SecProbe.io

August 16, 2019
Harry Simeonidis
President
Glucose Biosensor Systems (Greater China) Holdings, Inc.
708 Third Avenue, 6th Floor
New York, New York 10017
Re:Glucose Biosensor Systems (Greater China) Holdings, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed August 2, 2019
File No. 333-232557
Dear Mr. Simeonidis:
            We have reviewed your amended 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 your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our July 11, 2019 letter.
Amendment No. 1 to Registration Statement on Form S-1 filed August 2, 2019
Management, page 64
1.Exhibits 10.5 and 10.7 indicates that Mr. Syrmalis is your chief executive officer and that
your President and Chief Financial Officer report to him, contrary to your disclosure in
this section.  Please revise or advise.  Please also reconcile your disclosure on page 71
regarding the terms of the referenced employment agreements with Exhibits 10.5 and
10.7.
Exclusive Forum Selection, page 84
2.We note that your forum selection provision in exhibit 3.1 identifies the Court of
Chancery of the State of Delaware as the exclusive forum for certain litigation, including

 FirstName LastNameHarry Simeonidis
 Comapany NameGlucose Biosensor Systems (Greater China) Holdings, Inc.
 August 16, 2019 Page 2
 FirstName LastName
Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
August 16, 2019
Page 2
any “derivative action.”  Please disclose whether this provision applies to actions arising
under the Securities Act or Exchange Act.  In that regard, we note that Section 27 of the
Exchange Act creates exclusive federal jurisdiction over all suits brought to enforce any
duty or liability created by the Exchange Act or the rules and regulations thereunder, and
Section 22 of the Securities Act creates concurrent jurisdiction for federal and state courts
over all suits brought to enforce any duty or liability created by the Securities Act or the
rules and regulations thereunder.  If the provision applies to Securities Act claims, please
also revise your prospectus to state that there is uncertainty as to whether a court would
enforce such provision and that investors cannot waive compliance with the federal
securities laws and the rules and regulations thereunder.  If this provision does not apply
to actions arising under the Securities Act or Exchange Act, please also ensure that the
exclusive forum provision in the governing documents states this clearly.
            You may contact Michael Fay at (202) 551-3812 or Brian Cascio, Accounting Branch
Chief, at (202) 551-3676 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.