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    Hughes
        Hubbard & Reed LLP

        One
        Battery Park Plaza

        New
        York, New York 10004-1482

        Telephone:
        212-837-6000

        Fax:
        212-422-4726

        hugheshubbard.com

        Gary
        J. Simon

        Chair,
        Securities and Capital Markets Group

        Direct
        Dial: 212 837-6770

        Direct
        Fax: (212 299-6770

        gary.simon@hugheshubbard.com

November 7, 2018

By EDGAR

Securities and Exchange Commission

100 F St., N.E.

Mail Stop 3030

Washington DC 20549

 Attention: Russell Mancuso

Branch Chief

 Re: Glucose Biosensor Systems (Greater China) Holdings, Inc.

	Offering Statement on
Form 1-A

	Submitted October 19,
2018

	CIK
No. 001725430

Ladies and Gentlemen:

On behalf of our client,
Glucose Biosensor Systems (Greater China) Holdings, Inc. (the “Company”), set forth below are the Company’s responses
to the comment letter dated November 2, 2018 from the staff regarding the above-captioned offering statement filed by the Company
under the Securities Act of 1933. The numbered paragraphs and headings below correspond to the headings and numbers in the comment
letter and references in the responses below to exhibits and page numbers in the preliminary offering circular mean the exhibits
and pages in the Form 1-A/A filed concurrently herewith (“Amendment”). For your reference, preceding each response
in bold we have reproduced in italics the comment that corresponds thereto.

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.

Response:

1.       The
referenced disclosure has been revised on pages 54 and 97 of the Amendment.

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.

Response:

2.       The
audit report has been revised on page F-3 of the Amendment.

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.

Response:

3.       The
referenced disclosure has been revised on pages F-5, F-18, F-23 and F-33 of the Amendment.

Exhibit
Index

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

Response:

4.       The
exhibit index has been revised.

*  *  *  *  *

Acknowledgements

The Company acknowledges
that:

 · should the Commission or the staff, acting pursuant to delegated authority, declare the filing
effective, it does not foreclose the Commission from taking any action with respect to the filing;

 · the action of the Commission or the staff, acting pursuant to delegated authority, in declaring
the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure
in the filing; and

 · the Company may not assert staff comments and the declaration of effectiveness as a defense in
any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please call me at (212)
837-6770 with any questions or comments regarding the foregoing. Thank you for your consideration.

    Very truly yours,

    /s/ Gary J. Simon

    Gary J. Simon

 cc: Harry Simeonidis

Dr. Jean-Claude Becker