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Hemp
Technology, Inc.

A
Wyoming Company

3000,
421 - 7th Avenue SW • Calgary, Alberta, T2P4K9 Canada • Phone: (403) 870-8032

February
21, 2020

VIA
EDGAR TRANSMISSION AND E- MAIL

Division
of Corporation Finance

Office
of Life Sciences

U.
S. Securities and Exchange Commission

Division
of Corporate Finance

100
F Street N.E.

Washington,
D.C. 20549

    Re:
    Hemp
    Technology, Inc.

    Registration
    Statement on Form 10-12G

    Filed
    January 2, 2020

    File
    No. 000-56135

Ladies
and Gentlemen:

On
behalf of Hemp Technology, Inc. (the “Company”), we are hereby responding to the comment letter, dated January 29,
2020 (the “Comment Letter”), from the Staff (the “Staff”) of the U. S. Securities and Exchange Commission
(the “Commission”) with respect to the Company’s Registration Statement on Form 10-12G (File No. 000-56135).
In response to the Comment Letter, the Company is filing with the Commission today an amended Registration Statement on Form 10-12G/A.

For
ease of reference, set forth below are the comments of the Staff with respect to the Registration Statement. The Company’s
response is set forth below providing you with a response to each comment. Additionally, we are enclosing a marked copy of the
amended Registration Statement in PDF format in order to help you expedite your review process.

Item
1. Business, page 4

    1.
    We
    note the disclosure on page 4 that in September 2019 you entered into an agreement to acquire Pettanicals Pet Treats Inc.,
    which is owned by your president, and issued 1,020,000,000 shares of your stock as a deposit for this acquisition. Please
    revise to file the financial statements and pro forma financial information required by Rule 8-04 and 8-05 of Regulation S-X.

Response:
As disclosed in the Registration statement, the acquisition of Pettanicals Pet Treats Inc. is contingent on a payment of $153,000,
or no closing will take place. In our Registration Statement we added the disclosure under Principal Products or Services that
“there are no assurances or guarantees that the Company will be able to raise $153,000 to acquire the Pettanicals business.”
Under Management’s Discussion and Analysis of Financial Condition and Results of Operations, we added a Business Plan Timeline
that indicates that we need to raise monies in order to make this acquisition. At this time, it is questionable whether or not
we shall be able to raise the monies to complete this acquisition. Therefore, we believe it would be misleading, if we revised
our financial statements to reflect an acquisition that we state may not take place.

February
21, 2020

Page
2

Principal
Products or Services, page 4

    2.
    We
    note the disclosure on page 8 that you are a start-up in the hemp industry and have “put significant work into organizing
    the business and preparing it to succeed.” Additionally, we note that you have no revenues and will require substantial
    funds to complete your plans. Please revise this section as well as the rest of the registration statement to disclose in
    greater detail the current stage of your business. Your disclosure should clearly state the current status of development,
    the steps you have taken toward your planned operations, your anticipated timeline, and the steps that remain. Refer to Item
    101(h) of Regulation S-K.

Response:
Under our description of business, we added a section entitled “Required Funding,” which describes in greater detail
our current stage of business. Under Management Discussion and Analysis of Financial Condition and Results of Operations we added
a Business Timeline with milestone and manner of achievement of those milestones.

    3.
    In
    your description of your principal products or services, you state that “Hemp-derived CBD is believed to have many of
    the same medicinal properties as its cousin, cannabis” and “CBD extracted from hemp is typically used for therapeutic
    purposes such as pain management, sleep anxiety and inflammation.” Products that are intended for use in the diagnosis,
    cure, mitigation, treatment, or prevention of disease and/or intended to affect the structure or any function of the body
    are considered drugs under the Federal Food, Drug and Cosmetic Act and subject to FDA approval. Please revise to describe
    the regulatory status of these products, or revise to avoid unsubstantiated therapeutic claims.

Response:
We respectfully note the Staff’s comment. We have revised our disclosure to delete the unsubstantiated therapeutic claims.

    4.
    Please
    revise to include a discussion of the operations of Pettanicals Pet Treats Inc.

Response:
We have revised to include a discussion about Pettanicals Pet Treats Inc. under Principal Products or Services. We have also added
the disclaimer that if the Company is “unable to pay the additional $153,000, no closing will take place.”

