SecProbe.io

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 DUKE ROBOTICS CORP.

 10 HaRimon Street

 Mevo Carmel Science and Industrial Park, Israel

 May 13, 2026

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 United States Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Duke Robotics Corp. (CIK 0001638911)

 Registration Statement on Form S-1 (File No. 333-294808) (the "Registration Statement")

 Request for Acceleration of Effective Date

 Dear Mesdames:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended (the "Securities Act"), Duke Robotics Corp. (the "Registrant") hereby
requests that the effective date of the above-referenced Registration Statement be accelerated so that it will be declared effective on
May 14, 2026 at 4:15 p.m., Eastern Time, or as soon as practicable thereafter.

 The Registrant respectfully
requests that it be notified of such effectiveness by a telephone call to Ron Ben-Bassat, Esq. of Sullivan & Worcester LLP at (212)
660-5003 and that such effectiveness also be confirmed in writing. The Company hereby authorizes Mr. Ben-Bassat of Sullivan & Worcester
LLP to orally modify or withdraw this request for acceleration.

 Very truly yours,

 Duke Robotics Corp.

 By:
 /s/ Yossef Balucka

 Name:
 Yossef Balucka

 Title:
 Chief Executive Officer

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 Maxim Group LLC

 300 Park Avenue, 16th Floor

 New York, New York 10022

 May 13, 2026

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, DC 20549

 Re:
 DUKE Robotics Corp.

 Registration Statement on Form S-1, as amended File No: 333-294808 (the "Registration Statement")

 Ladies and Gentlemen:

 Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission (the " Commission ")
under the Securities Act of 1933, as amended (the " Securities Act "), Maxim Group LLC, as representative of the
underwriters, hereby joins the request of DUKE Robotics Corp. (the " Company ") that the effective date of the
above-referenced Registration Statement be accelerated so that it will become effective at 4:15 p.m. Eastern Time on Thursday, May
14, 2026 , or as soon thereafter as practicable.

 Pursuant to Rule 460 of the General Rules and
Regulations of the Commission under the Securities Act, please be advised that there will be distributed to each underwriter or dealer,
who is reasonably anticipated to participate in the distribution of the securities in this offering, as many copies of the preliminary
prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

 The undersigned
confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating dealers
that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection
with the above-referenced issue.

 Very truly yours,

 Maxim Group LLC

 By:
 /s/ Ritesh Veera

 Name:
 Ritesh Veera

 Title:
 Co-Head of Investment Banking

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 December 30, 2025

Yossef Balucka
Chief Executive Officer
DUKE Robotics Corp.
10 HaRimon Street
Mevo Carmel Science and Industrial Park
Israel, 2069203

 Re: DUKE Robotics Corp.
 Draft Registration Statement on Form S-1
 Submitted on December 22, 2025
 CIK 0001638911
Dear Yossef Balucka:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement and
non-public draft
submission on EDGAR at least two business days prior to the requested effective
date and
time. 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 Sarah Sidwell at 202-551-4733 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
cc: Ron Ben-Basset
</TEXT>
</DOCUMENT>

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UAS
DRONE CORP.

1 Etgar Street

Tirat-Carmel, Israel 3903212

June 17, 2020

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

    Re:

        UAS Drone Corp. (CIK: 0001638911)

        Registration Statement No. 333-237927 on Form S-1 (the “Registration
        Statement”)

Ladies and Gentlemen:

UAS Drone Corp. (the “Registrant”)
hereby requests acceleration of the effectiveness of the above-referenced Registration Statement pursuant to Rule 461 under the
Securities Act of 1933, as amended (the “Securities Act”), so that it may become effective on June 19, 2020,
at 4:30 p.m., Eastern Time, or as soon thereafter as is practicable.

The Registrant understands
that the Securities and Exchange Commission will consider this request for acceleration of the effective date of the Registration
Statement as a confirmation of the fact that the Registrant is aware of its responsibilities under the Securities Act and the Securities
Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the Registration
Statement.

Very truly yours,

UAS DRONE CORP.

By: /s/ Shlomo Zakai

Shlomo Zakai, Chief Financial Officer

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UAS
DRONE CORP.

1 Etgar Street

Tirat-Carmel, Israel 3903212

May 26, 2020

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington, DC 20549

Attention: Erin M. Purnell, Esq.

