SecProbe.io

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 20/20 Biolabs, Inc.

 15810 Gaither Road, Suite 235

 Gaithersburg, MD 20877

 April 8, 2026

 U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC. 20549
Attn: Robert Augustin

 Re:
 20/20 Biolabs, Inc.

 Registration Statement on Form S-1 (File No. 333-294903)

 Ladies and Gentlemen,

 Pursuant to Rule 461 under the Securities Act
of 1933, as amended, 20/20 Biolabs, Inc. hereby respectfully requests that the Securities and Exchange Commission accelerate the effectiveness
of the above-referenced Registration Statement on Form S-1 (the "Registration Statement") and declare the Registration Statement
effective at 5:00 p.m. (Eastern Time) on Friday, April 10, 2026, or as soon thereafter as practicable.

 It would
be appreciated if, as soon as the Registration Statement is declared effective, you would so inform Louis A. Bevilacqua of Bevilacqua
PLLC at (202) 869-0888, ext. 100 .

 Respectfully,

 20/20 Biolabs, Inc.

 By:
 /s/ Jonathan Cohen

 Jonathan Cohen

 Chief Executive Officer

 cc: Louis A. Bevilacqua, Esq.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
                                                           April 8, 2026

Jonathan Cohen
Chief Executive Officer
20/20 Biolabs, Inc.
15810 Gaither Road
Suite 235
Gaithersburg, MD 20877

       Re: 20/20 Biolabs, Inc.
           Registration Statement on Form S-1
           Filed April 6, 2026
           File No. 333-294903
Dear Jonathan Cohen:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

       Please contact Robert Augustin at 202-551-8483 with any questions.

                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and Services
cc:    Louis A. Bevilacqua, Esq.
</TEXT>
</DOCUMENT>

United States securities and exchange commission logo
July 15, 2020
Jonathan Cohen
Chief Executive Officer and President
20/20 GeneSystems, Inc.
9430 Key West Ave.
Rockville, MD 20850
Re:20/20 GeneSystems, Inc.
Offering Statement on Form 1-A
Post-Qualification Amendment No. 1
Filed July 8, 2020
File No. 024-11056
Dear Mr. Cohen:
            We have reviewed your amendment and do not have any comments.
            We will consider qualifying your offering statement at your request.  If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Cara Wirth at (202) 551-7127 or Erin Jaskot at (202) 551-3442 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Louis A. Bevilacqua, Esq.

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20/20 GeneSystems, Inc.

9430 Key West Ave.

Rockville, MD 20850

July 15, 2020

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn: Cara Wirth

    Re:
    20/20 GeneSystems, Inc.

    Offering Statement on Form 1-A

    Post-Qualification Amendment No. 1

    Filed July 8, 2020

    File No. 024-11056

Dear Ms. Wirth:

We understand that the staff of the U.S. Securities
and Exchange Commission (the “Commission”) has completed its review of the Post-Qualification Amendment No. 1 to Offering
Statement on Form 1-A (the “Offering Statement”) of 20/20 GeneSystems, Inc. (the “Company”) and we hereby
request that the Commission approve the qualification of the Offering Statement as of 4:00 PM Eastern Time on Friday, July 17,
2020.

We request that we be notified of such qualification
by a telephone call to Mr. Louis A. Bevilacqua at (202) 869-0888 ext. 100. We also respectfully request that a copy of the written
order from the Commission verifying the date and time of qualification of the Company’s Offering Statement be sent to Louis
A. Bevilacqua via email at lou@bevilacquapllc.com

    Sincerely,

    20/20 GeneSystems, Inc.

    By:
    /s/ Jonathan Cohen

    Jonathan Cohen

    Chief Executive Officer

 cc: Louis A. Bevilacqua, Esq.

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20/20 GeneSystems, Inc.

9430 Key West Ave.

Rockville, MD 20850

January 6, 2020

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn: Ronald (Ron) Alper

    Re:
    20/20 GeneSystems, Inc.

Offering Statement on Form 1-A

File No. 024-11056

Dear Sir:

We understand that the staff of the U.S. Securities
and Exchange Commission (the “Commission”) has completed its review of the Offering Statement on Form 1-A (the “Offering
Statement”) of 20/20 GeneSystems, Inc. (the “Company”) and we hereby request that the Commission approve the
qualification of the Offering Statement as of 4:00 PM Eastern Standard Time on Wednesday, January 8, 2020.

We request that we be notified of such qualification
by a telephone call to Mr. Louis A. Bevilacqua at (202) 869-0888 ext. 100. We also respectfully request that a copy of the written
order from the Commission verifying the date and time of qualification of the Company’s Offering Statement be sent to Louis
A. Bevilacqua via email at lou@bevilacquapllc.com

Sincerely,

20/20 GeneSystems, Inc.

By: /s/ Jonathan Cohen

Jonathan Cohen

Chief Executive Officer

cc: Louis A. Bevilacqua, Esq.

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20/20 GeneSystems, Inc.

9430 Key West Ave.

Rockville, MD 20850

December 31, 2019

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC. 20549

Attn: Ronald (Ron) Alper

    Re:
    20/20 GeneSystems, Inc.

    Amendment No. 2 to Preliminary Offering Statement on Form 1-A

    Filed November 26, 2019

    File No. 024-11056

Dear Sir:

We hereby submit the responses of 20/20
GeneSystems, Inc. (the “Company”) to the comments of the staff (the “Staff”) of the U.S.
Securities and Exchange Commission set forth in the Staff’s letter, dated December 11, 2019, providing the Staff’s
comments with respect to the Company’s Amendment No. 2 to Offering Statement on Form 1-A (as amended, the “Offering
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. 2 to Preliminary Offering
Statement on Form 1-A

Exhibits

 1. We note the subscription agreement includes a fee shifting provision
in Section 9. Please expand your disclosure to specify the types of actions subject to fee shifting and whether the provision is
intended to apply to claims under the federal securities laws. Please also disclose whether purchasers of shares in a secondary
transaction would be subject to these provisions. Please also clarify the level of recovery required by the plaintiff to avoid
payment. Lastly, please specify who is subject to the provision and who is allowed to recover under the provision. Please include
risk factor disclosure regarding the risk that the fee shifting provision could discourage shareholder lawsuits that might otherwise
benefit the company and its shareholders.

Response:
We have revised the subscription agreement to remove the fee shifting provision contained in Section 9.

If you would like to
discuss any of the responses to the Staff’s comments or if you would like to discuss any other matters, please contact the
undersigned at (240) 453-6339 or Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    20/20 GeneSystems, Inc.

