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    Reply
                           to:

                          Direct
                          Tel:

                          Email:

                          File No:

  Virgil Hlus
 604.891.7707
 VHlus@cwilson.com

  51179-0001

July
18, 2024

VIA
email

United
States Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

Attention: Division
                                            of Corporation Finance

                                            Office of Manufacturing

Dear
Sirs/Mesdames:

    Re:
    Yerbaé
    Brands Corp. (“Yerbaé” or the “Company”) – File No. 000-56654

    Registration Statement of Form 10-12G

    Filed July 2, 2024

    Response to Second Comment Letter dated July 11, 2024

We
write in response to your comment letter dated July 11, 2024. For ease of reference, the Company’s responses are numbered in a
manner that corresponds with your comments. All defined terms used but otherwise note defined herein shall have the meanings ascribed
thereto in the Form 10 – General Form for Registration of Securities Pursuant to Section 12(b) or 12(g) of the Securities Exchange
Act of 1934 of the Company filed on July 2, 2024 (the “Form 10”).

Summary
Compensation Table and Compensation of Directors, page 40

1. Please
                                            revise these sections so that the summary compensation table and the compensation of directors
                                            table are in text format, rather than as an image.

Response:

The
Form 10 has been revised such that that the summary compensation table and the compensation of directors table are in text format.

Report
of Independent Registered Public Accounting Firm, page F-1

2. Please
                                            obtain and include in your next amendment, a signed and dated audit opinion from your independent
                                            registered public accounting firm.

Response:

The
Form 10 has been revised to include a signed and dated audit opinion from the Company’s independent registered public accounting
firm.

Exhibits

3. Please
                                            refile prior exhibits 10.11 Director Services Agreement with Rose Zanic, 10.12 Director Services
                                            Agreement with Andrew Dratt, and 10.13 Director Services Agreement with Maruf Raza pursuant
                                            to Item 601(b)(10) of Regulation S-K, or advise us why you are not required to do so.

Response:

 The
Form 10 has been revised refiling exhibits 10.11 Director Services Agreement with Andrew Dratt, 10.12 Director Services Agreement with
Maruf Raza, and 10.13 Director Services Agreement with Rose Zanic pursuant to Item 601(b)(10) of Regulation S-K.

General

4. Your
                                            registration statement will become effective 60 days after you filed it with the Commission
                                            and you will then be responsible for filing reports required by the Securities Exchange Act
                                            of 1934, including the requirements to file Forms 10-K, 10-Q, and 8-K even if we have not
                                            completed the review of your filing. If you cannot resolve the comments before that time,
                                            you should consider withdrawing the filing before it becomes effective. You could then refile
                                            when you are able to respond to the comments.

Response:

Duly
noted.

We
trust you will find the foregoing to be in good order. Please do not hesitate to contact the undersigned if you require any further information.

  Yours truly,

  CLARK WILSON LLP

  Per: “Virgil Hlus”

  Virgil Hlus

  VZH

Encl.

  cc:
  Todd Gibson

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