SecProbe.io

October 4, 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.
Amendment No. 4 to Registration Statement on Form 10
Filed September 4, 2024
Form 10-Q for the Fiscal Quarter Ended June 30, 2024
Filed August 13, 2024
File No. 000-56658
Dear George Athanasiadis:
            We have reviewed your filings 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.
Amendment No. 4 to Registration Statement on Form 10
General
1.We note your response to prior comment 1. Please revise your registration statement to
include a description of the processes you have in place for determining whether your
products are "securities" within the meaning of Section 2(a)(1) of the Securities Act. For
instance, disclose who makes that determination, whether legal counsel is consulted and
whether you plan to re-evaluate your products on a periodic basis. Based on
these processes, please expand your related risk factor to have a more fulsome discussion
of the risks and limitations of your review process.
We note your response to prior comments 3 and 13. Please revise your registration
statement to make the disclosures we previously requested, including:
the details and development status of the platforms and services that you plan to offer •2.

October 4, 2024
Page 2
in the UAE, El Salvador, Thailand, Indonesia and Guatemala, including a detailed
timeline of the remaining steps in the development of the platforms and services, the
estimated costs of each step and the sources of funding for each of these steps;
•the material terms of your material contracts in El Salvador and any other
jurisdictions and identify the parties to those contracts;
•a clarification as to the term "back end programming" that you use on page 4; and
•for each jurisdiction in which you plan to operate, a description of the licensing
application process, including an estimate of the time it will take you to obtain the
necessary licenses to operate in the UAE, Thailand and El Salvador, and tell us why
you believe that your operations in other countries will make your ability to operate in
Indonesia and Guatemala more likely.
3.We note your response to prior comment 4. Please add a section that describes the laws
and regulations that have or will have a material impact on your business in El Salvador,
Thailand, Indonesia, Guatemala, the UAE, Tunisia and any other jurisdictions material to
your business or business plans, including a detailed description of the approvals and
licensing requirements for each. For example, we note your revised disclosure on page 13
that "Guatemala is more established with their policies than many other countries in
regards to how they treat crypto asset markets but is still evolving and regulations are
being changed often" but you have not added a section that describes the regulations or
pending regulations in Guatemala that will impact your business operations.
Prior Operations
Organizational History, page 2
4.We note your response to prior comment 7. Your disclosure on page 2 that the Universa
Blockchain is a public blockchain that is available to the public appears to be inconsistent
with your disclosure that the Universa Blockchain is owned by Universa Hub Africa
and that is permissioned by Universa Hub Africa to the Tunisian Government and your
statement in your September 4, 2024 correspondence that Universa Blockchain is the . . .
blockchain that you have used as a private blockchain for Tunisia as well as your
description of your business throughout in which it appears that you offer blockchain-as-
a-service to corporations and governments. Please revise for clarity and consistency. In
addition, please revise to disclose the material terms of your agreement with the Tunisian
Government for the private blockchain.
We note your revised disclosure on pages 2 and 3 regarding your agreement with the
Internet Agency of Tunisia for the National Tunisian Blockchain Network. Please
describe the material terms of the agreement, including your obligations in connection
with the agreement, how you earn revenues pursuant to the agreement and the termination
provisions of the agreement. Expand your description of National Blockchain Network to
describe the platform, your role in the platform, including the blockchain services you
provide, the mechanics of how a user gains access to the platform and utilizes the
platform to develop its business such as the certified digital signature service provider you
describe in your registration statement, the "latest technological developments of Universa
Blockchain" and your role regarding "future integrations." In addition, we note your
disclosure on page 3 that "[t]he next key points of the project are planned to be the launch
of a national DNS service on top of blockchain, a decentrali[z]ed identity system, 5.