    By:
    /s/ Jonathan Cohen

    Jonathan Cohen

    Chief Executive Officer

 cc: Louis A. Bevilacqua, Esq.

December 11, 2019
Jonathan Cohen
Chief Executive Officer
20/20 GeneSystems, Inc.
9430 Key West Ave.
Rockville, MD 20850
Re:20/20 GeneSystems, Inc.
Amendment No. 2 to Preliminary Offering Statement on Form 1-A
Filed November 26, 2019
File No. 024-11056
Dear Mr. Cohen:
            We have reviewed your amended offering statement and have the following comment.
            Please respond to this letter by amending your offering statement and providing the
requested information.  If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your offering statement and the information you
provide in response to this comment, we may have additional comments.
Amendment No. 2 to Preliminary Offering Statement on Form 1-A
Exhibits
1.We note the subscription agreement includes a fee shifting provision in Section 9.  Please
expand your disclosure to specify the types of actions subject to fee shifting and whether
the provision is intended to apply to claims under the federal securities laws.  Please also
disclose whether purchasers of shares in a secondary transaction would be subject to these
provisions.  Please also clarify the level of recovery required by the plaintiff to avoid
payment.  Lastly, please specify who is subject to the provision and who is allowed to
recover under the provision.  Please include risk factor disclosure regarding the risk that
the fee shifting provision could discourage shareholder lawsuits that might otherwise
benefit the company and its shareholders.

 FirstName LastNameJonathan Cohen
 Comapany Name20/20 GeneSystems, Inc.
 December 11, 2019 Page 2
 FirstName LastName
Jonathan Cohen
20/20 GeneSystems, Inc.
December 11, 2019
Page 2
            Please contact Ronald (Ron) Alper at 202-551-3329 or James Lopez at 202-551-3536
with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Louis A. Bevilacqua

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20/20 GeneSystems, Inc.

9430 Key West Ave.

Rockville, MD 20850

November 12, 2019

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC. 20549

Attn: Ronald (Ron) Alper

 Re: 20/20 GeneSystems, Inc.

Offering Statement on Form 1-A

Filed August 12, 2019

File No. 024-11056

Dear Sir:

We hereby submit the responses of 20/20
GeneSystems, Inc. (the “Company”) to the comments of the staff (the “Staff”) of the U.S.
Securities and Exchange Commission set forth in the Staff’s letter, dated September 4, 2019, providing the Staff’s
comments with respect to the Company’s Offering Statement on Form 1-A (as amended, the “Offering 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.

Offering Statement on Form 1-A filed
on August 12, 2019

Summary

The Offering

Proposed listing, page 5

 1. We note the subheading “Commercialization Milestones to
Execute our Growth Strategy” and related disclosure was removed from page 31, including milestone assumptions about “financing
goals” and numbers of participating physician practices and weekly cancer tests (combined “120 tests per week total”).
Please provide updated disclosure regarding your commercialization milestones.

We also
note the disclosure regarding the initial commercialization of OneTest in the second half of 2018 and the statement on page 2 that
you have received orders for 300 individual tests. Please revise your discussion of revenues, trends and uncertainties in Management’s
Discussion and Analysis to address the extent to which OneTest, in addition to BioCheck and PAULA’s test, contribute to and/or
present material trends or uncertainties regarding your operations and liquidity.

Response:
We have revised the Offering Statement to provide updated disclosure regarding our commercial milestones. With respect to OneTest,
we respectively note that the Company’s disclosure states that it “began focusing on the commercialization of OneTest”
in the second half of 2018. The Company did not begin generating revenues from OneTest until 2019. However, since we have revised
the Offering Statement to include our interim financial statements for the six months ended June 30, 2019 and 2018, we have revised
our disclosure in Management’s Discussion and Analysis to include a discussion of OneTest.

Management’s Discussion and Analysis
of Financial Condition and Results of Operations, page 34

 2. We note your disclosure related to your sources of revenue, and
your response letter dated June 22, 2018. Your website still states that BioCheck “generates revenues of about $500,000 per
year with Gross Profit margins of about 80%.” It also still states that the company has brought in approximately $7.5 million
“through numerous government and private grants.” Please advise us how these statements reconcile with the disclosure
in the Form 1-A, and, as necessary, enhance your disclosure to more specifically address how the company earns revenue from grants
and sales of BioCheck and other services.

Response:
We have removed such information from our website, which was incorrect. The information in the Form 1-A is correct and, therefore,
requires no further revision.

U.S. Securities and Exchange Commission

November 12, 2019

Page 2

If you would like to
discuss any of the responses to the Staff’s comments or if you would like to discuss any other matters, please contact the
undersigned at (240) 453-6339 or Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    20/20 GeneSystems, Inc.

    By:
    /s/ Jonathan Cohen

    Jonathan Cohen

    Chief Executive Officer

 cc: Louis A. Bevilacqua, Esq.

September 4, 2019
Jonathan Cohen
Chief Executive Officer
20/20 GeneSystems, Inc.
9430 Key West Ave.
Rockville, MD 20850
Re:20/20 GeneSystems, Inc.
Offering Statement on Form 1-A
Filed August 12, 2019
File No. 024-11056
Dear Mr. Cohen:
            We have reviewed your offering statement and have the following comments.  In some of
our comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to this letter by amending your offering statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.  After reviewing any amendment to your offering statement and the information you
provide in response to these comments, we may have additional comments.
Offering Statement on Form 1-A Filed August 12, 2019
Summary
The Offering
Proposed listing, page 5
1.We note the subheading "Commercialization Milestones to Execute our Growth Strategy"
and related disclosure was removed from page 31, including milestone assumptions about
"financing goals" and numbers of participating physician practices and weekly cancer
tests (combined "120 tests per week total").  Please provide updated disclosure regarding
your commercialization milestones.

 FirstName LastNameJonathan Cohen
 Comapany Name20/20 GeneSystems, Inc.
 September 4, 2019 Page 2
 FirstName LastName
Jonathan Cohen
20/20 GeneSystems, Inc.
September 4, 2019
Page 2
We also note the disclosure regarding the initial commercialization of OneTest in the
second half of 2018 and the statement on page 2 that you have received orders for 300
individual tests.  Please revise your discussion of revenues, trends and uncertainties in
Management's Discussion and Analysis to address the extent to which OneTest, in
addition to BioCheck and PAULA's test, contribute to and/or present material trends or
uncertainties regarding your operations and liquidity.

