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    BARNETT
    & LINN

    ATTORNEYS
    AT LAW

    60 Kavenish Drive
    ● Rancho Mirage, CA 92270

    www.barnettandlinn.com

    WILLIAM B. BARNETT

    TELEPHONE:
    442-474-7571

    Attorney/Principal

    wbarnett@wbarnettlaw.com

September
25, 2023

Division
of Corporation Finance

Office
of technology

Securities
and Exchange Commission

100
F Street NE

Washington
D.C. 20549

    Attn:
    Stephen
    Krikorian, Accounting Branch Chief

    Becky
    Chow, Senior Staff Accountant

    Austin
    Pattan, Staff Attorney

    Jeff
    Kauten, Staff Attorney

    Re:
    Eva
    Live Inc. (“Registrant” and/or “Company”)

    Amendment
    No. 2 to Registration Statement on Form S-1

    Filed
    on July 7, 2023

    File
    No. 333-273162

Gentlemen:

The
Registrant hereby files its Amendment No. 2 to Registration Statement on Form S-1 (“Amendment No. 2”). The Amendment No.
2 has been revised in accordance with the Commission’s comment letter dated August 25, 2023 (“Comment Letter”). To
assist the staff in its review of Registrant’s responses, we have provided a copy of Amendment No.2 “marked to show changes”,
and our responses below correspond to each comment number in the Comment Letter.

Registration
Statement on Form S-1 filed on July 7, 2023

Risks
Factors, page 6

1.
In accordance with your comment we have added a Rick Factor-”We derive a substantial portion of our revenues….Page 8”.

We
have a limited history of operations…. Page 7

2.
In accordance with your comment, we have revised the Risk Factor to acknowledge limited revenues.

Management’s
discussion and analysis of financial condition and results of operations, page 11

3.
& 4. In accordance with your comment we have substantially revised this entire section to disclose each metric provided and which
is non-GAAP and the reconciliation to comparable GAAP financial measures.

Financial
Statements, page F-1

5.
In accordance with your comment we have updated all financial statements through June 30, 2023.

Consolidated
Balance Sheets, page F-4

6.
In regard to your comment we have eliminated the dash (-).

Consolidated
Statements of Cash Flows, page F-7

7.
In accordance with your comments we substantially revised this section and have tried to reflect properly the non-cash activities to
be consistent with ACS 230-10-50-3 to 50-6.

Note
1. Business Description and Nature of Operations

EvaMedia
Corp. Acquisition, page F-8

8.
In accordance with your comment we have substantially revised this section to provide a detailed analysis to be consistent with ASC 805-10
to 55-15. We have restated the financial statements per ASC 805 analysis and provided a detailed explanation under Note 1 (F-8) and Note
2 (pages F-11, F-12, and F-13).

Revenue
recognition policy, , page F-13

9.
In accordance with your comment we have added disclosure regarding disaggregated revenues consistent with ASC 606-10-55-89 through 55-91
under Revenue Recognition Policy (page F-16).

Website
and Software Development Costs, page F.16

10.
In accordance with your comment we have added disclosure to clarify customer rights consistent with the requirements of ASC 985-20-15-5
(page F-19).

We
believe that we have responded to all your comments fairly and reasonably. Please do not hesitate to contact the undersigned as soon
as possible should you have any further questions or comments.

Thank
you for your cooperation and courtesies in this matter.

    Very
    truly yours,

    Barnett
    & Linn

    William B. Barnett

WBB:
lg

cc/
Mr. D. Boulette, CEO