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March 17, 2023
Steven Arenal
Chief Executive Officer
Lucent, Inc.
1633 East Fourth Street
Suite 148
Santa Ana, CA 92701
Re:Lucent, Inc.
Amendment No. 2 to Form 10
Filed March 3, 2023
File No. 000-56509
Dear Steven Arenal:
            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.
Amendment No. 2 to Form 10 filed March 3, 2023
General
1.We note your response to comment 11 of our letter.   Please revise the disclosure
throughout to clearly reference the prior registration statement on Form S-1 that was
declared effective on April 13, 2020, disclose the reporting obligations that commenced
upon effectiveness of that registration statement, and clearly disclose the delinquency of
the company by failing to file the required periodic reports.  Please also revise your
disclosure throughout to address the risks associated with failure to file the Exchange Act
reports.  Lastly, please include a separate risk factor relating to the risks.

 FirstName LastNameSteven Arenal
 Comapany NameLucent, Inc.
 March 17, 2023 Page 2
 FirstName LastName
Steven Arenal
Lucent, Inc.
March 17, 2023
Page 2
Item 4. Security Ownership of Certain Beneficial Owners and Management, page 11
2.We partially reissue comment 3.  Please update the information in this section as of the
most recent practicable date.  The current disclosure is as of July 31, 2018.
Item 5. Directors and Executive Officers, page 12
3.We note your response to comment 4 of our letter and reissue our comment.  Please
provide at least 5 years of experience for Mr. Arenal, including clear disclosure of any
experience with shell companies.  For example, we note that Mr. Arenal is listed as the
CEO for Tenaya Group Inc.  Please disclose each company worked at, the position held,
and the month and year his employment started and ended with each entity.  Please
identify any conflicts associated with having at least two companies that would currently
be seeking merger candidates.
Financial Statements as of and for the six months ended November 30, 2022 and 2021, page F-
14
4.We reissue our comment 10 as the header on page F-14 continues to refer to the notes to
the interim financial statements as audited instead of unaudited.  In addition, please revise
the header on page F-7 to refer to notes to the audited financial statements.
            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 Peter McPhun at 202-551-3581 or Jennifer Monick at 202-551-3295 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Stacie Gorman at 202-551-3585 or Pam Howell at 202-551-3357 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Byron Thomas, Esq.