SecProbe.io

May 7, 2019
Mark Williams
President and Chief Executive Officer
20/20 Global, Inc.
480 22nd Street, Box 2
Heyburn, ID 83336
Re:20/20 Global, Inc.
Form 10-12G
Filed April 15, 2019
File No. 000-56022
Dear Mr. Williams:
            We have reviewed your filing 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.
Form 10 Filed April 15, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
10
1.Please refer to your analysis of results of operations beginning on page 10.  Please revise
your disclosure concerning the fluctuations in revenue, gross profit, and general and
administrative expenses to provide your readers with management's insight into why these
items increased or decreased from 2017 to 2018 rather than merely repeating the dollar
amounts seen on the face of your statements of operations.  Refer to Item 303 of
Regulation S-K.
Exhibit 3.02 Bylaws of 20/20 Global, Inc
2.We note that the forum selection provision in your bylaws identifies the state or federal
court of Utah as the exclusive forum for certain litigation, including any ``derivative

 FirstName LastNameMark Williams
 Comapany Name20/20 Global, Inc.
 May 7, 2019 Page 2
 FirstName LastName
Mark Williams
20/20 Global, Inc.
May 7, 2019
Page 2
action.´´ Please disclose whether this provision applies to actions arising under the
Securities Act or Exchange Act. In this 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 revise your
disclosures to disclose this information and to state that there is uncertainty as to whether
a court would enforce such provision, and to state that stockholders will not be deemed to
have waived the company’s compliance with the federal securities laws and the rules and
regulations under it.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Jennifer Thompson, Accounting Branch Chief, at 202-551-3737 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg, Staff Attorney, at 202-551-3342 or Jennifer López-Molina, Staff
Attorney,  at 202-551-3792 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Consumer Products