    Re:

        UAS Drone Corp. (the “Company”)

        Registration Statement on Form S-1

        Filed April 30, 2020

        File No. 333-237927

Dear Ms. Purnell	:

The purpose of this letter is to respond to
the comments of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange
Commission as set forth in your letter of May 11, 2020, regarding the above referenced Registration Statement on Form S-1 (the
“Registration Statement”). For your convenience, your original comments appear in bold, followed by our response.

General

 1. We note your registration statement covers the offer and sale of common stock to be issued to
certain stockholders of Duke upon the consummation of a short-form merger agreement.  It appears you may have commenced this
transaction privately, on or about April 29, 2020, when you executed the merger agreement. Please note that a transaction
commenced privately cannot be converted to a registered offering. Please refer to Securities Act Sections Compliance and Disclosure Interpretations
Question 134.02.

RESPONSE:

The Company acknowledges
that, pursuant to Securities Act Sections Compliance and Disclosure Interpretations (“CD&I”) Question 134.02, a
private offering may not be converted into a registered offering. For the reasons set forth below, the Company did not commence
a private offering relating to the shares issuable to certain Duke stockholders pursuant to the short-form merger agreement and
believes the primary offering to certain stockholders of Duke (the “Duke Primary Offering Stockholders”), as contemplated
by the Registration Statement, is the sole offering of such securities (the “Primary Offering”). Such interpretation
is consistent with the Company’s discussions with the Staff prior to the filing of the Registration Statement.

On March 9, 2020, the Company
closed on a Share Exchange Agreement (the “Share Exchange Agreement”), pursuant to which Duke became a majority-owned
subsidiary of the Company (the “Share Exchange”). Certain stockholders of Duke were a party to the Share Exchange but
none of those stockholders are the Duke Primary Offering Stockholders. The Share Exchange closed on March 9, 2020, and as a result
of such closing, the Company adopted the business plan of Duke.

Securities and Exchange Commission

May 26, 2020

Page 2

With respect to the Registration
Statement, immediately prior to its filing, on April 29, 2020, the Company, Duke and UAS Acquisition Corp., a Delaware corporation
and a newly formed wholly-owned subsidiary of the Company (“UAS Sub”), executed an Agreement and Plan of Merger (the
“Merger Agreement”), pursuant to which UAS Sub intends to be merged with and into Duke, with Duke surviving as a wholly-owned
subsidiary of the Company (the “Short-Form Merger”). Importantly, none of the Duke Primary Offering Stockholders were
solicited to approve or execute the Merger Agreement and neither the Company, nor Duke or UAS Sub discussed or otherwise disclosed
to the Duke Primary Offering Stockholders the fact that the Merger Agreement was being negotiated or executed. In addition, none
of the Duke Primary Offering Stockholders reviewed the Registration Statement or knew it was being filed with the Securities and
Exchange Commission, prior to its filing. Finally, pursuant to the terms of the Merger Agreement, the agreement contemplates a
closing only upon the consummation of the Primary Offering, thus providing further evidence that no private placement offering
was ever contemplated. Therefore, the Company does not believe an offering was ever commenced or conducted prior to the filing
of the Registration Statement, whether publicly or privately.

For the foregoing
reasons, we believe that no private transaction with respect to the Duke Primary Offering Stockholders was ever commenced and consequently
CD&I 134.02 is not relevant under the current circumstances.

Please do not hesitate to call the Company’s
counsel, Ron Ben-Bassat, of Sullivan & Worcester LLP, at (212) 660-5003 with any questions or further comments you may have
regarding this letter.

* * *

Sincerely,

UAS DRONE CORP.

    By:
    /s/ Sagiv Aharon

    Chief Executive Officer and President

cc:  Ron Ben-Bassat, Esq.

