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E:  Mmendel@bevilacquapllc.com

T: 202.869.0888

W: bevilacquapllc.com

March 8, 2024

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and Services

100 F Street, N.E.

Washington, DC. 20549

 Attn: Jeanne Bennett

Michael Fay

Juan Grana

Lauren Nguyen

 Re: CleanCore Solutions, Inc.

Amendment No. 3 to Registration Statement
on Form S-1

Filed February 23, 2023

File No. 333-274928

Ladies and Gentlemen:

We hereby submit the responses of CleanCore Solutions,
Inc. (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “SEC”) set forth in the Staff’s letter, dated March 6, 2024, providing the Staff’s comments
with respect to the Company’s Registration Statement on Form S-1 (as amended, the “Registration Statement”).

For the convenience of the Staff, each of the
Staff’s comments is included and is followed by the corresponding response of the Company.  Unless the context indicates
otherwise, references in this letter to “we,” “us” and “our” refer to the Company on a consolidated
basis.

Amendment No. 3 to Registration Statement on Form S-1 filed February
23, 2023

Management's Discussion and Analysis of Financial Condition and Results of Operations

Comparison of Six Months Ended December 31, 2023 and 2022, page
35

 1. We note your decrease in revenue of 56.79% was
                                            primarily due to decreases in the volume of products sold to your largest customers, due
                                            to external factors that impacted their number of purchases, offset by increases in product
                                            prices. We also note this decrease was larger than the 35.2% first quarter decline in revenues.
                                            Please revise your disclosure to fully describe in further detail the external factors that
                                            impacted the number of purchases made by your largest customers. Please separately discuss
                                            your largest customers. In this regard, for example, we note in your discussion of full year
                                            2023 compared to full year 2022 a reference to the insolvency of a distributor that accounted
                                            for 10% of total revenue.

Response: We have revised the
Registration Statement in accordance with the Staff’s comment.

1050 Connecticut Ave., NW, Suite 500

Washington, DC 20036

    PG. 2

    March 8, 2024

 2. We note increases in product prices had a significant
                                            impact on gross margin, increasing from 27.30% to 51.32%. Please revise your disclosure to
                                            discuss in further detail the increase in prices given the significant impact. For example,
                                            identify the specific products that experienced a price increase, the timing of the price
                                            increases, and the approximate percentage of the price increases. In addition, please revise
                                            your disclosure to separately quantify the impact to revenue from the decrease in volume
                                            versus the increase in prices.

Response: We have revised the
Registration Statement in accordance with the Staff’s comment.

 3. You disclose, in part, for the six months
                                            ended December 31, 2023, our net loss of $782,093 and a decrease in inventory of $91,874
                                            [...] were the primary drivers of net cash used in operating activities. We note, however,
                                            that inventory increased during that period. Please correct your reference and also describe
                                            the reason for the increase in inventory. In addition, we note inventory is almost 50% of
                                            total current assets and there is greater than one year's worth of inventory based upon the
                                            amount of cost of sales for the most recent interim period. Please discuss the approximate
                                            duration it will take you to use the $506,248 in parts and $250,698 in finished goods as
                                            of December 31, 2023.

Response: We have revised the
Registration Statement in accordance with the Staff’s comment.

Principal Stockholders, page 63

 4. We note your disclosure that Mr. Clayton
                                            Adams has the right to acquire 2,000,000 shares of Class A Common Stock within 60 days through
                                            the exercise of vested stock options, which would result in Mr. Adams owning 93.02% of the
                                            Class A Common Stock and 55.34% of total voting power in the company prior to the offering.
                                            Please revise your disclosure throughout the registration statement to note that while Mr.
                                            Atkinson currently owns 100% of the Class A Common Stock outstanding and will control approximately
                                            64% of the total voting power of the company post-offering, Mr. Adams would control approximately
                                            63% of the company's Class A Common Stock and 54% of the voting control of the company post-offering
                                            if he were to exercise his vested stock options.

Response: We have revised the
Registration Statement in accordance with the Staff’s comment.

    PG. 3

    March 8, 2024

If you would like to discuss any of our responses to the Staff’s
comments or if you would like to discuss any other matters, please contact Mariya Mendel of Bevilacqua PLLC at (202) 571-4785, or Douglas
Moore, at (804) 317-5898.

    Sincerely,

    By:
    /s/ Mariya Mendel

    Mariya Mendel

    Bevilacqua PLLC

 cc: Douglas T. Moore, CleanCore Solutions, Inc.

Louis A. Bevilacqua, Esq.