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    ZENLabs
                                         Holdings Inc

ZENLABS
                                         Holdings Inc

7745
Arjons Drive

    June
    11, 2020
    San
    Diego Ca 92126

    619.763.4901

VIA
EDGAR

Paul
Fisher and

Ameen
Hamady

Division
of Corporation Finance

Office
of Life Sciences

    Re:
    Zenlabs
    Holdings, Inc.

    Offering
    Statement on Form 1-A

    As
    amended May 28, 2020

    File
    No. 024-11174

    REQUEST
    FOR ACCELERATION OF QUALIFCATION

Dear
Mr. Fisher and Ms. Hamady:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Zenlabs Holdings, Inc. (the “Registrant”) hereby
requests acceleration of the qualification date of its Offering Statement on Form 1-A (File No. 024-11174), as amended (the “Offering
Statement”), so that it may become qualified before 4:00 p.m. Eastern Time on June 15, 2020, or as soon as practicable thereafter.
There are no underwriters of the issuance of the securities being registered to join this request for acceleration.

The
Registrant hereby authorizes Gina M. Austin, of Austin Legal Group, APC, to orally modify or withdraw this request for acceleration.

The
Registrant hereby acknowledges that:

(i)
should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated

authority,
qualify the Offering Statement, it does not foreclose the Commission from taking any action with respect to the Offering Statement;

(ii)
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Offering Statement effective,
does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Offering Statement;
and

(iii)
the Registrant may not assert comments of the Commission or the staff and the declaration of qualifying the Offering Statement
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We
request that we be notified of such qualifying by a telephone call to Ms. Austin at (619) 924-9600. We also respectfully request
that a copy of the written order from the Commission verifying the qualifying time and date of such Offering Statement be sent
to Ms. Austin via facsimile at (619) 881-0045.

    Best
    Regards,

    Zenlabs
    Holdings, Inc.

    Michael
    Boshart - Chief Executive Officer

7745
Arjons Drive San Diego, Ca 92126 619.763.4901