United States securities and exchange commission logo
May 11, 2020
Erez Nachtomy
Interim Chief Financial Officer
UAS Drone Corp.
1 Etgar Street
Tirat Carmel, Israel, 3903212
Re:UAS Drone Corp.
Registration Statement on Form S-1
Filed April 30, 2020
File Number 333-237927
Dear Mr. Nachtomy:
            We have limited our review of your registration statement to those issues we have
addressed in our 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 registration 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 registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-1
General
1.We note your registration statement covers the offer and sale of common stock to be
issued to certain stockholders of Duke upon the consummation of a short-form merger
agreement.  It appears you may have commenced this transaction privately, on or about
April 29, 2020, when you executed the merger agreement. Please note that a transaction
commenced privately cannot be converted to a registered offering. Please refer to
Securities Act Sections Compliance and Disclosure Interpretations Question 134.02.
            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.

 FirstName LastNameErez Nachtomy
 Comapany NameUAS Drone Corp.
 May 11, 2020 Page 2
 FirstName LastName
Erez Nachtomy
UAS Drone Corp.
May 11, 2020
Page 2
            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.
            Please contact Erin Purnell at 202-551-3454 or Jay Ingram at 202-551-3397 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

United States securities and exchange commission logo
May 1, 2020
Sagiv Aharon
Chief Executive Officer and President
UAS Drone Corp.
1 Etgar Street
Tirat-Carmel, Israel 3903212
Re:UAS Drone Corp.
Form 8-K
Filed March 10, 2020
File No. 000-55504
Dear Mr. Aharon:
            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 Manufacturing
cc:       Ron Ben-Bassat, Esq.

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UAS
DRONE CORP.

1 Etgar Street

Tirat-Carmel, Israel 3903212

April 23, 2020

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Attention: Edward M. Kelly, Senior Counsel

    Re:

        UAS Drone Corp. (the “Company”)

        Current Report on Form 8-K

        Filed March 10, 2020

        File No. 000-55504

Dear Mr. Kelly:

The purpose of this letter is to respond to the comments of the
staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission as set forth
in your letter of April 6, 2020, regarding the above referenced Current Report on Form 8-K. For your convenience, your original
comments appear in bold, followed by our response. We are concurrently filing Amendment No. 1 to Current Report on Form 8-K (“Amendment
No. 1”). Page references in our response are to Amendment No. 1.

General

 1. Notwithstanding the inconsistent disclosures on page 17 that your common stock is traded on the OTC Pink Current Information
tier of the OTC Bulletin Board, on page 27 that your common stock is traded on the OTCBB, and on page 30 that your common
stock is traded on the OTCQB, the website of OTC Markets Group, Inc. indicates that your common stock is quoted on the OTC Pink
Marketplace.  Please revise.  Additionally, note that none of the three OTC marketplaces, OTCQX, OTCQB, and OTC Pink,
has a relationship or connection with the OTCBB.  Please remove any reference to the OTCBB in the context of disclosure relating
to any of the three OTC marketplaces.

Response: We have revised to reflect that our common stock
is traded on the OTC Pink Current Information Tier and also removed all references to the OTCBB.

Exhibit 99.1

Unaudited Pro Forma Condensed Combined Financial Information

Unaudited Pro Forma Condensed Combined Balance Sheet, page
2

    2.
    Please tell us how the $400,000 adjustment to long term convertible notes payable relates to the information provided in footnote 2a.

Response: The total current liabilities of the Company, excluding
account payables, totaled $800,000 as of September 30, 2019. Out of this amount, $400,000 were converted into 10,433,542 shares
as stated in footnote 2a to the pro forma financial statements, and an additional $400,000 was exchanged for new debentures
in the aggregate amount of $400,000 to the debt holders, Alpha Capital Anstalt and GreenBlock Capital LLC.

Securities and Exchange Commission

April 23, 2020

Page 2

    3.
    Please provide us the detailed adjustments that comprise the $1,629,000 aggregate adjustment to stockholders’ deficit.

Response: The requested details are found below:

    Adjustments of Stockholders' Deficit (in thousands):

    Conversion of balances - UAS Drone Corp.

    Account payables

    $
    33

    Other accounts liabilities & advances from stockholders

    & convertible note payable

    $
    400

    Promissory note payable

    $
    35

    $
    468

    Conversion of balances - Duke Robotics Inc.

    Stockholders loans

    $
    718

    Convertible loan

    $
    443

    $
    1,161

    TOTAL

    $
    1,629

* * *

Sincerely,

UAS DRONE CORP.

