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 March 13, 2026

James DiPrima
Chief Financial Officer
Blue Chip Capital Group, Inc.
110 East 59th Street, 23rd Floor
New York, NY 10022

 Re: Blue Chip Capital Group, Inc.
 Amendment No. 1 to Form 10-K for Fiscal Year Ended May 31, 2025
 File No. 000-56751
Dear James DiPrima:

 We have completed our review of your filing. 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.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Blue
Chip Capital Group, Inc.

 110
East 59 th Street, 23 rd Floor

 New
York, NY 10022

 Phone:
(212) 324-3748

 March
12, 2026

 United
States Securities and Exchange Commission

 Division
of Corporation Finance, Office of Finance

 Washington,
DC 20549

 Attention:
Cara Lubit and Robert Klein

 Re:
 Blue
 Chip Capital Group, Inc.

 Amendment
 No. 1 to Form 10-K for Fiscal Year Ended May 31, 2025

 File
 No. 000-56751

 Ladies
and Gentlemen:

 As
Chief Executive Officer of Blue Chip Capital Group, Inc. (the "Company"), we are submitting this letter in response to the
staff's comment letter dated March 3, 2026 (the "Staff Letter") regarding the Company's Form 10-K/A for the fiscal
year ended May 31, 2025. For the staff's convenience, we have included each of the staff's comments numbered sequentially
followed by our response to each comment, also numbered sequentially.

 Comment
No. 1: Item 9. Changes in and Disagreements With Accountants on Accounting and Financial Disclosure, page 26 . Disclosure on page
26 states that you have filed a letter from Hudgens CPA PLLC as Exhibit 16.1 to your form 10-K/A, and the same disclosure is in your
10-K. However, this letter does not appear to be included as an exhibit to either of these filings. Please include this letter as an
exhibit in an amended Form 10-K or revise your disclosure to reference the Exhibit included within the relevant Item 4.01 Form 8-K that
has been filed.

 Response
No.1: We have filed together with this correspondence Amendment No. 2 to the Company's Form 10-K for the fiscal year ended
May 31, 2025. We have corrected the disclosure in the Form 10-K/A filed with the Commission on November 10, 2025 to state that the letter
from Hudgens CPA PLLC was filed a Exhibit 16.1 to the Company's Form 8-K filed on April 5, 2024 and included reference to this
Form 8-K and a link to the subject Exhibit 16.1 in the Exhibit Table to this Amendment No.2 to the Form 10-K.

 Comment
No. 2:  Corporate Governance, page 30 . We note your disclosure on page 30 that you have included as exhibits certifications
of your Chief Executive Officer and Chief Financial Officer. However, there do not appear to be any certification exhibits included with
your 10-K or 10-K/A related to Section 906 of the Sarbanes-Oxley Act or Rule 13a-14(a) / Rule 15d-14(a). Please file a new full amendment
to the Form 10-K and include these certifications as exhibits.

 Response
No. 2: We have filed certification exhibits with the Company's Amendment No. 2 to the Form 10-K/A related to Section 906
of the Sarbanes-Oxley Act or Rule 13a-14(a) / Rule 15d-14(a).

 Respectfully submitted,

 /s/: James C.
DiPrima

 James C. DiPrima

 Chief Executive Officer

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<TEXT>
 March 3, 2026

James DiPrima
Chief Financial Officer
Blue Chip Capital Group, Inc.
110 East 59th Street, 23rd Floor
New York, NY 10022

 Re: Blue Chip Capital Group, Inc.
 Amendment No. 1 to Form 10-K for Fiscal Year Ended May 31, 2025
 File No. 000-56751
Dear James DiPrima:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Amendment No. 1 to Form 10-K for Fiscal Year Ended May 31, 2025
Item 9. Changes in and Disagreements With Accountants on Accounting and
Financial
Disclosure, page 26

1. Disclosure on page 26 states that you have filed a letter from Hudgens
CPA PLLC as
 Exhibit 16.1 to your form 10-K/A, and the same disclosure is in your
10-K. However,
 this letter does not appear to be included as an exhibit to either of
these filings. Please
 include this letter as an exhibit in an amended Form 10-K or revise your
disclosure to
 reference the Exhibit included within the relevant Item 4.01 Form 8-K
that has been
 filed.
Corporate Governance, page 30

2. We note your disclosure on page 30 that you have included as exhibits
certifications of
 your Chief Executive Officer and Chief Financial Officer. However, there
do not appear
 to be any certification exhibits included with your 10-K or 10-K/A
related to Section 906
 of the Sarbanes-Oxley Act or Rule 13a-14(a) / Rule 15d-14(a). Please
file a new full
 amendment to the Form 10-K and include these certifications as exhibits.
 March 3, 2026
Page 2

 In closing, 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 Lubit at 202-551-5909 or Robert Klein at
202-551-3847 with any
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

Blue
Chip Capital Group, Inc.