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
34
2.We note your disclosure related to your sources of revenue, and your response letter dated
June 22, 2018.  Your website still states that BioCheck “generates revenues of about
$500,000 per year with Gross Profit margins of about 80%.”  It also still states that the
company has brought in approximately $7.5 million “through numerous government and
private grants.”  Please advise us how these statements reconcile with the disclosure in the
Form 1-A, and, as necessary, enhance your disclosure to more specifically address how
the company earns revenue from grants and sales of BioCheck and other services.
            We will consider qualifying your offering statement at your request.  If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.  We also remind you that, following qualification of your Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered by the report.
            Please contact Ronald (Ron) Alper at 202-551-3329 or James Lopez at 202-551-3536
with any questions.
Sincerely,
Division of Corporation Finance
Office of Beverages, Apparel and
Mining
cc:       Louis A. Bevilacqua

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20/20 GeneSystems, Inc.

9430 Key West Ave,

Rockville, MD 20850

August 17, 2018

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn: John Reynolds

Re:  20/20 GeneSystems, Inc.

    Offering Statement on Form 1-A

    File No. 024-10816

Dear Mr. Reynolds:

We understand that the staff of the U.S. Securities
and Exchange Commission (the “Commission”) has completed its review of the Offering Statement on Form 1-A (the “Offering
Statement”) of 20/20 GeneSystems, Inc. (the “Company”) and we hereby request that the Commission approve the
qualification of the Offering Statement as of 4:00 PM Eastern Daylight Time on Friday, August 17, 2018.

We request that we be notified of such qualification
by a telephone call to Mr. Louis A. Bevilacqua at (202) 869-0888 ext. 100. We also respectfully request that a copy of the written
order from the Commission verifying the date and time of qualification of the Company’s Offering Statement be sent to Bevilacqua
PLLC, attention: Mary Sheridan, via email at mary@bevilacquapllc.com.

    Sincerely,

    20/20 GeneSystems, Inc.

    By:
    /s/ Jonathan Cohen

    Jonathan Cohen
Chief Executive Officer

 cc: Louis A. Bevilacqua, Esq.

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20/20 GeneSystems, Inc.

9430 Key West Ave.

Rockville, MD 20850

August 14, 2018

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC. 20549

Attn: John Reynolds

 Re: 20/20 GeneSystems, Inc.

Amendment No. 3 to

Offering Statement on Form
1-A

Filed August 1, 2018

File No. 024-10816

Dear Mr. Reynolds:

We hereby submit the responses of 20/20
GeneSystems, Inc. (the “Company”) to the comments of the staff (the “Staff”) of the U.S.
Securities and Exchange Commission set forth in the Staff’s letter, dated July 24, 2018, providing the Staff’s comments
with respect to Amendment No. 3 to the Offering Statement on Form 1-A (the “Offering 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.

Summary, page 1

 1. We note your response to comment 2 and revised disclosure on page 18 about exclusive forum and
waiver of jury trial. You state that “it is possible that a judge would find these provisions unenforceable.” Please
further clarify whether there is a question as to the enforceability of the jury trial provision and specifically address why you
believe the provision is enforceable under federal and state law.

Response:
We have revised the subscription agreement for the offering to remove the exclusive forum and waiver of jury trial provisions.
We have revised the Offering Statement to make conforming changes that reflect the removal of these provisions from the subscription
agreement.

 2. We note your response to comment 4. Please further address the differentiation between being a
primary purchaser and a secondary purchaser in your offering and provide further details as to how this will be implemented and
impact shareholders. As non-exclusive examples, please address whether the provision will essentially create two classes of shareholders
with different rights and how the differences will impact a single purchaser who may buy shares in both the primary offering and
the secondary market. Please consider an additional risk factor as necessary.

Response:
We have revised the subscription agreement for the offering to remove the exclusive forum and waiver of jury trial provisions.
Accordingly, the additional disclosure requested in comment 2 is no longer applicable.

U.S. Securities and Exchange Commission

August 14, 2018

Page 2

 3. We note your revised disclosure on page 6 and response to comment 5. Please revise to clarify “online
chat or commentary functions.” For example, it is unclear which members of management, if any, will answer all questions
in online chat or commentary functions.

Response:
We have revised the Offering Statement to refer to “senior management,” rather than “officers and other management.”
Furthermore, we hereby confirm to you that only senior members of our management team will answer questions about the Company that
are posted on online chat or commentary functions.

 4. In addition to the foregoing comments, we received from you a verbal comment indicating that our
counsel should file a signed copy of its opinion as an exhibit to the Form 1-A.

Response: A signed
copy of the opinion of Bevilacqua PLLC has been filed as Exhibit 12.1 to the Offering Statement.

If you would
like to discuss any of the responses to the Staff’s comments or if you would like to discuss any other matters, please contact
the undersigned at (240) 453-6339 or Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    20/20 GeneSystems, Inc.

    By:
    /s/ Jonathan Cohen

    Jonathan Cohen

    Chief Executive Officer

 cc: Louis A. Bevilacqua, Esq.

Mail Stop 3561

August 9 , 2018

Via E -mail
Jonathan Cohen
Chief Executive Officer
20/20 GeneSystems, Inc.
9430 Key West Ave.
Rockville, MD 20850

Re: 20/20 GeneSystems, Inc.
 Amendment No. 3  to
Offering Statement on Form 1 -A
Filed August 1 , 2018
  File No. 024-10816

Dear Mr. Cohen :

We have reviewed your amended offering statement  and have the following comments.
In some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your offering statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe  an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your offering statement and the information you
provide in response to these  comments, we may have  additional comments.   Unless we note
otherwise, our references to prior comments are to comments in our July 2 4, 2018 letter .

Summary, page 1

1. We note your response to comment 2 and revised disclosure on page 18 about exclusive
forum and  waiver of jury trial.  You state that “it is possible that a judge would find these
provisions unenforceable.”  Please f urther clarify whether there is a question as to the
enforceability  of the jury trial provision and specifically address why you believ e the
provision  is enforceable under federal and state  law.

2. We note your response to comment 4.   Please further address the differentiation between
being a primary purchaser and a secondary purchaser in your offering and provide further

Jonathan Cohen
20/20 GeneSystems, Inc.
August 9 , 2018
Page 2

 details as to how this will be implemented and impact shareholders.   As non -exclusive
examples, please address whether the provision will essentially create two classes of
shareholders with different rights and how the differences will impact a single purchaser
who may buy shares in both the primary offering and the secondary market.  Please
consider an additional risk factor as necessary .

3. We note your revised disclosure on page 6 and response to comment 5.  Please revise to
clarify “online chat or commentary functions.”  F or example, it is unclear which
members of management, if any, will answer all questions in online cha t or commentary
functions.

