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United States securities and exchange commission logo
June 11, 2024
George Athanasiadis
Chief Executive Officer
Eco Bright Future, Inc.
World Trade Center El Salvador
Calle El Mirador; 87 Ave Norte
San Salvador, El Salvador
Re:Eco Bright Future, Inc.
Registration Statement on Form 10
Filed May 16, 2024
File No. 000-56658
Dear George Athanasiadis:
            We have reviewed your filing and have the following comments.
            Please respond to this letter 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 a
comment applies 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 this letter,
we may have additional comments.
Registration Statement on Form 10
General
1.We note that you are voluntarily registering your common stock under Section 12(g) of
the Securities Exchange Act of 1934. Please note that the Form 10 goes effective
automatically by lapse of time 60 days after the original filing date. If our comments are
not addressed within this 60-day time period, you may consider withdrawing the Form 10
prior to effectiveness and refile a new Form 10 including changes responsive to our
comments. If you choose not to withdraw, you will be subject to the reporting
requirements under Section 13(a) of the Securities Exchange Act of 1934. In addition, we
will continue to review your filing until all of our comments have been addressed.
2.Please revise to disclose whether you offer or intend to offer any of your services and
products in the U.S. or to U.S. persons, and please revise to include disclosure regarding
the policies and procedures you have in place to determine whether the crypto assets and

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June 11, 2024
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crypto-asset related services and products you offer or intend to offer are not "securities"
within the meaning of Section 2(a)(1) of the Securities Act such that you are not
facilitating or engaging in transactions in unregistered securities.
3.Please include a risk factor that discusses the risks and limitation of your internal policies
and procedures to determine whether the crypto assets and crypto-asset related services
and products you offer or intend to offer are “securities” within the meaning of Section
2(a)(1), including that your internal policies and procedures are risk-based judgments
made by the company and not a legal standard or determination binding on any regulatory
body or court. In preparing your response, you may find useful the letter sent by the
SEC’s Strategic Hub for Innovation and Financial Technology to The New York State
Department of Financial Services on January 27, 2020, available at
https://www.sec.gov/files/staff-comments-to%20nysdfs-1-27-20.pdf.
4.Please provide us with your analysis as to your potential status as an investment company
under the Investment Company Act of 1940 and add a risk factor that addresses such risk
and the impact on your business.
5.We refer you to our December 2022 Sample Letter to Companies Regarding Recent
Developments in Crypto Asset Markets, located on our website at the following address:
https://www.sec.gov/corpfin/sample-letter-companies-regarding-crypto-asset- markets.
Please consider the issues identified in the sample letter as applicable to your facts and
circumstances and revise your disclosure accordingly.
Business
Prior Operations
Organizational History, page 1
6.We note your disclosure on page 1 that you are involved in digital wallet activities. Tell us
whether you intend to provide a service to safe-guard crypto-assets for your customers and
if you are therefore obligated to secure these crypto-assets and protect them from loss,
theft or other misuse.
7.Please expand this section to briefly describe the reverse merger transactions, including a
brief description of the business operations of United Heritage and Universa Hub Africa,
and the restructuring of your company following the reverse merger.
Present Operations, page 1
8.We note your disclosure on page 1 that you engage in "financial technology and
blockchain business worldwide" and that you build "tools to help people in accessing the
economy via mobile and digital services." Please disclose the types of applications or
tools you have built and are planning to build that assist people in this manner, including
disclosure regarding which of your applications or tools are or will be dependent on
blockchain technology and the risks and challenges related to such reliance. Disclose
whether you have or intend to build your own blockchain or whether you rely or intend to

