  The headings
appear to be reversed.  Also, delete the label "audited" above the balance sheet derived
from your audited financial statements.  The audit report expresses an opinion on the
financial statements taken as a whole rather than on individual components of those
financial statements.
Consolidated Statements of Operations, page F-4
26.Please revise to round loss per share to two decimal places to avoid giving the impression
of more precision than exists, here and Note 13.
            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 Tim Buchmiller at (202) 551-3635 or Geoff Kruczek, Special
Counsel, at (202) 551-3641 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc:       Eric T. Schwartz, Esq.