269
South Beverly Drive, Suite 373

Beverly
Hills, CA 90212

Phone:
(347) 629-1990

November
29, 2023

United
States Securities and Exchange Commission

Washington,
DC 20549

Re:
Blue Chip Capital Group

File
No. 333-273760

Registration
Statement on Form S-1/A

Request
for Acceleration

Ladies
and Gentlemen:

On
behalf of Blue Chip Capital Group, Inc., this is to request that the above-referenced Registration Statement on Form S-1/A be declared
effective by the Commission on Friday, December 1, 2023 at 4:45 p.m. EST or as soon thereafter as reasonably practicable.

Respectively
submitted,

  /s/ Joseph Richard
  Moran

  CEO

CORRESP
1
filename1.htm

    Lawrence
R. Lonergan, Esq.

    Partner

    Admitted
to the NY, NJ and MA Bar

    Writer’s Email: llonergan@wlesq.com

    96
    Park Street

    Montclair,
    NJ 07042

    Tel:
    973 641 4012

    Fax:
973 509 0063

     ______

    Woods
    Lonergan PLLC

    280
    Madison Avenue, Suite 300

    New
    York, NY 10016

    Tel:
    212 684 2500

    Fax:
    212 684 2512

    Reply
    to

    Montclair,
    NJ

November
20, 2023

United
State Securities and Exchange Commission

Division
of Corporation Finance

Office
of Finance

Washington,
D.C. 20459

    Attn:
    David
    Irving and Bonnie Baynes

    Re:

    Blue
    Chip Capital Group Inc.

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

    Filed
    October 23, 2023

    File
    No. 333-273760

Ladies
and Gentlemen:

This
Firm represents Blue Chip Capital Group, Inc. (the “Company”) with regard to the above-referenced submission. In response
to the staff’s comment letter dated November 3, 2023 (the “Staff Letter”), and for the staff’s convenience, we
have included each of the staff’s comments numbered sequentially followed by our response to each comment, also numbered sequentially.

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

    Comment
    1.
    Our
    Business, page 2

We
note your disclosure that you have recently organized a new 95% owned subsidiary in Brazil. Please revise your Exhibit 21.1 to include
this new subsidiary.

Response
1. We have revised the disclosure under Exhibit 21.1 to include our new 95% owned Brazilian subsidiary, Raisewise Brazil LTDA.

    Comment
    2.
    Management’s
    Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources, page 26

We
note your disclosure of $47,024 owed to related parties at May 31, 2023 on page 26 that appears excluded from your ASC 850 related party
disclosures on page 32 and Notes 4 on pages F-7 and F-18. Please tell us, and revise to disclose as necessary, the following:

    ●
    Separately
    state on the face of your consolidated financial statements all related party amounts and transactions pursuant to Rule 4-08(k) of
    Regulation S-X.

    ●
    Revise
    your notes to consolidated financial statements to include disclosure of each related party amount, nature, terms and manner of settlement,
    in compliance with ASC 850-10-50-1(d).

Response
2. In response to this comment, we have corrected the disclosures under the section Management’s Discussion and Analysis of
Financial Condition and Results of Operations, Liquidity and Capital Resources in the S-1/A Amendment No. 2, filed together with this
SEC Response Letter.

  Comment 3.
  Consolidated Balance Sheets,
page F-11

We
note your significant software application asset at May 31, 2023 and August 31, 2023. Please revise to disclose in your notes to consolidated
financial statements the nature and terms of this asset, including costs incurred, expenses capitalized and the accounting for depreciation,
or tell us why you removed the Software Application Note 6 since your prior filing.

Response
3. We have revised our filing to include Note 6 – Software Application for the annual financial statements for the years ended
May 31, 2023 and 2022 as well as the interim financial statements for the period ended August 31, 2023.