February
21, 2020

Page
3

    5.
    We
    refer to your disclosure on page 10 that you plan to introduce a powdered drink product that will likely contain CBD. In addition,
    we also note that a presentation on what appears to be your website located at www.hemptechnologyinc.com indicates that you
    are also developing branded products including vapes, CBD tinctures and CBD-infused topicals. To the extent material, please
    provide disclosure about these products and the status of development in the discussion of your products.

Response:
Our website has been revised to state under products, that “Hemp Technology’s planned product line-up includes
1) whole plant hemp; 2) CBD isolate powder; 3), high CBD hemp seeds; 4) CBD distillate oil; and 5) hemp-derived full spectrum
CBD oil.” We have changed the reference to the “powdered drink” in our Registration Statement to “proposed
product.” Further, under Item 1, entitled, “Principal Products or Services,” we have revised our proposed products
to match the products listed on our website.

Competitive
Conditions, page 5

    6.
    We
    note references to third-party market data from the Brightfield Group. Please provide us with copies of any materials that
    support third-party statements and advise us if any of the data cited was commissioned by the company.

Response:
We understand your concern with this reference. Upon further investigation, we discovered that the Brightfield Group makes references
to other third party sources, that would be difficult to verify. For this reason, we have deleted the reference to the Brightfield
Group. Further to your comment, there was no data cited that was commissioned by our company.

Distribution
Methods, page 5

    7.
    Please
    revise to provide the basis for your claim that when processing your own hemp in Colombia you expect margins to exceed 85%.

Response:
We respectfully note the Staff’s comment. When this Registration Statement was first written, management believed that margins
would exceed 85%. However, at this point, we recognize that there are too many variables to predict the outcome of our extraction
technology and subsequent margins. Therefore, we have deleted our margin expectations.

    8.
    We
    note your disclosure that you have identified buyers that are capable of buying your entire output for the first year. Please
    revise to disclose whether you are in negotiations with these buyers and/or whether you have entered into any agreements.
    To the extent that you have entered into any agreements, please describe the material terms of these agreement and file them
    as exhibits to the registration statement or tell us why you are not required to do so. Please see Item 601(b)(10) of Regulation
    S-K.

Response:
We are not in any negotiations nor do we have entered into any agreements with buyers. For that reason, we have deleted the reference
to the buyers. We have added in our business timeline, under Management Discussion and Analysis of Financial Condition and Results
of Operations that we are working on establishing key agricultural and cultivations partners in the hemp industry.

February
21, 2020

Page
4

Principal
Markets, page 5

    9.
    Please
    revise here, and elsewhere as applicable, to identify and discuss the restrictions that  may limit your ability to compete
    for market share.

Response:
Under the Principal Markets section, we have added the last two paragraph which discuss the restriction that my limit our ability
to complete for market share.

Farm
Design (Colombia), page 6

    10.
    Please
    revise to provide additional disclosure concerning your Columbian hemp farm. For  instance, revise, as applicable, to
    discuss whether you own or lease the farm.

Response:
Management has decided not to pursue any further planning, investment or any operations in Colombia, until, at least, Q1 of 2021.
See response to Comment 12 below. Therefore, the disclosure of the “Farm Design” is no longer applicable to this Registration
Statement and has been deleted.

Licenses,
page 6

    11.
    Please
    discuss the material terms of the Processor/Handler Licensing Agreements with the Kentucky Department of Agriculture and file
    the agreements as exhibits to the registration statement, or tell us why this is not required. In addition, to the extent
    you are party to any other material contracts, please include a description of material terms and file them as exhibits to
    the registration statement. See Item 601(b)(10) of Regulation S-K.

Response:
We have added disclosure where we discussed the material terms of the Processor/Handler Licensing Agreements with the Kentucky
Department of Agriculture and we files the agreements as exhibits. Supplementally, we are not a party to other material contracts
that have not already been disclosed.

February
21, 2020

Page
5

Principal
Suppliers, page 6

    12.
    We
    note that extraction licenses issued by the Colombian government include international exportation. Please discuss the licenses
    you will need in order to conduct your business in Colombia and the status of obtaining these licenses.

Response:
We have revised the disclosure to state, “Management has decided not to pursue any further planning, investment or any operations
in Colombia, at this time. Management has not applied for, nor proceeded with our intended acquisition of an existing Colombian
license. Management is focused on raising money to initiate its planned operations in the State of Kentucky. At this time, management
intends to wait until, at least, Q1 of 2021 to access and survey any business opportunity in Colombia.”