You may contact Linda Cvrkel at (202) 551 -3813 or Rufus Decker, Accounting Branch
Chief, at (202) 551 -3769 if you have questi ons regarding comments on the financial statements
and related matters.  Please contact Hillary Daniels at (202) 551 -3959 or James Lopez, Legal
Branch Chief, at (202) 551 -3536 with any other questions.

Sincerely,

 /s/ Brigitte Lippmann (for)

John Reynolds
Assistant Director
Office of Beverages, Apparel, and
Mining

cc: Louis A. Bevilacqua, Esq.
Bevilacqua PLLC

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20/20 GeneSystems, Inc.

9430 Key West Ave.

Rockville, MD 20850

August 1, 2018

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC. 20549

Attn: John Reynolds

 Re: 20/20 GeneSystems, Inc.

Amendment No. 2 to

Offering Statement on Form
1-A

Filed July, 2018

File No. 024-10816

Dear Mr. Reynolds:

We hereby submit the responses of 20/20
GeneSystems, Inc. (the “Company”) to the comments of the staff (the “Staff”) of the U.S.
Securities and Exchange Commission set forth in the Staff’s letter, dated July 24, 2018, providing the Staff’s comments
with respect to Amendment No. 2 to the Offering Statement on Form 1-A (the “Offering 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.

Prospectus cover page

 1. We note your response to comment 2. Please tell us the entity that will receive the 2% transaction
fee that will function as a brokerage fee.

Response:
The entity that will receive the 2% transaction fee is SI Securities, LLC, the Company’s placement agent. SI Securities,
LLC is a FINRA member and SEC registered broker-dealer.

Summary,
page 1

 2. We note your responses to comments 3, 4, 5, and 7 related to the provisions contained in your Subscription
Agreement regarding exclusive forum, venue and jurisdiction provisions, and the waiver of the right to a jury trial. Please advise
us why you believe these provisions are enforceable under applicable law, including any questions as to enforceability. Please
also provide further risk factor disclosure, to include risks of such provisions related to increased cost.

Response:
We have revised the risk factor disclosure and elsewhere in the Offering Statement to address the Staff’s comment. Please
note that we have indicated that the exclusive jurisdiction provision may not be enforceable in all jurisdictions. We do not believe
we can describe the enforceability of the exclusive jurisdiction provision beyond such statement because to do so would place a
significant burden on the Company of knowledge of the laws (including common law) with respect to the enforceability of exclusive
jurisdiction provisions of subscription agreements in each jurisdiction from which an investor in the offering may be based.

U.S. Securities and Exchange Commission

August 1, 2018

Page 2

 3. Please provide an explicit statement, both in the disclosure and in the Subscription Agreement,
that by agreeing to these provisions, investors will not be deemed to have waived the company’s compliance with the federal
securities laws and the rules and regulations thereunder.

Response:
We have included such statement, both in the disclosure and the Subscription Agreement.

 4. Please clarify whether these provisions apply to secondary purchasers. If not, the differences
between being a primary purchaser and a secondary purchaser should be clearly delineated in the offering circular, as should how
this will be implemented.

Response:
The exclusive forum provision and the waiver of trial by jury provisions of the subscription agreement will not apply to secondary
purchasers who are not parties to the subscription agreement. The provisions of the subscription agreement only apply to the Company
and the initial subscribers. We have revised the offering circular to reflect this fact.

 5. We note your response to comment 6. Please revise risk factor disclosure and where appropriate
to address the information in Sections 4(f) as to the representations of subscribers related to reviewing aspects of the company’s
business.

Response:
We have revised the applicable risk factor and elsewhere in the Offering Statement to add disclosure describing the information
in Section 4(f) of the subscription agreement related to review of the Company’s business.

If you would like to discuss any of the
responses to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at (240)
453-6339 or Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    20/20 GeneSystems, Inc.

    By:
    /s/ Jonathan Cohen

    Jonathan Cohen

    Chief Executive Officer

 cc: Louis A. Bevilacqua, Esq.

Mail Stop 3561

July 24, 2018

Via E -mail
Jonathan Cohen
Chief Executive Officer
20/20 GeneSystems, Inc.
9430 Key West Ave.
Rockville, MD 20850

Re: 20/20 GeneSystems, Inc.
 Amendment No. 2  to
Offering Statement on Form 1 -A
Filed July 11 , 2018
  File No. 024-10816

Dear Mr. Cohen :

We have reviewed your amended offering statement  and have the following comments.
In some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your offering statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendmen t is appropriate, please tell us why in your
response.

After reviewing any amendment to your offering statement and the information you
provide in response to these  comments, we may have  additional comments.   Unless we note
otherwise, our references to prior comments are to comments in our July 2 , 2018 letter .

Prospectus cover page

1. We note your response to comment  2.  Please tell us the entity that will receive the 2%
transaction fee that will function as a brokerage fee.

Summary, page 1

2. We note your responses to comments 3, 4, 5, and 7 related to the provisions contained in
your Subscription Agreement regarding exclusive forum, venue and jurisdiction
provisions , and the  waiver of the right to a jury trial.  Please advise us why you believe

Jonathan Cohen
20/20 GeneSystems, Inc.
July 24, 2018
Page 2

 these provisions are enforceable under applicable law, including any questions as to
enforceability.  Please also provide  further risk factor disclosure, to include  risks of such
provisions related to increased cost.

3. Please provide an explicit statement, b oth in the disclosure and in the Subscription
Agreement, that by agreeing to these provisions, investors will not be deemed to have
waived the company’s compliance with the federal securities laws and the rules and
regulations thereunder.

4. Please clarify w hether these provisions apply to secondary purchasers.  If not, the
differences between being a primary purchaser and a secondary purchaser should be
clearly delineated in the offering circular, as should how this will be implemented.

5. We note your respons e to comment 6.  Please revise risk factor disclosure and where
appropriate to address the information in Sections 4(f) as to the representations of
subscribers related to reviewing aspects of the company’s business.

You may contact Linda Cvrkel at (202) 551-3813 or Rufus Decker, Accounting Branch
Chief, at (202) 551 -3769 if you have questions regarding comments on the financial statements
and related matters.  Please contact Hillary Daniels at (202) 551 -3959 or James Lopez, Legal
Branch Chief, at (202) 55 1-3536 with any other questions.

Sincerely,

 /s/ Pamela Howell
 for

John Reynolds
Assistant Director
Office of Beverages, Apparel, and
Mining

cc: Louis A. Bevilacqua, Esq.
Bevilacqua PLLC

CORRESP
1
filename1.htm

20/20
GeneSystems, Inc.