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George Athanasiadis
Eco Bright Future, Inc.
June 11, 2024
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rely on an already existing blockchain. To the extent that you rely or intend to rely on an
already existing blockchain, please identify the blockchain. Further, please describe the
purpose of such applications or tools, whether they will relate only crypto assets you
create or also to third-party crypto assets. To the extent that you have already developed
such applications or tools, please disclose the geographic locations where each product
and service is currently offered and whether you offer or plan to offer such products and
services to U.S. persons. In this regard, we note your disclosure on page 5 that you intend
to "provide digital assets from El Salvador, tokenize assets and develop blockchain tools
for entry to countries such as Tunisia and United Arab Emirates and plan to enter into
agreements in connection with its blockchain products in Thailand, Indonesia, and
Guatemala." Please clarify what you mean by "digital assets from El Salvador," describe
the "blockchain tools" you are developing "for entry" to Tunisia and United Arab
Emirates and disclose the agreements you have or intend to enter into "in connection with
its blockchain products" in Thailand, Indonesia and Guatemala.
9.We note your disclosure on page 1 that "[y]our capital needs are between $5,000,000 and
$25,000,000 (varying based on growth strategies)" and your disclosure on page 2 that
such capital will need to be raised within the next two years. Please revise to disclose here
how you intend to raise such capital and disclose your growth strategies based upon the
different levels of capital raised.
10.We note your disclosure on page 1 that you are "involved in . . . digital wallet activities."
Please describe such "activities," including whether you currently offer or plan to offer
wallet services, the jurisdictions in which you offer or intend to offer wallet services,
whether your wallet services include taking custody of customer funds and, if so, your
security and custody arrangements related to the storage of customer funds, including
private keys and the risks that you may be liable for any cybersecurity breach resulting in
the loss of customer assets. In addition, please identify the crypto assets that your wallets
support or will support.
11.We note your disclosure on page 1 that you are "involved in . . . digital asset
tokenization." Please disclose the characteristics of the tokens, the rights of holders, how
the rights and characteristics of the token will be memorialized, the blockchain on which
the tokens exist, whether you have minted any such tokens to date, how such tokens are
issued and transferred, whether there are issuance and transfer restrictions, your
AML/KYC procedures, whether a transfer agent is used or will be used, and, if so, the role
of the transfer agent, whether the tokens may only be held in your wallet or whether the
tokens can be stored in third-party wallets and whether you will be tokenizing "real word
assets" yourself, how that process works, including how you will ensure parity between
the "real world assets" and their crypto asset equivalents, and whether you will own, store
and maintain such "real world assets." In this regard, we note your disclosure on page 1
related to your asset acquisitions. To the extent that you have acquired "real world assets"
that you have tokenized or intend to tokenize, please describe such "real world assets."

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 Comapany NameEco Bright Future, Inc.
 June 11, 2024 Page 4
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George Athanasiadis
Eco Bright Future, Inc.
June 11, 2024
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12.We note that you are building a platform that "enables everyone to access and participate
in the global economy and Real-World Assets(RWA) tokenization." Please revise to
include more specifics on your platform that is in development including, but not limited
to, if applicable, the blockchain on which the platform will run, an estimate of the timeline
for the launch of the platform and the activities that you plan to make available to users of
your platform and the jurisdictions in which your platform will operate.
13.We note your disclosure that your corporate offices are located in Florida and El Salvador,
that your main operations will be spread across Central America and Asia and that you
plan to "provide digital assets from El Salvador, tokenize assets and develop blockchain
tools for entry to countries such as Tunisia and United Arab Emirates and [that you] plan
to enter into agreements with . . . Thailand, Indonesia and Guatemala." Please describe the
laws and regulations that will have a material impact on your business, whether you are
required to obtain governmental licenses and authorizations in the jurisdictions in which
you intend to operate and offer your services and products and whether you have obtained
such governmental licenses and authorizations. In addition, describe the steps you have
taken or intend to take to prevent unauthorized or impermissible customer access to your
products and services outside of the jurisdictions in which you have obtained the
necessary licenses and authorizations to operate. Also describe the material risks you face
from such unauthorized or impermissible customer access to your products and services,
and expand the first risk factor on page 2 to describe the jurisdictions in which you are
currently seeking licensing and permission to tokenize "real world assets" and the impact
to your business if you are unable to obtain such licensing and permission as well as the
licensing and authorizations that you are currently seeking related to your other business
plans such as your platform and wallet services and the impact to your business if you fail
to obtain such licenses and authorizations.
14.We note your disclosure on page 1 that you engage in digital asset trading. Please disclose
the nature and extent of your crypto asset trading, including the types of crypto assets you
are trading, the platforms or applications you use to trade, your general trading strategy,
and whether you have any agreements with any such platforms for trading your crypto
assets. In addition, please disclose the crypto assets you hold as of the most recent
practicable date and your custody arrangements. To the extent that you use a third-party
custodian, please identify the custodian, describe the material terms of your agreement
with the custodian, how the custodian will store your private keys, including whether they
will be commingled with assets of other customers, the geographic location where the
private keys will be stored, whether any entity is responsible for verifying the existence of
your crypto assets and whether and to what extent the custodian carries insurance for any
losses of the crypto assets it custodies for you.
15.Please discuss what business consulting activities you conducted during the past couple of
years and whether such consulting services are anticipated to continue under your existing
business model. In this regard, we note your disclosure on page 18 regarding the