    By:
    /s/ Erez Nachtomy

    Vice Chairman and Interim Chief Financial Officer

April 6, 2020
Sagiv Aharon
Chief Executive Officer and President
UAS Drone Corp.
1 Etgar Street
Tirat-Carmel, Israel 3903212
Re:UAS Drone Corp.
Form 8-K
Filed March 10, 2020
File No. 000-55504
Dear Mr. Aharon:
            We have reviewed your filing and have the following comments.  In some of our
comments we may ask you to provide us information so that we may better understand your
disclosure.
            Please respond to these comments within 10 business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe that
our comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Current Report on Form 8-K filed March 10, 2020
General
1.Notwithstanding the inconsistent disclosures on page 17 that your common stock is traded
on the OTC Pink Current Information tier of the OTC Bulletin Board, on page 27 that
your common stock is traded on the OTCBB, and on page 30 that your common stock is
traded on the OTCQB, the website of OTC Markets Group, Inc. indicates that your
common stock is quoted on the OTC Pink Marketplace.  Please revise.  Additionally, note
that none of the three OTC marketplaces, OTCQX, OTCQB, and OTC Pink, has a
relationship or connection with the OTCBB.  Please remove any reference to the OTCBB
in the context of disclosure relating to any of the three OTC marketplaces.

 FirstName LastNameSagiv Aharon
 Comapany NameUAS Drone Corp.
 April 6, 2020 Page 2
 FirstName LastName
Sagiv Aharon
UAS Drone Corp.
April 6, 2020
Page 2
Exhibit 99.2
Unaudited Pro Forma Condensed Combined Financial Information
Unaudited Pro Forma Condensed Combined Balance Sheet, page 2
2.Please tell us how the $400,000 adjustment to long term convertible notes payable relates
to the information provided in footnote 2a.
3.Please provide us the detailed adjustments that comprise the $1,629,000 aggregate
adjustment to stockholders’ deficit.
            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.
            You may contact Dale Welcome, Staff Accountant, at (202) 551-3865 or Kevin W.
Stertzel, Staff Accountant, at (202) 551-3723 if you have questions regarding comments on the
financial statements and related matters.  Please contact Edward M. Kelly, Senior Counsel, at
(202) 551-3728 or Sherry Haywood, Senior Counsel, at (202) 551-3345 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Ron Ben-Bassat, Esq.

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FUTURE HEALTHCARE OF AMERICA    UAS DRONE CORP.

 420 ROYAL PALM WAY

 SUITE 100

 PALM BEACH, FLORIDA  33480

 (561) 693-1421

 September 3, 2015

 J. Nolan Williams

 U. S. Securities and Exchange Commission

 100 F Street, N.E.

 Washington, DC  20549

 Re:       Registration Statement on Form S-1 of UAS Drone Corp., a Nevada corporation

             (the “Company”)

 Commission File No. 333-206561

 Dear Mr. Williams:

 The Company respectfully requests acceleration of effectiveness of the above-referenced Registration Statement to 4:30 p.m. EDT on Tuesday, September 15, 2015, or as soon thereafter as is possible.

 The Company acknowledges that:

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

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

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

 Thank you very much.

 UAS DRONE CORP., a Nevada corporation

 By /s/ Chad Swan

 Chad Swan, Chief Executive Officer

July 28, 2015

Chad Swan
Chief Executive Officer
UAS Drone Corp.
420 Royal Palm Way, Suite 100
Palm Beach, FL 33480

Re: UAS Drone Co rp.
  Amendment No. 2  to Draft Registration Statement on Form  S-1
Submitted July 21, 201 5
  CIK  No. 0001638911

Dear Mr. Swan :

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 c omments 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.

Prospectus Cover Page

1. We note your response to prior comment 2.  Please clarify here and throughout that the
selling shareholders will sell the shares pursuant to this offering at the fixed  price of
$1.00 per share until th e shares are quoted on the OTCQB  at which time they may sell the
shares at the prevailing market prices  or at privately negotiated prices .

Prospectus Summary , page 6

2. It appears that an event of default under the Securit ies Purchase Agreement has occurred
because  the registration  has not been declar ed effective and the shares underlying the
debenture with Alpha Capital Anstalt have not been registered by the date specified in the

Chad Swan
UAS Drone Corp.
July 28, 2015
Page 2

 agreement.  Please revise your disclosure to indicate that an event of default has occurred
and discuss  the effect of this event of default here and in your risk factors section, as
appropriate.