9430
Key West Ave.

Rockville,
MD 20850

July
11, 2018

U.S.
Securities and Exchange Commission

100 F Street, N.E.

Washington, DC. 20549

Attn: John Reynolds

 Re: 20/20
                                         GeneSystems, Inc.

Amendment
No. 1 to

Offering
Statement on Form 1-A

Filed
June 22, 2018

File
No. 024-10816

Dear
Mr. Reynolds:

We
hereby submit the responses of 20/20 GeneSystems, Inc. (the “Company”) to the comments of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission set forth in the Staff’s letter, dated July 2, 2018, providing the Staff’s
comments with respect to Amendment No. 1 to the Offering Statement on Form 1-A (the “Offering 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.

Prospectus
cover page

 1. Please
                                         disclose the termination date of the offering. See Item 1(e) of Part II.

Response:
Please note that the fourth paragraph of the prospectus cover included the following disclosure regarding the termination date:
“The offering will terminate at the earlier of: (1) the date on which the maximum offering amount has been sold, (2) the
date which is one year after this offering has been qualified by the U.S. Securities and Exchange Commission, or the SEC, or (3)
the date on which this offering is earlier terminated by us in our sole discretion.” We have revised the Offering Statement
to include this language in a separate paragraph.

 2. We
                                         note the statement on page 22 that investors will be charged a non-refundable transaction
                                         fee equal to 2%. Please advise us if this fee will be in addition to any brokerage or
                                         similar fees to be incurred by investors. If so, please revise here and risk factors
                                         to clarify the extent to which investors will be charged an extra 2% for purchasing your
                                         securities.

Response:
The 2% transaction fee functions as a brokerage fee and is charged to all investors investing in the offering. There are no additional
brokerage or similar fees incurred by investors.

Summary,
page 1

 3. We
                                         note the waiver of the right to a jury trial provision contained in Section 7 of your
                                         Subscription Agreement. Please revise your offering circular to provide risk factor disclosure
                                         which discusses the effects of such a provision on your investors.

Response:
We have revised the Offering Statement to include a risk factor that discusses the effects of the right to a jury trial provision
and the exclusive forum provision contained in Section 7 of the Subscription Agreement.

U.S. Securities and Exchange Commission

July 11, 2018

Page 2

 4. Please
                                         clarify whether the waiver of the right to a jury trial applies to claims made under
                                         the federal securities laws.

Response:
The waiver of the right to a jury trial applies to claims made under the federal securities laws, which is disclosed in the risk
factor referenced in Response 3 above.

 5. We
                                         also note the provision contained in Section 7 of your Subscription Agreement that establishes
                                         Delaware as the exclusive forum for state and federal claims relating to the agreement.
                                         Please revise your offering circular to provide risk factor disclosure which discusses
                                         the effects of such a provision on your investors. Please also clarify whether the exclusive
                                         forum applies to claims made under the federal securities laws.

Response:
We have revised the Offering Statement to include a risk factor that discusses the effects of the right to a jury trial provision
and the exclusive forum provision contained in Section 7 of the Subscription Agreement. The exclusive forum provision applies
to claims made under the federal securities laws, which is disclosed in the risk factor referenced above.

 6. Please
                                         disclose the terms from Section 1 of the Subscription Agreement, including the minimum
                                         subscription amounts and irrevocability. Please also revise risk factors and where appropriate
                                         to address the information in Sections 4(f) and 6.

Response:
We have revised the Offering Statement to include the terms from Section 1 of the Subscription Agreement.

The
first risk factor in our Offering Statement is entitled “We are an early stage company and have incurred operating losses
since inception and we do not know if we will attain profitability,” which discusses the risks associated with early-stage
companies as described in Section 4(f) of the Subscription Agreement. We have revised such risk factor to provide additional disclosure
to more fully describe the risk inherent in early-stage company investments. We have also made revisions elsewhere in the Offering
Statement to make clear that the Company is an early-stage company.

Section
6 of the Subscription Agreement provides that investors in our Series B Preferred Stock would receive rights substantially equivalent
to the rights of securities issued by the Company in its next equity financing within 180 days after the date this offering, if
such new securities (a) have rights, preferences or privileges that are more favorable than the terms of the Series B Preferred
Stock, (b) provide all such future investors other contractual terms such as registration rights. Since this provision is favorable
to the investors in our Series B Preferred Stock, we believe a risk factor is not needed to disclose the information contained
Section 6 of the Subscription Agreement. However, we have added disclosure describing these additional rights in the section of
the Offering Statement entitled “Securities Being Offered.”

 7. Please
                                         advise us of the enforceability of Section 7 of the Subscription Agreement regarding
                                         review and consultation with counsel.

Response:
Investors under the Subscription Agreement are required to represent that they have reviewed and consulted with legal counsel
on their waiver of a jury trial. The Company cannot and is not required under any applicable laws to check if such representations
are accurate. Section 7 of the Subscription Agreement has been revised to clarify that its applicability is limited to the
what is permissible under state and federal law.

U.S. Securities and Exchange Commission

July 11, 2018

Page 3

Description
of Business, page 25

 8. We
                                         note your revised disclosure and response to comment 2. Please disclose the basis for
                                         your belief that Paula’s Test is the “first combinatorial blood test …
                                         that incorporates a machine learning algorithm” and the statement that “no
                                         marketed product currently competes with [y]our proposed OneTest multi (pan) cancer test.”

Response:
We have revised the Offering Statement accordingly.

Our
Commercial Approach, page 29

 9. We
                                         note your response to comment 3. Please revise to clarify the significant milestones
                                         for commercialization of your tests which are currently in development. For example,
                                         it remains unclear what material achievements you must accomplish to make your tests
                                         “available at pharmacy chains and walk-in clinics” and “national clinical
                                         laboratory testing chains such as LabCorp or Quest Diagnostics.”

Response:
We have revised the Offering Statement accordingly.

Financial
Statements

Note
7 – Stockholders’ Equity

Preferred
Stock

Liquidation
Rights, page F-15

 10. Please
                                         tell us how you determined that your preferred stock need not be presented in temporary
                                         equity given the deemed liquidation provisions, where redemption may be outside of your
                                         control. Refer to ASC 480-10-S99-3A.

Response:
In determining if preferred equities need be classified as temporary equity, the Company conducted the following analysis.

ASC
480-10-S99 requires preferred stock redeemable for cash or other assets to be classified outside of permanent equity (in the “mezzanine”
equity or “temporary” equity section), if it is redeemable:

 ● At
                                         a fixed or determinable price on a fixed or determinable date

Response:
The redemption upon a liquidation event, deemed liquidation event or change in control is for a fixed price but is not based on
a fixed or determinable date and thus mezzanine treatment does not apply under such guidance.