    Comment
    4.
  Consolidated Statements of Operations, page F-12

We
note your outstanding common stock warrants, Preferred A stock, note conversions, financial instrument, and that your weighted average
number of common shares used to compute your basic and diluted earnings per share for the periods ended May 31, 2022 and August 31, 2023
differ from the number of common shares issued and outstanding for those periods. We further note the removal of the Earnings (Loss)
per share disclosure in Note 3 of your prior filing. Please explain or revise to disclose the following:

    ●
    Please
    revise the notes to the Consolidated Financial Statements to include a reconciliation of the numerators and denominators of the basic
    and diluted per-share computations for each period to comply with ASC 260-10-50-1(a).

    ●
    Also
                                            revise the notes to the Consolidated Financial Statements to disclose the number of securities
                                            that could potentially dilute basic earnings per share in the future but that were not included
                                            in the computation of diluted earnings per share for the periods presented because they were
                                            anti-dilutive. Refer to the guidance in ASC 260-10-50- 1(c).

Response
4. In response to this comment, we have revised the disclosure in Consolidated Statement of Operations to include the Earnings (loss)
per share disclosure which describes the reconciliation of the numerator and denominator. We have not included a table as described by
ASC 260-10-50-1(a) as the Company is in a net loss position and all potentially dilutive securities would be anti-dilutive. The only
adjustments to the denominator are the weighted average share calculation for shares issued throughout the period. We have included the
number of potentially dilutive securities exercisable as described within ASC 260-10-50-1(c) within the policy footnote in footnote 3.

  Comment
  5.
  Note 1 - Organization and Business, page F-15

We
note your disclosure on page F-17 that your fair value estimates for May 31, 2023, are based on market assumptions available at November
30, 2021. Please explain your use of this non-current date and revise to clarify as appropriate.

Response
5. The date November 30, 2021 was included in error and has been revised and updated to reflect the periods of the financial statements.
The Company currently has no fair value assets or liabilities recorded on the face of the financial statements as of the dates reflected
within the financial statement periods.

Thank
you.

    Sincerely,

    /s/
    Lawrence R. Lonergan, Esq.

    Lawrence
    R. Lonergan, Esq.

    c:
    Blue
    Chip Capital Group, Inc.

Encs.

    2

United States securities and exchange commission logo
November 3, 2023
Joseph Richard Moran
Chief Executive Officer
Blue Chip Capital Group Inc.
269 South Beverly Drive – Suite 373
Beverly Hills, CA 90212
Re:Blue Chip Capital Group Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed October 23, 2023
File No. 333-273760
Dear Joseph Richard Moran:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
Amendment No. 1 to Registration Statement on Form S-1
Our Business, page 2
1.We note your disclosure that you have recently organized a new 95% owned subsidiary in
Brazil.  Please revise your Exhibit 21.1 to include this new subsidiary.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 26
2.We note your disclosure of $47,024 owed to related parties at May 31, 2023 on page 26
that appears excluded from your ASC 850 related party disclosures on page 32 and Notes
4 on pages F-7 and F-18.  Please tell us, and revise to disclose as necessary, the following:
•Separately state on the face of your consolidated financial statements all related party
amounts and transactions pursuant to Rule 4-08(k) of Regulation S-X.
•Revise your notes to consolidated financial statements to include disclosure of each
related party amount, nature, terms and manner of settlement, in compliance with
ASC 850-10-50-1(d).