You may contact Theresa Messinese  at (202) 551 -3307  or Doug Jones  at (202) 551 -3309
if you have questions regarding comments on the financial statements and related matters.
Please contact Sonia Bednarowski  at (202) 551 -3666  or me at (202) 551 -3217 with any other
questions.

Sincerely,

 /s/ J. Nolan McWilliams

 J. Nolan McWilliams
Attorney -Advisor

cc: Branden T. Burningham, Esq.

July 14 , 2015

Chad Swan
Chief Executive Officer
UAS Drone Corp.
420 Royal Palm Way, Suite 100
Palm Beach, FL 33480

Re: UAS Drone Co rp.
  Amendment No. 1 to Draft Registration Statement on Form  S-1
Submitted June 29 , 201 5
  CIK  No. 0001638911

Dear Mr. Swan :

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.

General

1. We note your response to our prior comment 3 .  Please disclose the information pursuant
to Item 201(a)(2)(ii) of Regulation S -K.

Prospectus Cover Page

2. We note your response to our prior comment 6 .  Plea se specify  here and throughout the
fixed price per share of the common stock offered by the selling stockholders until your
shares are quoted on the OTCQB.  In this regard, we note your disclosure that the
“Selling Stockholders will se ll their shares of common stock at such fixed prices as they
may negotiate.”

Chad Swan
UAS Drone Corp.
July 14 , 2015
Page 2

 3. We note your response to prior  comment  7.  Please disclose the net proceeds to be
received  by selling stockholders assuming all shares are sold at the initial fixed offering
price.

Use of Proceeds, page 15

4. We note your response to our prior comment 14 .  Please reconcile this section with your
revised disclosure on page 23 so that investors understand how you intend to use the
proceeds received under the various scenarios in this offering to implement  the business
plan discussed on page 23.

Executive Compensation, page 31

5. We note your response to our prior comment 19.  Ple ase revise your disclosure in the
Outstanding Equity Awards at Fiscal Year -End to include all named executive officers
for fiscal year 2014.  In addition, we note your response to our prior comment 20 .  David
Sweeny is not included in your summary  compensation table on page 31.  Please revise
or advise.

Exhibit 5.1

6. We note your response to our prior comment 28 and reissue.  Please have counsel provide
its opinion regarding the secondary offering.  In this regard, we note that counsel states
that when “issued/sold . . . the Common stock will be  legally issued, fully paid and non -
assessable.” (emphasis  added).  However,  as the shares of common stock  in the
secondary offering  will have  already been issued , please have counsel provide an opinion
that the shares of common stock  in the secondary offering  are legally issued, fully paid,
and nonassessable .

You may contact Theresa Messinese  at (202) 551 -3307  or Doug Jones  at (202) 551 -3309
if you have questions regarding comments on the financi al statements and related matters.
Please contact Sonia Bednarowski  at (202) 551 -3666  or me at (202) 551 -3217 with any other
questions.

Sincerely,

  /s/ J. Nolan McWilliams

 J. Nolan McWilliams
Attorney -Advisor

cc: Branden T. Burningham, Esq.

June 18, 2015

Chad Swan
Chief Executive Officer
UAS Drone Corp.
420 Royal Palm Way, Suite 100
Palm Beach, FL 33480

Re: UAS Drone Co rp.
  Draft Registration Statement on Form  S-1
Submitted May 22 , 201 5
  CIK  No. 0001638911

Dear Mr. Swan :

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.

General

1. Please provide us with copies of all written communications, as defined in Rule 405
under the Securities Act, that you , or anyone a uthorized to do so on your behalf , present
to potential investors in reliance on Section 5(d) of the Securities Act, whether or not they
retain copies of the communications.

2. Please provide us with a detailed analysis for determining that the offering by t he selling
shareholders is appropriately characterized as a secondary offering that is eligible to be
made pursuant to Rule 415(a)(1)(i) of the Securities Act.  We note that you are
registering the resale of a significant percentage of your issued and outs tanding shares of
common stock  held by non -affiliates , that Green Block Capital LLC , a company in which

Chad Swan
UAS Drone Corp.
June 18, 2015
Page 2

 your sole director is the managing partner,  purchased shares of your common stock in a
private offering on March 3, 2015 , and that Alpha Capital  Anstalt purchased the
convertible debenture  in a private offering on April 1, 2015.  We may have further
comment upon review of your response.  For guidance, refer to Securities Act Rule s
Compliance and Disclosure Interpretations Question 612.09  located on our web site at
http://www.sec.gov/divisions/corpfin/guidance/securitiesactrules -interps.htm .