 ● At
                                         the option of the shareholder

Response:
The redemption upon a liquidation event is not at the option of the holder and thus mezzanine treatment does not apply under such
guidance.

 ● Upon
                                         the occurrence of an event that is not solely within the control of the reporting entity

Response:
Per the guidance of ASC 480-10-399-3A(f) a liquidation event(s) “…which involve the redemption and liquidation
of all of an entity's equity instruments for cash or other assets of the entity, do not result in an equity instrument being subject
to ASR 268. In other words, if the payment of cash or other assets is required only from the distribution of net assets upon the
final liquidation or termination of an entity (which may be a less-than-wholly-owned consolidated subsidiary), then that potential
event need not be considered when applying ASR 268.” Thus, such liquidation event is not considered.

U.S. Securities and Exchange Commission

July 11, 2018

Page 4

Accordingly,
the Company only needs to consider a deemed liquidation event, which as outlined by ASC 480-10-S99-3A(f) “Other transactions
are considered deemed liquidation events. For example, the contractual provisions of an equity instrument may require its redemption
by the issuer upon the occurrence of a change in-control that does not result in the liquidation or termination of the issuing
entity, a delisting of the issuer's securities from an exchange, or the violation of a debt covenant. Deemed liquidation events
that require (or permit at the holder's option) the redemption of only one or more particular class of equity instrument for cash
or other assets cause those instruments to be subject to ASR 268.”

If
the Company cannot control (i.e., cannot prevent) the occurrence of a transaction resulting in a change in control, by using corporate
governance provisions under the certificate of incorporation or by invoking state or federal securities law, the deemed liquidation
event would not be considered within the Company’s control, and thus the preferred shares would be treated as mezzanine.

However,
the General Corporation Law of the State of Delaware requires that the types of transactions that would cause a deemed liquidation
to be approved by both the Board of Directors and by the holders of a majority of the outstanding stock. The Preferred Stock shareholders
do not make up a majority of the Board of Directors nor do they have voting control as a single class or on an as-converted basis,
and thus cannot force redemption through control of both the Board and outstanding shares. Accordingly, the events that would
cause a deemed liquidation or Change of Control as defined by the Preferred Stock designations, are believed to be within the
control of the reporting entity and thus not subject to mezzanine treatment per the guidance of ASC 480-10-S99. This conclusion
is consistent with Examples 5 and 6 of under ASC 480-10-S99-3A which indicates permanent equity classification is appropriate
in such instances.

Exhibits

 11. Please
                                         file the PHS, MdBio and Abbot Molecular agreements or advise us why you believe they
                                         are not required to be filed under Item 17 of Part III.

Response:
We have revised the Offering Statement to file the PHS and MdBio agreements as exhibits thereto. We do not believe that the Abbott
Molecular agreement is material. As noted in the Offering Statement, total royalty expenses incurred under this agreement were
$1,049 and $1,890 for 2017 and 2016, respectively. Furthermore, this agreement is confidential.

If
you would like to discuss any of the responses to the Staff’s comments or if you would like to discuss any other matters,
please contact the undersigned at (240) 453-6339 or Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    20/20 GeneSystems, Inc.

    By:
    /s/ Jonathan Cohen

    Jonathan Cohen

    Chief Executive Officer

cc: Louis
                                         A. Bevilacqua, Esq.

Mail Stop 3561

July 2 , 2018

Via E -mail
Jonathan Cohen
Chief Executive Officer
20/20 GeneSystems, Inc.
9430 Key West Ave.
Rockville, MD 20850

Re: 20/20 GeneSystems, Inc.
 Amendment No. 1  to
Offering Statement on Form 1 -A
Filed June 22, 2018
  File No. 024-10816

Dear Mr. Cohen :

We have reviewed your amended offering statement  and have the following comments.
In some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your offering statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendmen t is appropriate, please tell us why in your
response.

After reviewing any amendment to your offering statement and the information you
provide in response to these  comments, we may have additional comments.   Unless we note
otherwise, our references to prior comments are to comments in our April 5, 2018 letter .

Prospectus cover page

1. Please disclose the termination date of the offering.  See Item 1(e) of Part II.

2. We note the statement on page 22 that investors will be charged a non -refundable
transacti on fee equal to 2%.  Please advise us if this fee will be in addition to any
brokerage or similar fees to be incurred by investors.  If so, please revise here and risk
factors to clarify the extent to which investors will be charged an extra 2% for purchas ing
your securities .

Jonathan Cohen
20/20 GeneSystems, Inc.
July 2 , 2018
Page 2

 Summary, page 1

3. We note the waiver of the right to a jury trial provision contained in Section 7 of your
Subscription Agreement.  Please revise your offering circular to provide risk factor
disclosure which discusses the effects of such a provision on your investors.

4. Please clarify whether the waiver of the right to a jury trial applies to claims made under
the federal securities laws .

5. We also note the provision contained in Section 7 of your Subscription Agreement that
establishes Delaware as the exclusive forum for state and federal claims relating to the
agreement.  Please revise your offering circular to provide risk factor disclosure which
discusses the effects of such a provision on your investors.  Please also clarify whether
the exclusive forum applies to claim s made under the federal securities laws.

6. Please disclose the terms from Section 1 of the Subscription Agreement, including the
minimum subscription amounts and irrevocability.  Please also revise risk factors and
where appropriate to address th e informat ion in Sections 4(f) and 6 .

7. Please advise us of the enforceability of Section 7 of the Subscription Agreement
regarding review and consultation with counsel.

Description of Business, page 25

8. We note your revised disclosure and response to comment 2.  Please disclose the basis for
your belief that Paula’s Test is the “first combinatorial blood test … that incorporates a
machine learning algorithm” and the statement that “no marketed product currently
competes with [y]our proposed OneTest multi (pan) ca ncer test.”

Our Commercial Approach, page 29

9. We note your response to comment 3.  Please revise to clarify the significant milestones
for commercialization of your tests which are currently in development.  For example, it
remains unclear what material achievements you must accomplish to make your tests
“available at pharmacy chains and walk -in clinics” and “national clinical laboratory
testing chains such as LabCorp or Quest Diagnostics.”

Jonathan Cohen
20/20 GeneSystems, Inc.
July 2 , 2018
Page 3

 Financial Statements
Note 7 – Stockholders’ Equity
Preferred Stock
Liquidation Rights, page F -15

10. Please tell us how you determined that your preferred stock need not be presented in
temporary equity given the deemed liquidation provisions, where redemption may be
outside of your control.   Refer to ASC 480 -10-S99-3A.