October 4, 2024
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blockchain web services and several other services” and that “this is expected sometime
between September 2020 and January 2021." Please update your disclosure to state
whether these services were "launched" and describe the decentralized identity system and
any other services that have launched or that you plan to develop. Finally, you state that
the "[f]uture planned developments are oriented towards Smart Cities, e-government and
citizen-oriented services." Please briefly describe each of these planned developments and
disclose whether you have signed agreements with any parties in relation to these planned
developments.
6.We note your disclosure that in December 2023 you completed a reverse merger with
Universa Hub Africa, a Tunisian Corporation. However, we have seen media reports,
including the one you cite in your registration statement on page 2, that describes the
Universa Hub Africa's platform as a "Russian platform." Please revise to clarify the
jurisdictions in which your subsidiaries are located and the jurisdictions in which you
operate.
7.Please tell us the basis for your statement on page 2 that your blockchain is one of the
fastest and most secure blockchains in the world. Alternatively, please remove this
statement.
Present Operations, page 3
8.We note your response to prior comment 5 and that you expect to earn revenue from users
of your open-source platform because "there will also be blockchain transaction fees that
will be paid to the Universa Blockchain for verification of transactions." If your platform
is open source, will entities that use a version of your technology be able to remove or
change this transaction fee requirement such that Universa Blockchain does not receive
any revenue? If so, please disclose this and if not, please explain how this is possible with
an open-source platform.
9.We note your response to prior comment 6, your description of DMCC Tradeflow and
your statement that your sugar exchange tokenizes DMCC paper warrants. Please revise
your disclosure to describe the testing of your digital sugar exchange with DMCC
Tradeflow and the results of the test. Please also clarify what you mean by the
tokenization of the DMCC “paper warrants” as you disclose that the DMCC creates
electronic negotiable instruments (the “DMCC Tradeflow Warrants”) and that the DMCC
Tradeflow Warrants are electronically transferred between users using a web-based
interface. In addition, please expand your disclosure to explain how your platform and the
DMCC work together to prevent issues like double spending, and  include disclosure
regarding (i) the mechanics of how the tokens are exchanged on your blockchain and
platform, (ii) a description of the information provided on your platform, and (iii) a
detailed description of the tokenized Sugar Warrants that addresses the risks and
characteristics of the Sugar Warrants and the rights of the Sugar Warrant holders. In
addition, your June 18, 2024 correspondence states that you "issued a Digital Sugar
Warrant for the same volume secured by a paper warrant." Please tell us what you mean
by this statement. Also, we note your disclosure that you have not yet applied for
licensing in the UAE and that you do not have any contracts in place with the UAE.
Please clarify whether to operate the sugar exchange in the UAE you will need to obtain a
license and execute agreements with DMCC Tradeflow.

October 4, 2024
Page 4
10.We note your response to prior comment 7. Please revise your disclosure to include a
description of the Universa Blockchain, including, but not necessarily limited to, whether
it is public or permissioned, the consensus mechanism used by the blockchain, the number
of transactions that the blockchain can accommodate per minute, the types of crypto
assets that can be created and transferred on the blockchain and how changes are made to
the blockchain.
11.We note your response to prior comment 10. Please revise to disclose the material terms
of your agreement with the Bank of Abu Dhabi and the DMCC related to the gold
tokenization, describe the wallets you will offer and whether you will hold the private
keys for such wallets. If you will hold the private keys for such wallets, disclose whether
you will use a third-party custodian for the private keys and whether these will be stored
in cold or hot storage, disclose how an end-user could prove ownership without the token
and how discrepancies between the blockchain and other proofs of ownership are
resolved. Additionally, please explain whether the gold bar tokens will be able to be split
by users and traded in a manner such that less than one gold bar is changing hands at a
time. If so, please explain how redemption of the underlying gold bar would function.
12.We note your response to prior comment 11 and the role that SumSub plays in your KYC
and AML process. Please revise your registration statement to include a risk factor that
discusses the material risks you face from unauthorized or impermissible customer access
to your products and services by those who circumvent your KYC and AML process. In
addition, we note your disclosures on page 4, 14 and 50 that "[i]t is currently planned to
not accept clients from certain jurisdictions," that "[t]hese jurisdictions include the United
States of America and European Union countries" and that "[t]he KYC process will not
allow individuals with passports from these jurisdictions to use [y]our services." Please
revise your disclosure to clarify what you mean by "clients." For example, clarify whether
you are you referring to the "large corporate and government customers" for whom you
intend to create infrastructure solutions or if you are referring to individuals who may
wish to utilize your platform or purchase crypto assets using the blockchain services you
provide. Finally, please expand your disclosure to clarify how you will restrict U.S.
persons given that you are "building an open- source platform and developer
infrastructure which enables everyone to access and participate in the global economy and
Real-World Assets (RWA) tokenization.”
13.We note your response to prior comment 12. Your disclosure on page 3 that you are
involved in "digital asset trading" is inconsistent with your revised disclosure on page 3
that "[t]he company is does not engage in crypto asset trading." Please revise for clarity
and consistency.
We note your response to prior comment 15. Please revise your registration statement to
include the information you provided in your September 4, 2024 response, including the
status of your plans for the AI service. In this regard, we note you state that a substantial
amount of the code is written for your AI platform. If known, please describe how the AI
platform will operate, the estimated costs of advertising the platform and integrating the
reservation systems to your blockchain as well as any other costs associated with offering
this product, the mechanics of how users can make hotel and restaurant reservations
"directly from their wallet" and how you intend to earn revenues from this product. To the
 14.