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June 11, 2024
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consulting revenue you recognized from consulting services related to blockchain
technology software development sales.
16.We note that you plan to carry on the business of one of your subsidiaries in the field of
artificial intelligence. Please revise to disclose how and to what extent you plan on
developing artificial intelligence as part of your business. Further disclose risks related to
artificial intelligence in the Risk Factors section.
Risk Factors, page 2
17.We note that you plan to associate your product with El Salvador, Tunisia, United Arab
Emirates, Thailand, Indonesia and Guatemala. Please revise to disclose risks related to
operating your product in these countries, including whether the regulatory regimes in
these countries will impair your ability to operate.
18.Please include risk factor disclosures related to your use of blockchain and crypto
technology, including, but not limited to, regulatory and technological risks. To the extent
that you utilize blockchain technology that exists today, please include specific risk
factors disclosures related to that technology.
The Real World Asset (RWA) Tokenization Market is Highly Competitive and Fragmented,
page 3
19.Please revise to disclose the risks associated with "real world asset" tokenization,
including, but not necessarily limited to, future government regulation limiting the scope
of activities available to generate revenue and technological difficulties.
Management's Discussion and Analysis of Financial Condition and Results of Operation
Business Operations, page 5
20.Please tell us, and revise your next amendment, to disclose more about your current and
planned operations. We note your disclosures on pages 1, 5, and 17 that you are, or plan to
be, involved in certain activities:
•p. 1 - "to build tools to help people in accessing the economy via mobile and digital
services";
•p. 1 - "you are involved in digital asset tokenization, digital asset trading, and digital
wallet activities";
•p. 1 - "the company is building an open source platform and developer infrastructure
which enables everyone to access and participate in the global economy and Real-
World Assets(RWA) tokenisation"; and
•p. 5 - "The Company intends to carry on the business of UHA as an artificial
intelligence and blockchain technology company that utilizes real world tokenization
to create a virtual investment vehicle on the blockchain linked to tangible assets such
as real estate, precious metals, art and collectibles. The Company intends to provide
digital assets from El Salvador, tokenize assets and develop blockchain tools for entry
to countries such as Tunisia and United Arab Emirates and plan to enter into

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 Comapany NameEco Bright Future, Inc.
 June 11, 2024 Page 6
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Eco Bright Future, Inc.
June 11, 2024
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agreements in connection with its blockchain products in Thailand, Indonesia, and
Guatemala."

Expand your MD&A to disclose which of these activities you are currently involved in
and which activities you intend to become involved in within the next 12 months.
21.Please revise your next amendment to break out the material components of general and
administrative expenses. Discuss any material trends between periods. Refer to Item
303(b)(2) of Regulation S-K.
22.Please revise your next amendment to discuss the material items within Other Income
(Expenses) - interest expense, other expenses, other income and impairment
expense. Discuss any material trends between periods. Refer to Item 303(b)(2) of
Regulation S-K.
Directors and Executive Officers, page 8
23.We note that you indicate that Mr. Athanasi