3. Please disclose the information pursuant to Item 201(a)(2)(i) and (ii) of Re gulation S -K.
4. Prior to printing and distribution of the preliminary prospectus, please provide us with
mock -ups of any pages that include any pictures or graphics to be presented.
Accompanying captions, if any, should also be provided.  We may have comme nts after
reviewing the materials.

Registration Cover Page

Calculation of Registration Fee, page 2

5. Please identify the provision of Rule 457 under the Securities Act that you used to
calculate the fee.

Prospectus Cover Page , page 3

6. We note your disclosure on page 8 that the selling shareholders are offering their shares
at “[m]arket prices prevailing at the time of sale, at prices related to the prevailing market
prices, at negotiated prices or at fixed prices, all of which may chang e” and your
disclosure on page 3 that your common stock is not currently quoted on any market.”  As
there is no existing marke t for your common stock, revise your prospectus cover page to
specify the fixed price per share until your shares are quoted on th e OTCQB and explain
that thereafter the selling shareholders will offer the shares at prevailing market prices or
at privately negotiated prices to the extent the offering is appropriate ly characterized as a
secondary offering eligible to be made pursuant to Rule 415(a)(1)(i) of the Securities Act.

7. Please disclose the selling shareholders’ net proceeds if all of the shares of common stock
are sold.

Forward -Looking Statements and Certain Terminology, page 5

8. Please remove any reference s to the safe harbor s under Section 27A of the Securities Act
and Section 21E of the Exchange Act as these provisions are not available for an initial
public offering or for penny stock issuers.

Chad Swan
UAS Drone Corp.
June 18, 2015
Page 3

 Prospectus Summary, page 6

9. Please disclose  here that your independent auditor  has expressed substantial doubt about
your ability to continue as a going concern and that you are a development stage
company.  In addition , please  disclose an estimate of the amount of capital necessary to
accomplish your business pla ns, that you have yet to earn revenues, and your net losses
from your most recently complete d fiscal year and interim stub .

10. Please briefly discuss the risks of dilution  associated with your failure to obtain quotation
for your common stock within 90 days of the effective date of the registration statement
and disclose whether you have taken any  steps to arrange for a broker dealer to apply to
have your shares quoted on the OTCQB .  In this regard, we note your disclosure on page
12 that the failure to obtain quotations for your common stock within 90 days of
effectiveness w ould result in an Event of Default under the terms of the Debenture held
by Alpha Capital.

Risk Factors, page 9

11. We note your disclosure on page F -15 regarding conflicts of interests your executive
officers and director have with your company.  Please disclose such conflicts in your risk
factor section.

12. We note that you intend to sell your products to the U.S. military and law enforcement
agencies.  To the extent material , please ad d a risk factor discussing the e ffect export
control regulations  and the ability of the U.S. Government to terminate contracts for its
own convenience could have on your business.

Risks Relating to Our Business and Industry, page 9

Because our executive officers collectively own a majority, page 10

13. Please briefly describe the risks addressed in this risk factor in your prospectus summary
section.

Use of Proceeds, page 14

14. Please reconcile the anticipated uses of the proceeds with your revised disclosure with
respect to your plan of operations, liquidity, and capital expenditures .  Refer to
Instruction 2 to Item  504 of Regulation S -K.

Selling Stockholders, page 16

15. We note your disclosure on page 16 that the failure to obtain listing or quotation for
trading of your common stock on a n applicable trading market by October 13, 2015 will

Chad Swan
UAS Drone Corp.
June 18, 2015
Page 4

 result in an Event of Default and your disclosure on page 12 that you must obtain
quotation within 90 days of the effective date of the registration statement  to avoid an
Event of Default .  Please revise  here and throughout for consistency and clarity.

16. Please clarify  the effect of an Event of Default by definin g the “Mandatory Default
Amount, ” and disclose such amount here and in your prospectus summary section.