Exhibits

11. Please file the PHS, MdBio and Abbot Molecular agreements or advise us why you
believe they are not required to be filed under Item 17 of Part III.

You may contact Linda Cvrkel at (202) 551 -3813 or Rufus Decker, Accounting Branch
Chief, at (202) 551 -3769 if you have questions regarding comments on the financial statements
and related matters.  Please contact Hillary Daniels at (202) 551 -3959 or James Lopez, Legal
Branch Chief, at (202) 551 -3536 with any other questions.

Sincerely ,

 /s/ James Lopez (for)

John Reynolds
Assistant Director
Office of Beverages, Apparel, and
Mining

cc: Louis A. Bevilacqua, Esq.
Bevilacqua PLLC

CORRESP
1
filename1.htm

20/20
GeneSystems, Inc.

9430
Key West Ave.

Rockville,
MD 20850

June
22, 2018

U.S.
Securities and Exchange Commission

100 F Street, N.E.

Washington, DC. 20549

Attn: John Reynolds

 Re: 20/20
                                         GeneSystems, Inc.

Offering
Statement on Form 1-A

Filed
March 9, 2018

File
No. 024-10816

Dear
Mr. Reynolds:

We
hereby submit the responses of 20/20 GeneSystems, Inc. (the “Company”) to the comments of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission set forth in the Staff’s letter, dated April 5, 2018, providing the Staff’s
comments with respect to the Offering Statement on Form 1-A (the “Offering 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.

Risk
Factors, page 6

 1. We
                                         note the discussion on page 17 regarding different options for ongoing reporting. Please
                                         revise where appropriate to clarify your reporting if your shares become quoted on the
                                         OTCQB.

Response:
We have revised the Offering Statement to clarify our ongoing reporting obligations if the Company’s shares of common stock
become quoted on the OTCQB, which are satisfied by remaining in compliance with (i) SEC reporting requirements, if we elect to
become a public reporting company under the Exchange Act, or (ii) Regulation A reporting requirements, if we elect not to become
a reporting company under the Exchange Act.

Description
of Business, page 25

 2. We
                                         note the statement that you believe Paula’s Test is the “first combinatorial
                                         blood test … that incorporates a machine learning algorithm.” We also note
                                         the statement that “no marketed product currently competes with our proposed OneTest
                                         multi (pan) cancer test.” Please revise to clearly differentiate how your current
                                         and pending tests differ from ones provided by other companies. For example, it appears
                                         that some public companies currently offer tests using machine learning and algorithms,
                                         and some tests appear to screen for multiple types of cancer.

Response:
We have revised the Offering Statement to differentiate how our tests differ form those of other companies.

U.S.
Securities and Exchange Commission

June
22, 2018

Page
2

Our
Commercial Approach, page 29

 3. We
                                         note statements that you “expect to eventually” make your products available
                                         to large national clinical laboratory testing chains such as LabCorp or Quest Diagnostics.
                                         Please clarify the expected timeline for any existing or planned arrangements with such
                                         third parties to the extent material. Please also revise to clarify the status of your
                                         tests. For example, the first paragraph on page 1 suggests that your products currently
                                         include OneTest; however, you state on page 28 that OneTest is “late stage”
                                         without providing an approximate timeline for commercialization. You also (1) refer to
                                         BioCheck as a “legacy” product without explaining the extent to which it
                                         is expected to generate more than de minimis revenues and (2) refer to “Lung Cancer
                                         Detection (China)” on page 28 without providing an approximate timeline for commercialization.

Response:
We have revised the Offering Statement to clarify the expected timeline for the status and commercialization of our tests. The
Company operates its own lab with a Certificate of Compliance (General Immunology) through June 2020. In May 2018, the Company
acquired, installed, and validated the automated immunoassay analyzers needed to run OneTest™. We expect to have
all of our standard operating procedures in place per CLIA requirements before the end of June 2018 at which time we expect to
widely promote OneTest™, with an initial focus in the Washington, D.C. metropolitan area. We estimate our current
capacity would be to handle up to approximately 500 tests per week. Before we exceed that capacity, which may occur before the
end of 2019, we would seek to have the biomarker tests run in external clinical labs such as LabCorp and Quest Diagnostics. This
will likely require approval from the Food and Drug Administration since the test would no longer be a Laboratory Developed Test.

Regarding
other products, the Company’s current intent is that PAULA’s Test+™ will become subsumed by OneTest™,
at least for customers with a history of smoking, since most of the biomarkers that are detected by the former are also detected
by the latter. It is possible that PAULA’s Test+™ will remain as a stand-alone test for high risk smokers and former
smokers although time is needed to make that assessment. Our Chinese lung cancer test algorithm, which is presently designed to
help with the differentiation of benign and malignant pulmonary nodules, will likely need to be integrated with Artificial Intelligence
imaging technology to become competitive. Our BioCheck® kits for screening suspicious powders remains profitable but with
limited growth potential, at least in the U.S. absent a serial anthrax incident like the one that occurred in the U.S. in 2001.

Management’s
Discussion and Analysis of Financial Condition and Results of Operations, page 33

 4. We
                                         note that you do not expect to have a predictable revenue stream in the near future and
                                         that you recently transitioned to a “potentially more profitable self-pay model.”
                                         We also note the statement that you have “payment obligations and obligations to
                                         pursue development and commercialization of diagnostic tests.” Please revise to
                                         address these topics to the extent they represent trends, demands, commitments or events
                                         that are reasonably likely to have a material effect on your net sales or revenues. In
                                         this regard, if material, please address period-to-period changes to the average selling
                                         price of Paula’s test, which you state on page 3 is about $149. Refer to Item 9(d)
                                         of Part II of Form 1-A.

Response:
We have revised our disclosure to include period-to-period changes for our products.
Based on market research conducted to date, including pre-orders, we believe that there is a substantial base of American consumers
willing to pay between $150 to $200 for our multi-cancer early detection blood (OneTest™). At an average selling
price of $175, this product would generate gross profit margins of 80% that would rise to about 90% with growing test volume as
the negotiated cost of test reagents drop from the current $30 to below $20.

U.S.
Securities and Exchange Commission

June
22, 2018

Page
3

In
addition, we have revised our disclosure to summarize our payment obligations and obligations to pursue development and commercialization
of diagnostic tests.