October 4, 2024
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extent that you have not yet finalized your plans for how the AI platform will function,
please disclose.
Risk Factors, page 8
15.We note your response to prior comment 16 and your updated risk factors. For each
jurisdiction you plan to operate in, please identify the regulations and material pending
regulations that will impact your business and describe the material effects each such
regulation and pending regulation may have on your business and business plans. In this
regard, we note that you refer generally to the existence of rules and regulations
in each jurisdiction but do not address specific regulations or pending regulations. In
addition, please revise your "Blockchain Technology carries with is certain risks and
compliance issues" risk factor on page 13 to expand your description of the "[f]raudulent
activities and 'hacking wallets'" by providing specific examples of such fraudulent
activities and an explanation of what 'hacking wallets' means.
We have a potential requirement to register, page 11
16.We note your response to prior comment 17. Please be advised that the Howey  test is
not the determinative test as it relates to whether you meet the definition of an
"investment company" for purposes of the Investment Company Act of 1940. As such,
please provide to us an analysis of why you believe you may meet the definition of an
"investment company" in the future, and revise this risk factor to include a summary of
the reasons you identify in the analysis.
Financial Information
Management's Discussion and Analysis of Financial Condition and Results of Operation, page 14
17.Please revise your next amendment to include a discussion of the results of operations for
the three and six month periods ended June 30, 2024. Refer to Item 303 of Regulation S-
K.
18.You disclose on page 15 that the insurance on the gold in your agreement with the Bank
of Abu Dhabi is held by the bank and the government of the UAE, and we note your
response to prior comment 10 stating that the insurance would not be liable if an end user
could not prove ownership of a token. Please describe for us your liability in the event of
a security breach on your blockchain or if an end user could not prove ownership of a
token.
19.Please tell us the native token for your blockchain. Further, tell us the value of the Real
World Assets, such as under your sugar or gold tokenization agreements, you have
tokenized on your blockchain.
20.Please tell us how you recognize the blockchain in your financial statements, and whether
you consolidate the blockchain and related activities.
Business Operations, page 14
We note your response to prior comment 9. Your disclosure on page 14 that the tools you
are developing will allow integration to other blockchains is inconsistent with your
revised disclosure that you have no plans to implement other blockchains within your
ecosystem. Please revise for clarity and consistency. Similarly, your disclosure that you 21.

October 4, 2024
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have not finalized the open-source options that will allow integration into other wallets
appears to be inconsistent with your disclosure that "[y]our blockchain can be used with
other developed wallets." Please revise for clarity and consistency. In addition, please
disclose the "open-source options" you have not yet completed and describe the wallets
that you offer and intend offer to users of the platform, including whether you maintain
the private keys, and, if so, whether you use a third