17. We note your disclosure th at your selling stockholder table does  not include shares
underlying warrants or convertible securities other than the share s of common stock
issuable upon conversion of the Debenture.  Please revise this table to include the
underlying shares of any warrants  or convertible securities that the selling stockholders
are deemed to beneficially own  as of the most recent practicable date .

Description of Business, page 21

18. Please revise here and throughout to discuss  your business as it exists  today by clarifying
which aspects of your business operations are anticipatory .  For the aspects of your
business operations that are anticipatory in nature, discuss the estimated costs and
timelines in reaching your business goals.  Additionally , please clarify whether you will
need any agreements with suppliers for the raw materials necessary to manufacture your
product ; whether you will be required to license  third party products such as GoPro Hero
4, which  you use in your products ; whether you have or will be required to ob tain local,
state, or federal regulatory licenses necessary for the production and sale of your product ;
what concrete steps  you have taken to develop  marketing and sales platforms you discuss
on page 23 ; the amount you have spent on research and developme nt to date and the
additional amount you anticipate spending on research and development, if any, before
you offer your products for sale ; and the extent to which your present production capacity
is sufficient to accommodate demand for your product .

Directors, Executive Officers and Corporate Governance, page 27

19. We note that Scott Kahoe signed Exhibit 3.2 as your secretary and that John L. Basshaus
signed your registration statement as your acting principal accounting officer.  Please
revise your dis closure here and in your Executive Compensation section, as appropriate,
or advise.

Executive Compensation, page 30

20. Please include David Sween ey in your summary compensation and Outstanding Equity
Awards at Fiscal Year -End tables or tell us how you concl uded he was not a named
executive officer .

Chad Swan
UAS Drone Corp.
June 18, 2015
Page 5

 Certain Relationships and Related Transaction, and Director Independence, page 32

21. Please identify the listing standards on which you are relying to determine the
independence of Mr. Nelson.  See Item 407(a)(1)(ii) of Regulation S -K for the
independence definitions that may be used when the registrant is not a listed issuer.

Security Ownership of Certain Beneficial Owners and Management, page 32

22. In an appropriate part of your prospectus please addr ess the potential conflict of interest
created by Green Block Capital, LLC’s owne rship of your company and Green Block
Capital, LLC’s managing director serving as your sole director.

23. Please identify the natural person who exercises or the persons who exercise the sole or
shared voting power or dispositive power for the shares of common stock held by Green
Block Capital, LLC .  We note in this regard footnote (5) to the table of selling
stockholders.

Related Party Transactions, page 32

24. We note your disclosure on page 26 regarding the $43,180 provided “from a note payable
from and advance from a shareholder as well as an advance  from an officer of the
company ,” you r disclosure on page F -8 regarding a stock holder advancing $20,000 to the
company in the form of a note payable and the same stockholder advancing an additional
$12,500 to the company  and your disclosure on page F -14 regarding related party
transactions .  Please disclose  these transactions pursuan t to Item 404 of Regulation S -K
or tell us why you believe this is unnecessary.

Undertakings, page 53

25. Please revise the undertaking in paragraph 1(ii) on page 53 so that it appears exactly as
the undertaking  in Item 512(a)(1)(ii) of Regulation S -K.

Signatures, page 55

26. Please revise to include the signature of the person or persons performing the function of
your chief financial officer.

Exhibit 5.1

27. Please have counsel revise to remove assumption  2 as it is inappropriate to make such an
assumption regarding counsel’s own client and have counsel remove assumption 3 as it is
inappropriate to assume a matter of law upon which counsel is opining .

Chad Swan
UAS Drone Corp.
June 18, 2015
Page 6

 28. Please have counsel provide its opinion regarding the se condary offering.  In this regard,
we note that counsel has only provided an opinion for the primary offering.

You may contact Theresa Messinese  at (202) 551 -3307  or Doug Jones  at (202) 551 -3309
if you have questions regarding comments on the financi al statements and related matters.
Please contact Sonia Bednarowski  at (202) 551 -3666  or me at (202) 551 -3217 with any other
questions.

Sincerely,

 /s/ J. Nolan McWilliams

 J. Nolan McWilliams
Attorney -Advisor

cc: Branden T. Burningham, Esq.