 5. We
                                         note your disclosure related to your sources of revenue. We also note that your website
                                         states that BioCheck “generates revenues of about $500,000 per year with Gross
                                         Profit margins of about 80%.” It also states that the company “has brought
                                         in approximately $7.5 million in grant funding.” Please advise us how these statements
                                         reconcile with the disclosure in the Form 1-A, and, as necessary, enhance your disclosure
                                         to more specifically address how the company earns revenue from grants and sales of BioCheck
                                         and other services.

Response:
We are in the process of removing such information from our website, which was incorrect. The information in the Form 1-A is correct
and, therefore, requires no further revision.

Compensation
of Directors and Executive Officers, page 42

 6. We
                                         note your disclosure that certain directors are awarded options that vest over time.
                                         Please revise this section to provide all information required by Item 11(d) of Form
                                         1-A.

Response:
We have revised the Offering Statement to disclose the compensation payable to the Company’s Chief Executive Officer and
to clarify that the Company does not otherwise have an ongoing plan or arrangement for compensation of directors and executive
officers.

Interest
of Management and Others in Certain Transactions, page 44

 7. We
                                         note your disclosure on page F-12 regarding various Investment LLCs and arrangements
                                         with immediate family members of the CEO. Please revise this section to provide all information
                                         required by Item 13 of Form 1-A and file any related agreements.

Response:
We have revised our disclosure to provide all of the information required by Item 13 of Form 1-A. We do not believe that these
agreements must be filed since they are not material.

Part
III - Exhibits

 8. Please
                                         file the escrow agreement as an exhibit to the offering statement. Refer to Item 17(8)
                                         in Part III of Form 1-A.

Response:
We have revised the Offering Statement to file the escrow agreement as an exhibit thereto.

If
you would like to discuss any of the responses to the Staff’s comments or if you would like to discuss any other matters,
please contact the undersigned at (240) 453-6339 or Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext 100).

    Sincerely,

    20/20 GeneSystems, Inc.

    By:
    /s/ Jonathan Cohen

    Jonathan Cohen

    Chief Executive Officer

 cc: Louis
                                         A. Bevilacqua, Esq.

April 5, 2018

Via E -mail
Jonathan Cohen
Chief Executive Officer
20/20 GeneSystems, Inc.
9430 Key West Ave.
Rockville, MD 20850

Re: 20/20 GeneSystems, Inc.
Offering Statement  on Form 1-A
Filed  March 9, 2018
  File No. 024-10816

Dear Mr. Cohen :

We have reviewed your offering statement and have the following comments.  In some of
our comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter by amending your offering statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.  After reviewing any amendment to your offering statement and the information you
provide in response to these comments, we may have additional comments.

Risk Factors, page 6

1. We note the discussion on page 17 regarding different options for ong oing reporting.
Please revise where appropriate to clarify your reporting if your shares become quoted on
the OTCQB.

Description of Business , page 25

2. We note the statement that you believe Paula’s Test is the “first combinatorial blood test
… that incorporates a machine learning algorithm.”  We also note the statement that “no
marketed product currently competes with our proposed OneTest multi (pan) can cer test.”
Please revise to clearly differentiate how your current and pending tests differ from ones
provided by other companies.  For example, it appears that some public companies
currently offer tests using machine learning and algorithms, and some te sts appear to
screen for multiple types of cancer.

Jonathan Cohen
20/20 GeneSystems, Inc.
 April 5, 2018
 Page 2

 Our Commercial Approach, page 29

3. We note statements that you “expect to eventually” make your products available to large
national clinical laboratory testing chains such as LabCorp or Quest Diagnostics.   Please
clarify the expected timeline for any existing or planned arrangements with such third
parties to the extent material.  Please also revise to clarify the status of your tests.  For
example, the first paragraph on page 1 suggests that your products  currently include
OneTest; however, you state on page 28 that OneTest is “late stage” without providing an
approximate timeline for commercialization.  You also (1) refer to BioCheck as a
“legacy” product without explaining the extent to which it is expec ted to generate more
than de minimis revenues and (2) refer to “Lung Cancer Detection (China)” on page 28
without providing an approximate timeline for commercialization.

Management’s Discussion and Analysis of Financial Condition and Results of Operati ons, page
33

4. We note that you do not expect to have a predictable revenue stream in the near future
and that you recently transitioned to a “potentially more profitable self -pay model.”  We
also note the statement that you have “payment obligations and ob ligations to pursue
development and commercialization of diagnostic tests.”  Please revise  to address these
topics to the  extent they  represent  trends, demands, commitments or events that are
reasonably likely to have a material effect on your net sales or revenues.  In this reg ard, if
material, please address period -to-period changes to the average selling price of Paula’s
test, which you state on page 3 is about $149.  Refer to Item 9(d) of Part II of Form 1 -A.

5. We note your disclosure related to your sources of revenue.  We al so note that your
website states that BioCheck “generates revenues of about $500,000 per year with Gross
Profit margins of about 80%.”  It also states that the company “has brought in
approximately $7.5 million in grant funding.”  Please advise us how thes e statements
reconcile with the disclosure in the Form 1 -A, and, as necessary, enhance your disclosure
to more specifically address how the company earns revenue from grants and sales of
BioCheck and other services.

Compensation of Directors and Executive Officers, page 42

6. We note your disclosure that certain directors are awarded options that vest over time.
Please revise this section to provide all information required by Item 11(d) of Form 1 -A.

Interest of Mana gement and Others in Certain Transactions, page 44

7. We note your disclosure on page F -12 regarding various Investment LLCs and
arrangements with immediate family members of the CEO.  Please revise this section to
provide all information required by Item 13  of Form 1 -A and file any related agreements.

Jonathan Cohen
20/20 GeneSystems, Inc.
 April 5, 2018
 Page 3

 Part III - Exhibits

8. Please file the escrow agreement as an exhibit to the offering statement.  Refer to Item
17(8) in Part III of Form 1 -A.

We will consider qualifying your offering statement at your request .  If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.

 We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.   We also remind you that, following qualification of your F orm 1 -A, Rule 257
of Regulation  A requires you to file periodic and current reports , including a Form 1 -K which
will be  due within 120 calendar days after the end of the fiscal year covered by the report .

You may contact Linda Cvrkel at (202) 551 -3813  or Rufus Decker , Accounting Branch
Chief,  at (202) 551 -3769  if you have questions regarding comments on the financial statements
and re lated matters.  Please contact Hillary Daniels at (202) 551 -3959  or James Lopez, Legal
Branch Chief, at (202) 551 -3536  with any other questions.

Sincerely,

 /s/ James Lopez (for)

John Reynolds
Assistant Director
Office of Beverages, Apparel, and
Mining

cc: Louis A. Bevilacqua, Esq.
Bevilacqua PLLC