SecProbe.io

CORRESP
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filename1.htm

Reagan
Bosco International Company, Inc.

1800
2nd Street, Suite 603

Sarasota,
FL 34236

October
5, 2023

Division
of Corporation Finance

Office
of Real Estate & Construction

U.S.
Securities and Exchange Commission

Washington,
D.C. 20549

    Attn:
    Mr.
    Kibum Park

    Mr.
    Jeffrey Gabor

    Re:
    Reagan
    Bosco International Company, Inc.

    Registration
    Statement on Form S-1

    Filed
    September 27, 2023

    File
    No. 333-274718

Ladies
and Gentlemen:

We
are hereby transmitting the response of Reagan Bosco International Company, Inc., a Nevada corporation (the “Company,”
“we,” or “our”), to the comment letter we received from the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) on October 4, 2023, regarding the Registration
Statement on Form S-1, as submitted to the Commission on September 27, 2023 (the “Registration Statement”).
An amendment to the Registration Statement is being submitted to the Commission concurrently with this letter.

For
your convenience, we have repeated below the comments of the Staff in bold and have followed the Staff’s comments with the Company’s
response.

Registration
Statement on Form S-1 Filed September 27, 2023

Dilution,
page 12

    1.
    We
                                            note your response to prior comment 1. Please include a table comparing the public contribution
                                            under the proposed public offering and the effective cash cost to officers, directors,
                                            promoters and affiliated persons of common equity acquired by them in transactions since
                                            inception. Include columns for the number and percent of shares purchased; amount
                                            and percent of total consideration; and the average price per share for existing shareholders
                                            versus new investors. Refer to Item 506 of Regulation S-K.

Response:
The Company has added the table at page 12 in the “Dilution” section in response to the Staff’s comment.

We
thank the Staff in advance for its review of our Registration Statement. Should you have no further comments following your review, pursuant
to Rule 461 of the Securities Act, as amended, we kindly request acceleration of effectiveness so that the Registration Statement may
be declared effective at 4:30 pm on October 9, 2023, or as soon thereafter as reasonably practical.

The
Company acknowledges the following:

    ●
    should
                                                                                                                                   the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the
                                                                                                                                   Commission from taking any action with respect to the filing;

     ●
    the
action of the Commission or the staff, acting pursuant to delegated authority in declaring the filing effective, does not relieve
the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

     ●
    the
                                                                                                                                   Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the
                                                                                                                                   Commission or any person under the federal securities laws of the

    United
    States.

Should
you have any questions or concerns, please kindly contact our counsel Stephen Weiss, Esq. by telephone at (917) 797-0015 of Michelman
& Robinson, LLP. If you are able to take the Registration Statement effective on Monday, October 9, 2023, we kindly request that
you contact Mr. Weiss upon effectiveness.

    Sincerely,

    /s/
    Timothy Spell

    Timothy
    Spell

    Chief
    Executive Officer

    Reagan
    Bosco International Company, Inc.