 FirstName LastNameJoseph Richard Moran
 Comapany NameBlue Chip Capital Group Inc.
 November 3, 2023 Page 2
 FirstName LastName
Joseph Richard Moran
Blue Chip Capital Group Inc.
November 3, 2023
Page 2
Consolidated Balance Sheets, page F-11
3.We note your significant software application asset at May 31, 2023 and August 31,
2023.  Please revise to disclose in your notes to consolidated financial statements the
nature and terms of this asset, including costs incurred, expenses capitalized and
the accounting for depreciation, or tell us why you removed the Software Application
Note 6 since your prior filing.
Consolidated Statements of Operations, page F-12
4.We note your outstanding common stock warrants, Preferred A stock, note
conversions, financial instrument, and that your weighted average number of common
shares used to compute your basic and diluted earnings per share for the periods ended
May 31, 2022 and August 31, 2023 differ from the number of common shares issued
and outstanding for those periods.  We further note the removal of the Earnings (Loss) per
share disclosure in Note 3 of your prior filing.  Please explain or revise to disclose the
following:
•Please revise the notes to the Consolidated Financial Statements to include a
reconciliation of the numerators and denominators of the basic and diluted per-share
computations for each period to comply with ASC 260-10-50-1(a).
•Also revise the notes to the Consolidated Financial Statements to disclose the number
of securities that could potentially dilute basic earnings per share in the future but that
were not included in the computation of diluted earnings per share for the periods
presented because they were anti-dilutive. Refer to the guidance in ASC 260-10-50-
1(c).
Note 1 - Organization and Business, page F-15
5.We note your disclosure on page F-17 that your fair value estimates for May 31, 2023 are
based on market assumptions available at November 30, 2021.  Please explain your use of
this non-current date and revise to clarify as appropriate.
            Please contact David Irving at 202-551-3321 or Bonnie Baynes at 202-551-4924 if you
have questions regarding comments on the financial statements and related matters. Please
contact Eric Envall at 202-551-3234 or David Lin at 202-551-3552 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance

United States securities and exchange commission logo
August 8, 2023
Joseph Richard Moran
Chief Executive Officer
Blue Chip Capital Group Inc.
269 South Beverly Drive – Suite 373
Beverly Hills, CA 90212
Re:Blue Chip Capital Group Inc.
Registration Statement on Form S-1
Filed August 7, 2023
File No. 333-273760
Dear Joseph Richard Moran:
            We have limited our review of your registration statement to those issues we have
addressed in our comment.  In our comment, we may ask you to provide us with information so
we may better understand your disclosure.
            Please respond to this letter by amending your registration 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 registration statement and the information you
provide in response to this comment, we may have additional comments.
Form S-1 Filed August 7, 2023
General
1.Please be advised that we are deferring review of your Form S-1 filed August 7,
2023 until you update your stale financial statements.  Please update to include audited
financials for the years ended May 31, 2023 and 2022.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

 FirstName LastNameJoseph Richard Moran
 Comapany NameBlue Chip Capital Group Inc.
 August 8, 2023 Page 2
 FirstName LastName
Joseph Richard Moran
Blue Chip Capital Group Inc.
August 8, 2023
Page 2
            You may contact David Irving at (202) 551-3321 or Bonnie Baynes at (202) 551-4924 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Eric Envall at (202) 551-3234 or David Lin at (202) 551-3552 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance

United States securities and exchange commission logo
June 30, 2023
Joseph Richard Moran
Chief Executive Officer
Blue Chip Capital Group Inc.
269 South Beverly Drive – Suite 373
Beverly Hills, CA 90212
Re:Blue Chip Capital Group Inc.
Amendment No. 7 to
Draft Registration Statement on Form S-1
Submitted June 15, 2023
CIK No. 0001932213
Dear Joseph Richard Moran:
            We have reviewed your amended draft registration 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 7 to Draft Registration Statement on Form S-1
Business
The Company's Raisewise Subsidiaries and Material Terms of Contracts, page 22
1.Please revise to reconcile your disclosure regarding the company's percentage ownership
interests in Raisewise Sweden and Raisewise Morocco, respectively, on pages 22 and
Exhibit 21.1.  For example, your disclosure on page 22 indicates that Raisewise Morocco
is a 100% owned subsidiary of the company, while Exhibit 21.1 indicates that the
company owns 80% of Raisewise Morocco.  Additionally, your disclosure on page 22
states that Raisewise Sweden is a 80% owned subsidiary of the company, while Exhibit
21.1 indicates that the company owns 100% of Raisewise Sweden.  Please revise to

 FirstName LastNameJoseph Richard Moran
 Comapany NameBlue Chip Capital Group Inc.
 June 30, 2023 Page 2
 FirstName LastName
Joseph Richard Moran
Blue Chip Capital Group Inc.
June 30, 2023
Page 2
reconcile your disclosure or advise.
            You may contact David Irving at (202) 551-3321 or Bonnie Baynes at (202) 551-4924 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Eric Envall at (202) 551-3234 or David Lin at (202) 551-3552 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance

United States securities and exchange commission logo
June 8, 2023
Joseph Richard Moran
Chief Executive Officer
Blue Chip Capital Group Inc.
269 South Beverly Drive – Suite 373
Beverly Hills, CA 90212
Re:Blue Chip Capital Group Inc.
Amendment No. 6 to
Draft Registration Statement on Form S-1
Submitted May 26, 2023
CIK No. 0001932213
Dear Joseph Richard Moran:
            We have reviewed your amended draft registration 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
March 16, 2023 letter.
Amendment No. 6 to Draft Registration Statement on Form S-1
Exhibits
1.Please include an Exhibit Index in your next amendment and ensure that you number your
exhibits in accordance with the Exhibit Table.  Refer to Item 601(a)(2) of Regulation S-K.
2.We note that you have submitted several agreements with RaiseWise relating to your
crowdfunding platform as exhibits.  Please revise to disclose the material terms of these
agreements.
3.Please ensure each exhibit is in the proper text-searchable format. See Rules 301 and 304

 FirstName LastNameJoseph Richard Moran
 Comapany NameBlue Chip Capital Group Inc.
 June 8, 2023 Page 2
 FirstName LastName
Joseph Richard Moran
Blue Chip Capital Group Inc.
June 8, 2023
Page 2
of Regulation S-T.  For example, we note that the exhibits you have numbered as exhibits
1, 3, 4, 5 and 6 are not in text-searchable format.
4.Refer to your form of common stock purchase warrant submitted as Exhibit 4.1.  If this
document is the warrant that you intend to sell in this registered offering, please tell us
why the legend includes language regarding an unregistered offering.
5.We note your response to comment 8 and we partially reissue the comment.  Since the
warrants are contractual obligations issued pursuant to agreements, please file a revised
legality opinion that opines on whether the warrants will be a binding obligation of the
registrant under the law of the jurisdiction governing the common stock purchase
warrant.  For guidance, please refer to Staff Legal Bulletin 19.
            You may contact David Irving at (202) 551-3321 or Sharon Blume, Accounting Branch
Chief, at (202) 551-3474 if you have questions regarding comments on the financial statements
and related matters. Please contact Eric Envall at (202) 551-3234 or David Lin at (202) 551-
3552 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance

United States securities and exchange commission logo
March 16, 2023
Joseph Richard Moran
Chief Executive Officer
Blue Chip Capital Group Inc.
269 South Beverly Drive – Suite 373
Beverly Hills, CA 90212
Re:Blue Chip Capital Group Inc.
Amendment No. 5 to
Draft Registration Statement on Form S-1
Submitted March 2, 2023
CIK No. 0001932213
Dear Joseph Richard Moran:
            We have reviewed your amended draft registration 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 5 to Draft Registration Statement on Form S-1
Cover Page
1.We note your revisions in response to comment 2 from our letter dated July 19,
2022.  Please further revise to provide a cross-reference with the heading and page
number of the corresponding risk factor on page 10.  Also please revise the cover
page and the corresponding risk factor to identify your controlling shareholder and
disclose the percentage of your total voting power this shareholder will control following
the completion of this offering.
2.We refer to your disclosure in the third paragraph of the cover page regarding FINRA

 FirstName LastNameJoseph Richard Moran
 Comapany NameBlue Chip Capital Group Inc.
 March 16, 2023 Page 2
 FirstName LastNameJoseph Richard Moran
Blue Chip Capital Group Inc.
March 16, 2023
Page 2
approval of the symbols you request for the Units, shares of Common Stock, and the
Warrants.  In an appropriate location in your prospectus, please briefly explain the process
of receiving FINRA approval of any listing or trading symbols you would utilize.
Item 2 - Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 25
3.We note your response to comment 9 from our letter dated July 19, 2022. Please provide
us with additional information concerning the "ongoing and pending contracts" you have
in place with your subsidiaries that will help you meet short-term and long-term liquidity
requirements given that you have no revenues in the periods presented.  Include
the following in your response:
•Whether you have signed contracts with external counterparties;
•The terms of the contracts;
•Explain why the contracts are pending; and
•Explain in greater detail the specific contractual provisions related to royalties,
management fees, annual platform fees, etc.