Employees,
page 7

    13.
    We
    note your disclosure that you have three executive officers and no other employees. We also note that what appears to be your
    website at www.hemptechnologyinc.com includes profiles of nine individuals on the Hemp Technology management team. Please
    revise or advise.

Response:
Our website at www.hemptechnologyinc.com has been updated to reflect the names of our three executive officers and no other employees
as originally disclosed in our Registration Statement.

Environmental
Laws, page 7

    14.
    To
    the extent material, please expand this section to provide more details on the environmental laws and regulations that impact
    your operations and costs.

Response:
We have expanded the section under environment laws to provide more details on the environmental laws and regulations that can
impact our operations and costs. See last two paragraphs under the Environmental Law section.

Risk
Factors

We
may be subject to compliance actions by the Food and Drug Administration..., page 12

    15.
    Please
    revise to disclose why your operations may be subject to compliance actions by the Food and Drug Administration for making
    unsubstantiated claims as to your products’ efficacy or intended use. In your revised disclosure, please disclose how
    compliance actions would impact your business.

Response:
This section has been completely revised, it is now entitled “FDA regulation could negatively affect the hemp industry,
which would directly affect our financial condition.” The section has been revised to disclose how compliance actions would
impact our business.

We
may be subject to product liability claims or regulatory action..., page 12

    16.
    We
    note your disclosure that you have in the past recalled, and may again in the future have to recall, certain of your products
    as a result of potential contamination and quality assurance concerns. Please revise to disclose the products you recalled
    and the nature of the concern.

Response:
We have not had any product recalls. The sentence dealing with the product recalls has been deleted. Thank you for bringing this
oversight to our attention.

February
21, 2020

Page
6

The
FDA has stated that it interprets the FDCA to prohibit the sale..., page 13

    17.
    Please
    revise to clarify why this risk factor is applicable to your operations. To the extent you plan to market and sell food products,
    including animal foods and supplements, that contain CBD in a manner that would violate US federal law, please make this clear
    here and in your business section.

Response:
We respectfully note the Staff’s comment and we agree with the Staff that this risk factor is not applicable to our
operations. For this reason, this risk factor has been deleted.

Item
5. Directors and Executive Officers

Business
Experience, page 27

    18.
    We
    note your disclosure that Mr. Costa is a “serial entrepreneur in the cannabis space” and was “instrumental
    in founding and establishing a chain of legal retail cannabis stores that have achieved strong recognition and significant
    market share.” Please revise your disclosure to name the chain of legal retail cannabis stores that Mr. Costa established
    and to disclose the names of any other businesses he founded in the cannabis space. See Item 401(e)(1) of Regulation S-K.

Response:
We have revised our disclosure to comply your comments and with 401(e)(1) of Regulation S-K.

Item
13. Financial Statements and Supplementary Data, page 38

    19.
    Please
    revise to update the financial statements included in your Form 10 pursuant to Article 8-08 of Regulation S-X.

Response:
We have updated the financial statements included in our Form 10 pursuant to

Article
8-08 of Regulation S-X.

Exhibits

    20.
    Please
    file the complete articles of incorporation for the company, as amended. We note that Exhibit 3.1 appears to only include
    amendments. Refer to Item 601(b)(3)(i) of Regulation S-K.

Response:
We have filed the complete Articles of Incorporation dated October 17, 2005.

February
21, 2020

Page
7

    21.
    Please
    file a complete copy of Exhibit 10.1, including the signature page and any exhibits or schedules if applicable.

Response:
We have filed a complete copy of Exhibit 10.1, including the signature page.

General

    22.
    Pursuant
    to Section 12(g)(1) of the Exchange Act, the Form 10 becomes effective automatically 60 days after the initial filing date.
    At that time, you will be subject to the reporting requirements of the Exchange Act. In addition, we will continue to review
    your filing until all of our comments have been addressed. If the review process has not been completed before the effectiveness
    date you should consider withdrawing the Form 10 registration statement to prevent it from becoming effective and, as applicable,
    file a new Form 10 registration at such time as you are able to respond to any remaining issues or comments.

Response:
Acknowledged.

We
thank you for your thorough review process to assist us in our compliance with the applicable disclosure requirements and to enhance
the overall disclosure in our filing. Please let us know if you have any additional comments.

    Hemp Technology, Inc.