Refer to Item 303 of Regulation S-K which states that discussion and analysis must focus
on material events and uncertainties known to management that are "reasonably likely" to
occur.  In the event these contracts are not reasonably likely, please remove the disclosure
from future amendments and revise your liquidity discussion accordingly.
Item 4 - Controls and Procedures, page 27
4.Please revise your next amendment to refer to the correct periods when disclosing
management's evaluation of disclosure controls and procedures and changes in internal
controls over financial reporting.  Please address the following:
•Reference to the interim period ended August 31, 2021 in the first sentence of the
first paragraph; and
•Reference to the period and quarter ended November 30, 2021 in the second sentence
of the second paragraph and first sentence of the third paragraph, respectively, which
is not the most recent period.
Description of Offered Securities, page 33
5.We note your revisions in response to comment 20 from our letter dated July 19, 2022.
Please further revise to include a description of the Units and the Warrants in the offering.
Please refer to Item 9 of Form S-1 and Item 202 of Regulation S-K.
Plan of Distribution
Placement Agent Agreement, page 34
6.We note your revisions in response to comment 10 from our letter dated July 19, 2022.
Please further revise to include a definition of the term "accredited investor."

 FirstName LastNameJoseph Richard Moran
 Comapany NameBlue Chip Capital Group Inc.
 March 16, 2023 Page 3
 FirstName LastName
Joseph Richard Moran
Blue Chip Capital Group Inc.
March 16, 2023
Page 3
Consolidated Financial Statements - November 30, 2022 and May 31, 2022
Notes to the Consolidated Financial Statements
Note 5. Stockholders' Equity, page F-19
7.We note your response to comment 16 from our letter dated July 19, 2022.  Please tell us,
with reference to applicable accounting literature, how you accounted for the warrants
issued on June 29, 2021, July 3, 2021, and November 9, 2022.
Exhibits
8.We note your response to comment 18 from our letter dated July 19, 2022 and reissue the
comment in part.  Please have counsel revise the legality opinion to opine on the Units and
each security component thereof. In particular, please revise to address the following
points:
•Clearly opine that the common stock included in the Units will be, when sold, legally
(or validly) issued, fully paid and non-assessable
•Clearly opine that the common stock underlying the warrants will be, when sold,
legally (or validly) issued, fully paid and non-assessable.
•Since the warrants are contractual obligations issued pursuant to agreements, please
file a revised legality opinion that opines on whether the warrants will be a binding
obligation of the registrant under the law of the jurisdiction governing the common
stock purchase warrant. In that regard, we note that the opinion does not indicate that
the warrants will be the binding obligation of the registrant, and the opinion is limited
to the laws of Nevada. However, the form of common stock purchase warrant filed as
Exhibit 4.1 indicates that the warrant will be governed by the laws of the State of
Delaware.

For guidance, please refer to Staff Legal Bulletin 19.

            You may contact David Irving at (202) 551-3321 or Sharon Blume, Accounting Branch
Chief, at (202) 551-3474 if you have questions regarding comments on the financial statements
and related matters. Please contact Eric Envall at (202) 551-3234 or David Lin at (202) 551-
3552 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance

United States securities and exchange commission logo
February 3, 2023
Joseph Richard Moran
Chief Executive Officer
Blue Chip Capital Group Inc.
269 South Beverly Drive – Suite 373
Beverly Hills, CA 90212
Re:Blue Chip Capital Group Inc.
Amendment No. 4 to
Draft Registration Statement on Form S-1
Submitted January 31, 2023
CIK No. 0001932213
Dear Joseph Richard Moran:
            We have reviewed your amended draft registration 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 4 to Draft Registration Statement on Form S-1
General
1.Please be advised that we are deferring review of your amendment submitted January 31,
2023, as it is not substantially complete. For example:
•Please update to include unaudited interim financials for the period ended November
30, 2022.  If you omitted interim financial statements in reliance on section 71003 of
the Fixing America's Surface Transportation Act (FAST Act), and our guidance
in Question 1 in the FAST Act C&DIs issued on August 17, 2017, advise us in
writing;
•Please update Management’s Discussion and Analysis, specifically in the Forward-

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Joseph Richard Moran
Blue Chip Capital Group Inc.
February 3, 2023
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Looking Statements on page 25, to correct periods presented; and
•Please update Item 4 (Controls and Procedures) to reflect the correct periods
presented.
            You may contact David Irving at (202) 551-3321 or Sharon Blume, Accounting Branch
Chief, at (202) 551-3474 if you have questions regarding comments on the financial statements
and related matters. Please contact Eric Envall at (202) 551-3234 or David Lin at (202) 551-
3552 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance

United States securities and exchange commission logo
December 5, 2022
Joseph Richard Moran
Chief Executive Officer
Blue Chip Capital Group Inc.
269 South Beverly Drive – Suite 373
Beverly Hills, CA 90212
Re:Blue Chip Capital Group Inc.
Amendment No. 3 to
Draft Registration Statement on Form S-1
Submitted November 30, 2022
CIK No. 0001932213
Dear Joseph Richard Moran:
            We have reviewed your amended draft registration 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 3 to Draft Registration Statement on Form S-1
General
1.
Please be advised that we are deferring review of your amendment submitted November
30, 2022, as it is not substantially complete. For example:
•Please update to include unaudited interim financials for the period ended August 31,
2022. If you omitted interim financial statements in reliance on section 71003 of the
Fixing America's Surface Transportation Act (FAST Act), and our guidance
in Question 1 in the FAST Act C&DIs issued on August 17, 2017, advise us in
writing;

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 FirstName LastName
Joseph Richard Moran
Blue Chip Capital Group Inc.
December 5, 2022
Page 2
•You continue to include unaudited interim financial statements for the periods ended
February, 28, 2022 and February 28, 2021 in your filing. Please revise accordingly;
•Please update Management’s Discussion and Analysis, including Results of
Operations and Liquidity, to reflect the most recent periods presented; and
•Please update Item 4 (Controls and Procedures) to reflect the most recent periods
presented.
            You may contact David Irving at (202) 551-3321 or Sharon Blume, Accounting Branch
Chief, at (202) 551-3474 if you have questions regarding comments on the financial statements
and related matters.  Please contact Eric Envall at (202) 551-3234 or David Lin at (202) 551-
3552 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance

United States securities and exchange commission logo
July 19, 2022
Joseph Richard Moran
Chief Executive Officer
Blue Chip Capital Group Inc.
269 South Beverly Drive – Suite 373
Beverly Hills, CA 90212
Re:Blue Chip Capital Group Inc.
Draft Registration Statement on Form S-1
Submitted June 22, 2022
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted July 1, 2022
CIK No. 0001932213
Dear Mr. Moran:
            We have reviewed your draft registration 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1
Cover page
1.We note your disclosure regarding the possible quotation of your securities on the OTC
Market.  Please revise this disclosure prior to effectiveness to provide more details
regarding the potential quotation or listing, such as the status of any applications for
listing that you have made.  Please also reconcile your disclosure with the last risk factor
on page 12 referencing the possible listing of your securities on the "Nasdaq Stock Market
or on another national securities exchange."

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2.Please disclose on the cover page that following the offering you will be a "controlled
company." Include a cross-reference where you describe the definition and ramifications
of being a "controlled company" in a new risk factor as well.
Prospectus Summary, page 2
3.We note your disclosure at the top of page 2 referencing the company's name
as "Investview, Inc.," which appears to be a clerical error.  Please revise or advise.
4.Please prominently disclose here that you have incurred net losses in each fiscal quarter
since inception and that your auditors have expressed substantial doubt about your ability
to continue as a going concern, as disclosed elsewhere.
Our Business, page 2
5.Please provide support for your assertions and descriptions of Lending Club, Funding
Circle Holdings PLC and SeedInvest.  If these statements are solely your opinions, please
clearly state as such.
6.We note your disclosures in this section and in the Business section regarding your named
competitors.  Please provide more details regarding how you are currently competing with
these companies when it does not appear that you have begun operations.
7.Please provide more details regarding what your intellectual properties center upon and
how that can be monetized.  Include a discussion of the term "White Labeling," as
referenced on page 6.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
25
8.Please revise your next amendment to discuss interim period results as required by Item
303 of Regulation S-K.
9.We note your disclosure on page 25 that you have, "ongoing and pending contracts that
are expected to generate operating cash to support operations well into 2022" despite the
fact that you do not appear to have any revenues from operations.  We further note your
liquidity disclosure that you, "have cash reserves and cash commitments available to fund
operations through the end of the year or longer."  Please revise your next amendment to
address the disclosure requirements in Item 303 of Regulation S-K regarding liquidity.
Specifically, address your ability to meet requirements in the short-term (the next 12
months from the most recent fiscal period end) and in the long-term (beyond the next 12
months).
Plan of Distribution, page 34
10.We note your disclosure regarding the potential use of placement agents and that you
intend to utilize multiple closings of your offering.  Please revise your disclosure to clarify

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the mechanics of your offering.  Please also reconcile your disclosure in this section that
the Units "are" being offered by your officers and directors with your cover page
disclosure that your management "may" participate in the offering of the Units.  We may
have further comments based upon your revised disclosure.
Placement Agent Agreement, page 34
11.Please define the term "Qualified Investors," as your disclosure references on page 34.
Audited Financial Statements for the Years Ended May 31, 2021 and 2020
Note 4 - Related Parties, page F-9
12.Please tell us the accounting guidance you relied upon for the forgiveness of payables by a
related party.  Further, tell us how you determined that the forgiveness resulted in an
expense of $56,900 in 2021.
Note 5 - Stockholders Equity, page F-9
13.Please tell us how you considered the guidance in Rule 5-02-27 of Regulation S-X
concerning the classification of Preferred Stock within Stockholders' Equity.
Note 6 - Software Application, page F-9
14.Please provide us with your basis in authoritative accounting literature for capitalizing
costs incurred related to the ongoing production of your development stage software
application. Refer to ASC 985-20-25.
Unaudited Financial Statements for the Period Ended February 28, 2022 and 2021, page F-11
15.Please revise your next amendment to reflect the correct period for the comparable income
statement and cash flows of February 28, 2021 in the Table of Contents.
Note 3 - Summary of Significant Accounting Policies
Warrants, page F-18
16.We note your sale of shares of 3,040,000 shares for $95,000 during June and July 2021.
As part of the agreement, you issued warrants with escalating strike prices.  Please tell us
how you considered the guidance in ASC 815-40-25 related to the sale and the potential
allocation of the proceeds to warrants.
Note 4 - Joint Venture, page F-20
17.Please tell us the following concerning Raisewise Sweden referenced in Note 4:
•Do you account for Raisewise Sweden as a consolidated, wholly-owned subsidiary or
an equity method joint venture;
•How are you accounting for the investment in the development of the web platform
that is valued at $250,000 given that there is no intellectual property on the Balance

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Sheet in the periods presented;
•Has the transaction been cash settled with Medcap LTD?  If so, how was it accounted
for in the financial statements.
Exhibits
Exhibit 5.1, page II-2
18.Please have counsel revise the legality opinion to opine on the Units and each security
component thereof.  In particular, please revise to address the following points:
•Please provide a binding obligation opinion with respect to the legality of the Units.
•Clearly opine that the common stock included in the Units will be, when sold, legally
(or validly) issued, fully paid and non-assessable.
•Clearly opine that the common stock underlying the warrants will be, when sold,
legally (or validly) issued, fully paid and non-assessable.
•Since the warrants are contractual obligations issued pursuant to agreements,
please file a revised legality opinion that opines on whether the warrants will be a
binding obligation of the registrant under the law of the jurisdiction governing the
common stock purchase warrant.  In that regard, we note that the opinion does not
indicate that the warrants will be the binding obligation of the registrant, and the
opinion is limited to the laws of Nevada.  However, the form of common stock
purchase warrant filed as Exhibit 4.1 indicates that the warrant will be governed by
the laws of the State of Delaware.

For guidance, please refer to Staff Legal Bulletin 19.
General
19.Please provide us with supplemental copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
have presented or expect to present to potential investors in reliance on Section 5(d)of the
Securities Act, whether or not you retained, or intend to retain, copies of those
communications.  Please contact the staff member associated with the review of this
submission to discuss how to submit the materials, if any, to us for our review.
20.We note that in Amendment No. 1 you removed your previous disclosure in the section
headed "Description of the Offered Securities."  Please restore this disclosure or explain to
us why it was deleted.

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 FirstName LastName
Joseph Richard Moran
Blue Chip Capital Group Inc.
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            You may contact Jacob Luxenburg at (202) 551-2339 or David Irving at (202) 551-3321
if you have questions regarding comments on the financial statements and related matters.
Please contact Eric Envall at (202) 551-3234 or David Lin at (202) 551-3552 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance