SecProbe.io

<DOCUMENT>
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<TEXT>
 April 29, 2026

Irving Kau
Chief Financial Officer
Focus Universal Inc.
1515 W. Cameron Ave., Ste 210
West Covina, CA 91790

 Re: Focus Universal Inc.
 Registration Statement on Form S-1
 Filed April 23, 2026
 File No. 333-295285
Dear Irving Kau:

 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 Nicholas O'Leary at 202-551-4451 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and Services
cc: Gilbert J. Bradshaw, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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 Focus
Universal Inc.

 1515 W. Cameron Ave., Ste. 210

 West Covina, California 91790

 April 29, 2026

 Securities and Exchange Commission
Division of Corporation Finance

 Office of Industrial Applications and Services
100 F Street, N.E.
Washington, D.C. 20549

 Re:

 Acceleration Request for Focus Universal Inc.
 Registration Statement Filed on Form S-1, as amended
 Initially Filed on April 23, 2026
 File No. 333-295285

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the " Securities Act "), Focus Universal Inc., a Nevada corporation (the " Registrant ")
hereby requests acceleration of the effective date of the Registration Statement on Form S-1, as amended (File No. 333-295285) (the " Registration
Statement "), so that it may become effective at 4:00 pm Eastern Standard Time on Friday, May 1, 2026, or as soon as practicable
thereafter.

 In connection with this request, we hereby acknowledge
that:

 (i)
 Should the Securities and Exchange Commission (the " Commission ") or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the filing;

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

 (iii)
 The Registrant 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.

 We confirm that we are aware of our responsibilities
under the Securities Act and the Securities Exchange Act as they relate to the public offering of securities specified in the Registration
Statement.

 We request that our counsel, Mr. Bradshaw, be
notified of such effectiveness by a telephone call to (805) 807-2277. We also request that a copy of the written order from the Commission
verifying the effective time and date of the Registration Statement be sent to Mr. Bradshaw via facsimile at (917) 791-8877 or by email
to gil@securitieslegal.com.

 Sincerely,

 Focus Universal Inc.

 By:
 /s/ Irving Kau

 Name: Irving Kau
Title: Chief Financial Officer and Principal Accounting Officer

CORRESP
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 Focus
Universal Inc.

 2311 East Locust Court

 Ontario, CA 91761

 December 16, 2025

 Securities and Exchange Commission
Division of Corporation Finance

 Office of Industrial Applications and Services
100 F Street, N.E.
Washington, D.C. 20549

 Re:

 Acceleration Request for Focus Universal Inc.
 Registration Statement Filed on Form S-1/A (File No. 333-292009)

 Ladies and Gentlemen:

 Pursuant to Rule 461, Focus
Universal Inc., a Nevada corporation (the " Registrant ") hereby requests acceleration of the effective date of the Registration
Statement on Form S-1/A (File No. 333-292009), as amended (the " Registration Statement "), so that it may become effective
at 1:00 pm Eastern Standard Time on Thursday December 18, 2025, or as soon as practicable thereafter.

 In connection with this request, we hereby acknowledge
that:

 (i)

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

 (ii)

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

 (iii)

 The Registrant 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 State.

 We confirm that we are aware
of our responsibilities under the Securities Act and the Securities Exchange Act as they relate to the public offering of securities specified
in the Registration Statement.

 We request that our counsel,
Mr. Bradshaw, be notified of such effectiveness by a telephone call to (805) 807-2277. We also request that a copy of the written order
from the Commission verifying the effective time and date of the Registration statement be sent to Mr. Bradshaw via facsimile at (917)
791-8877 or by email to gil@securitieslegal.com.

 Sincerely,

 Focus Universal Inc.

 By:
 /s/ Desheng Wang

 Name: Desheng Wang
Title: Chief Executive Officer

CORRESP
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Focus
Universal Inc.

2311 East Locust Court

Ontario, CA 91761

January 6, 2025

Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and Services

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Acceleration Request for Focus Universal Inc.

    Registration Statement Filed on Form S-3 (File No. 333-284048)

Ladies and Gentlemen:

Pursuant to Rule 461, Focus
Universal Inc., a Nevada corporation (the “Registrant”) hereby requests acceleration of the effective date of the Registration
Statement on Form S-3 (File No. 333-284048), as amended (the “Registration Statement”), so that it may become effective
at 5:00 pm Eastern Standard Time on Wednesday January 8, 2025, or as soon as practicable thereafter.

In connection with this request, we hereby acknowledge
that:

 (i) Should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement
effective, it does not foreclose the Commission from taking any action with respect to the filing;

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

 (iii) The Registrant 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.

We confirm that we are aware
of our responsibilities under the Securities Act and the Securities Exchange Act as they relate to the public offering of securities specified
in the Registration Statement.

We request that our counsel,
Mr. Bradshaw, be notified of such effectiveness by a telephone call to (805) 807-2277. We also request that a copy of the written order
from the Commission verifying the effective time and date of the Registration statement be sent to Mr. Bradshaw via facsimile at (917)
791-8877 or by email to gil@securitieslegal.com.

    Sincerely,

    Focus Universal Inc.

    By:
    /s/ Desheng Wang____

    Name: Desheng Wang

Title: Chief Executive Officer

January 2, 2025
Irving Kau
Chief Financial Officer
FOCUS UNIVERSAL INC.
2311 East Locust Court
Ontario, CA 91761
Re:FOCUS UNIVERSAL INC.
Registration Statement on Form S-3
Filed December 26, 2024
File No. 333-284048
Dear Irving Kau:
            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 Margaret Sawicki at 202-551-7153 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Gilbert J. Bradshaw, Esq.

CORRESP
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Focus
Universal Inc.

2311 East Locust Court

Ontario, CA 91761

November 12, 2021

Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Acceleration Request for Focus Universal Inc.

    Registration Statement Filed on Form S-3 (File No. 333-260180)

Ladies and Gentlemen:

Pursuant to Rule 461, Focus
Universal Inc., a Nevada corporation (the “Registrant”) hereby requests acceleration of the effective date of the
Registration Statement on Form S-3 (File No. 333-260180), as amended (the “Registration Statement”), so that it may
become effective at 5:00 pm Eastern Standard Time on Tuesday November 16, 2021, or as soon as practicable thereafter.

In connection with this request, we hereby acknowledge
that:

 (i) Should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement
effective, it does not foreclose the Commission from taking any action with respect to the filing;

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

 (iii) The Registrant 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.

We confirm that we are aware
of our responsibilities under the Securities Act and the Securities Exchange Act as they relate to the public offering of securities specified
in the Registration Statement.

We request that our counsel,
Mr. Bradshaw, be notified of such effectiveness by a telephone call to (917) 830-6517. We also request that a copy of the written order
from the Commission verifying the effective time and date of the Registration statement be sent to Mr. Bradshaw via facsimile at (917)
791-8877 or by email to gbradshaw@wbc-law.com.

    Sincerely,

    Focus Universal Inc.

    By:
    /s/ Desheng Wang

    Name: Desheng Wang

Title: Chief Executive Officer

CORRESP
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Focus
Universal Inc.

2311 East Locust Court

Ontario, CA 91761

August 26, 2021

David Gessert

Laura Crotty

Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Acceleration Request for Focus Universal Inc.

    Registration Statement Filed on Form S-1 (File No. 333-253049)

Ladies and Gentlemen:

Pursuant to Rule 461, Focus
Universal Inc., a Nevada corporation (the “Registrant”) hereby requests acceleration of the effective date of the Registration
Statement on Form S-1 (File No. 333-253049), as amended (the “Registration Statement”), so that it may become effective
at 5:00 pm Eastern Standard Time on Monday August 30, 2021, or as soon as practicable thereafter. In connection with this request, we
hereby acknowledge that:

 (i) Should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement
effective, it does not foreclose the Commission from taking any action with respect to the filing;

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

 (iii) The Registrant 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.

We confirm that we are aware
of our responsibilities under the Securities Act and the Securities Exchange Act as they relate to the public offering of securities specified
in the Registration Statement. Further, we understand that request for acceleration is a confirmation of the fact that we are aware of
our responsibilities under the federal securities laws.

We request that our counsel,
Gilbert J Bradshaw, be notified of such effectiveness by a telephone call to (917) 830-6517. We also request that a copy of the written
order from the Commission verifying the effective time and date of the Registration statement be sent to Mr. Bradshaw via facsimile at
(917) 791-8877 or by email to gbradshaw@wbc-law.com.

    Sincerely,

    Focus Universal Inc.

    By:
    /s/ Desheng Wang

    Name: Desheng Wang

Title: Chief Executive Officer

CORRESP
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August 26, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

 Attn: David Gessert

    Laura Crotty

 Re: Focus Universal Inc.

    Registration Statement on Form S-1, as amended

    Filed February 12, 2021

    File No. 333-253049

Ladies and Gentlemen:

As the underwriter of the
proposed offering of Focus Universal Inc. (the “Company”), we hereby join the
Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 5:00 p.m., Eastern
Time, on Monday, August 30, 2021, or as soon thereafter as is practicable.

Pursuant to Rule 460 of the
General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, we, acting
on behalf of the several underwriters, wish to advise you that, through August 26, 2021, we distributed to each underwriter or dealer,
who is reasonably anticipated to be invited to participate in the distribution of the security, as many copies, as well as “E-red”
copies of the Preliminary Prospectus dated August 26, 2021, as appears to be reasonable to secure adequate distribution of the preliminary
prospectus.

The undersigned advise that
they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very truly yours,

    Boustead Securities, LLC

    By:
    /s/ Keith Moore

    Name: Keith Moore

Title: Chief Executive Officer

CORRESP
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May 27, 2021

U.S. Securities & Exchange Commission

Division of Corporate Finance

100 F. Street NE

Washington, D.C. 20549

Attn: David Gessert and Laura Crotty

Re: Focus Universal Inc. Amendment No. 3 of Registration Statement
on Form S-1, Filed February 12, 2021, File No. 333-253049

Dear David Gessert and Laura Crotty:

We are outside counsel to Focus Universal Inc.,
a Nevada corporation (the “Company”), and are addressing and delivering this letter to you on the Company’s behalf.
The Company has revised the Registration Statement filed on Form S-1 (File No. 333-253049) (the “Registration Statement”)
to address each of the staff’s comments (in bold) to the Registration Statement and the Company’s responses thereto. In relation
thereto, the Company is filing with you concurrently with this letter, Amendment No. 3 to the Registration Statement (“Amendment
No. 3”), which contains the revisions made to the Registration Statement pursuant to the Staff’s comments.

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

Cover Page

 1. We note your revisions in response to prior comment 1. We further note that your registration statement
still discloses and anticipated public offering price between $4.00 and $6.00 per share. Paragraph 501(b)(3) of Regulation S-K requires
that, where you offer securities for cash, you disclose the price to the public of the securities. As a reporting company, you are not
eligible to disclose a bona fide estimate of the range of the maximum offering price in reliance on Instruction 1(A) to paragraph 501(b)(3).
Pursuant to Instruction 2, if it is impracticable to state the price to the public you may explain the method by which the price is to
be determined. However, based on the methodology described on the amended cover page, it does not appear it is impracticable to state
the price to the public in this case. Accordingly, please revise the registration statement to state the price of the securities to the
public.

We have revised the prospectus cover page to indicate
a price per share of $5.00 per share throughout the Amendment No. 3.

Please contact the undersigned if you have further
questions or comments regarding the Registration Statement as amended by pre-effective Amendment No. 3.

Sincerely,

/s/Gilbert J. Bradshaw

Gilbert J. Bradshaw

Managing Partner, Wilson Bradshaw LLP

United States securities and exchange commission logo
April 30, 2021
Desheng Wang
Chief Executive Officer
Focus Universal Inc.
Nevada Business Center, LLC
701 S. Carson St. Suite 200
Carson City, NV 89701
Re:Focus Universal Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed April 27, 2021
File No. 333-253049
Dear Dr. Wang:
            We have reviewed your amended registration statement and have the following
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.  Unless we note
otherwise, our references to prior comments are to comments in our February 24, 2021 letter.
Amendment No. 2 to Registration Statement on Form S-1
Cover Page
1.We note your revisions in response to prior comment 1. We further note that your
registration statement still discloses an anticipated public offering price between $4.00
and $6.00 per share. Paragraph 501(b)(3) of Regulation S-K requires that, where you offer
securities for cash, you disclose the price to the public of the securities. As a reporting
company, you are not eligible to disclose a bona fide estimate of the range of the
maximum offering price in reliance on Instruction 1(A) to paragraph 501(b)(3). Pursuant
to Instruction 2, if it is impracticable to state the price to the public you may explain the
method by which the price is to be determined. However, based on the methodology

 FirstName LastNameDesheng Wang
 Comapany NameFocus Universal Inc.
 April 30, 2021 Page 2
 FirstName LastName
Desheng Wang
Focus Universal Inc.
April 30, 2021
Page 2
described on the amended cover page, it does not appear it is impracticable to state the
price to the public in this case. Accordingly, please revise the registration statement to
state the price of the securities to the public.
            Please contact David Gessert at 202-551-2326 or Laura Crotty at 202-551-7614 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Gilbert J. Bradshaw, Esq.

CORRESP
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    Christopher
    A. Wilson

    Partner

    CWilson@securitieslegal.com

    Licensed
    in California

    William
    L. Horn

    Partner

    William@securitieslegal.com

    Licensed
    in California

    Ashley
    L. Duran

    Of
    Counsel

    ADuran@securitieslegal.com

    Licensed
    in the District of Columbia

    www.securitieslegal.com

    Gilbert
    J. Bradshaw

    Partner

    Gil@securitieslegal.com

    Licensed
    in New York

    Monique
    Saugstad

    Of
    Counsel

    monique@securitieslegal.com

    Licensed
    in New Jersey

    Javiera
    P. Salamanca

    International
    Counsel

    Javiera@securitieslegal.com

    Licensed
    in Chile

April 26, 2021

U.S. Securities & Exchange Commission

Division of Corporate Finance

100 F. Street NE

Washington, D.C. 20549

Attn: David Gessert and Laura Crotty

Re: Focus Universal Inc. Registration Statement on Form S-1, Filed
February 12, 2021, File No. 333-253049

Dear David Gessert and Laura Crotty:

We are outside counsel to Focus Universal Inc.,
a Nevada corporation (the “Company”), and are addressing and delivering this letter to you on the Company’s behalf.
The Company has revised the Registration Statement filed on Form S-1 (File No. 333-253049) (the “Registration Statement”)
to address each of the staff’s comments (in bold) to the Registration Statement and the Company’s responses thereto. In relation
thereto, the Company is filing with you concurrently with this letter, Amendment No. 2 to the Registration Statement (“Amendment
No. 2”), which contains the revisions made to the Registration Statement pursuant to the Staff’s comments.

Registration Statement on Form S-1 filed February
12, 2021 Cover Page

 1. We note your disclosure that your offering of common shares will be “at an assumed offering price
of $4.00 to $6.00 per share.” We further note that you are subject to the reporting requirements of Section 13(a) or 15(d) of the
Exchange Act, as applicable. Accordingly, please revise to state the price of the securities to the public. If you are not able to state
a price, explain the method by which the price is to be determined. Refer to Instruction 2 to Item 501(b)(3) of Regulation S-K for guidance

We have revised the prospectus cover page to indicate
the methodology by which the price is to be determined, specifically, we wrote the following:

“Focus Universal Inc., a Nevada corporation
(“Focus Universal,” “the Company,” “we,” “us,” and “our,”), is offering 2,000,000
shares of common stock, $0.001 par value per share, on a firm commitment basis. We anticipate a public offering price between $4.00 and
$6.00 per share. We have assumed a public offering price of $5.00 per share, which is the midpoint of the estimated offering price range.
Our common stock is currently quoted on the OTCQB market, operated by OTC Markets Group, under the symbol “FCUV.” On April
26, 2021, the last quoted price of our common stock as reported on the OTCQB was $5.00 per share. This price will fluctuate based on the
demand for our common stock. There is a limited public trading market for our common stock. The final public offering price will be determined
through a negotiation between us and the underwriters in the offering and will take into account the recent market price of our common
stock, the general condition of the securities market at the time of the Offering, the history of, and the prospects for, the industry
in which we compete, and our past and present operations and our prospects for future revenues. The assumed public offering price used
throughout this prospectus may not be indicative of the actual offering price.”

Main
Office: 18818 Teller Avenue, Suite 115, Irvine, CA 92612

New
York Office: 45 Rockefeller Plaza, Suite 200, New York, NY 10111

Tel:
(917) 830-6517 / Fax: (917) 791-8877

Page 2

Item 16. Exhibits

Exhibit 5.1 - Opinion of Wilson Bradshaw LLP,
page II-2

 2. We note the opinion of counsel as to the legality of the securities refers to the registration of common
stock “to be offered by the selling stockholders.” We further note that this is a primary offering of common stock by the
company and, based on the disclosure in the prospectus, no shares are being registered for resale by selling stockholders. Please provide
a revised opinion of counsel that clearly refers to the securities being registered, or advise.

We have revised the opinion of counsel that reflects
a primary offering of common stock by the Company.

Please contact the undersigned if you have further
questions or comments regarding the Registration Statement as amended by pre-effective Amendment No. 2.

Sincerely,

/s/Gilbert J. Bradshaw

Gilbert J. Bradshaw

Managing Partner, Wilson Bradshaw LLP

United States securities and exchange commission logo
February 24, 2021
Desheng Wang
Chief Executive Officer
Focus Universal Inc.
Nevada Business Center, LLC
701 S. Carson St. Suite 200
Carson City, NV 89701
Re:Focus Universal Inc.
Registration Statement on Form S-1
Filed February 12, 2021
File No. 333-253049
Dear Mr. Wang:
            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 filed February 12, 2021
Cover Page
1.We note your disclosure that your offering of common shares will be "at an assumed
offering price of $4.00 to $6.00 per share."  We further note that you are subject to the
reporting requirements of Section 13(a) or 15(d) of the Exchange Act, as applicable.
Accordingly, please revise to state the price of the securities to the public.  If you are not
able to state a price, explain the method by which the price is to be determined.  Refer to
Instruction 2 to Item 501(b)(3) of Regulation S-K for guidance.

 FirstName LastNameDesheng Wang
 Comapany NameFocus Universal Inc.
 February 24, 2021 Page 2
 FirstName LastName
Desheng Wang
Focus Universal Inc.
February 24, 2021
Page 2
Item 16. Exhibits
Exhibit 5.1 - Opinion of Wilson Bradshaw LLP, page II-2
2.We note the opinion of counsel as to the legality of the securities refers to the registration
of common stock "to be offered by the selling stockholders."  We further note that this is a
primary offering of common stock by the company and, based on the disclosure in the
prospectus, no shares are being registered for resale by selling stockholders.  Please
provide a revised opinion of counsel that clearly refers to the securities being registered,
or advise.
            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.
            Please contact David Gessert at 202-551-2326 or Laura Crotty at 202-551-7614 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Gilbert J. Bradshaw, Esq.

CORRESP
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Focus
Universal Inc.

20511 East Walnut
Drive North

Walnut, CA 91789

October 15, 2018

Geoffrey D. Kruczek

Caleb French

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

        Acceleration Request for Focus Universal Inc.

        Registration Statement Filed on Form S-1 (File No. 333-227311)

Ladies and Gentlemen:

Pursuant to Rule 461, Focus Universal Inc.,
a Nevada corporation (the “Registrant”) hereby requests acceleration of the effective date of the Registration
Statement on Form S-1 (File No. 333-227311), as amended (the “Registration Statement”), so that it may become
effective at 4:00 pm Eastern Standard Time on October 17, 2018, or as soon as practicable thereafter. In connection with this request,
we hereby acknowledge that:

 (i) Should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it
does not foreclose the Commission from taking any action with respect to the filing;

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

 (iii) The Registrant 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.

We
confirm that we are aware of our responsibilities under the Securities Act and the Securities Exchange Act as they relate to the
public offering of securities specified in the Registration Statement. Further, we understand that request for acceleration is
a confirmation of the fact that we are aware of our responsibilities under the federal securities laws.

We request that  a copy of the written order from
the Commission verifying the effective time and date of the Registration statement be sent to Mr. Bradshaw via facsimile at (917)
791-8877 or by email to gbradshaw@wbc-law.com.

    Sincerely,

    Focus Universal Inc.

    /s/ Desheng Wang

    Desheng Wang, CEO

July 12, 2018
Desheng Wang
Chief Executive Officer
Focus Universal Inc.
20511 East Walnut Drive North
Walnut, CA 91789
Re:Focus Universal Inc.
Form 10-K for Fiscal Year Ended December 31, 2017
Filed April 2, 2018
File No. 000-55247
Dear Mr. Wang:
            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.
Division of Corporation Finance
Office of Telecommunications
cc:       Gilbert Bradshaw

CORRESP
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June 12, 2018

Via EDGAR and Federal Express

Courtney Lindsay

Staff Attorney

Securities and Exchange Commission

100 F Street N.E.

Washington D.C. 20549

 Re: Focus Universal Inc.

    Form 10-K for Fiscal Year Ended December
31, 2017

    Filed April 2, 2018

    File No. 000-55247

Dear Mr. Lindsay:

Set forth below is
the response on behalf of Focus Universal, Inc. (the “Company”) to the comments of the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) contained in the letter dated May 9, 2018 (the “Comment
Letter”) concerning the referenced Form 10-K for the Fiscal Year Ended December 31, 2017 which was filed with the Commission
on April 2, 2018. For your convenience and to facilitate your review, we have set forth herein each comment of the Staff contained
in the Comment Letter followed by our response. In this Comment Response Letter unless the context otherwise requires, the words
“we,” “us” and “our” refer to our client, the Company.

We are providing to
you under separate cover one copy of our Amendment No. 1 to our Annual Report on Form 10-K for the fiscal year ended December 31,
2017, which has been filed with the Commission concurrently herewith.

Amendment No. 1 to the Annual Report
on Form 10-K for the fiscal year ended December 31, 2017

Cover Page

 1. Please revise the cover page to the Form 10-K to disclose the aggregate market value of the voting
and non-voting common equity held by non-affiliates computed by reference to the price at which the common equity was last sold,
or the average bid and asked price of such common equity, as of the last business day of the registrant’s most recently
completed second fiscal quarter. Provide us with your calculation. In this regard, we note that you made this calculation as
of March 30, 2018 and appear to have multiplied the closing price by all of your outstanding common shares, rather than only the
amount of voting stock held by non-affiliates of the company.

The Company has revised the disclosure on cover
page as requested.

 2. Please revise the cover page to the Form 10-K to indicate that your common stock is registered
under Section 12(g). We refer you to the Form 8-A12G filed on July 15, 2014.

The Company has revised the
disclosure as requested. However, it is our position that the Company is not or should not be a 12(g) filer under the Exchange
Act. The Form 8-A filed on July 15, 2014 was incorrectly filed. The Company intends to take remedial measures to amend its Form
8-A so that it can correctly be categorized as a filer under Section 12(b) of the Exchange Act.

Risk Factors

We will not be required to evaluate our internal
control over financial reporting under Section 404 of the Sarbanes-Oxley Act..., page 13

 3. Please update this risk factor and the first risk factor on page 11 to account for the fact that
you have filed your second annual report on Form 10-K and, thus, your management is currently required to assess your internal
control over financial reporting. Disclose the results of that assessment.

The Company has revised the
risk factors on page 11 and page 13 as requested.

      1

Item 15. Exhibits, page 30

 4. Please list in the exhibit index and file all material contracts required by Item 601 of Regulation
S-K. For example, please file the convertible promissory notes you issued on June 30, 2017 and July 28, 2017. If you have previously
filed these exhibits, you may incorporate them by reference. Refer to Item 601(a)(2) of Regulation S-K.

The Company has revised its
exhibit to include the convertible promissory notes as requested.

If you have any additional questions
regarding any of our responses to the Amendment No. 1 to the Annual Report on Form 10-K for the fiscal year ended December
31, 2017, please feel free to call me at 917-830-6517.

    Sincerely yours,

    /s/ Gilbert Bradshaw

Enclosures

Yue
Cao

Desheng Wang

      2

June 14, 2018
Desheng Wang
Chief Executive Officer
Focus Universal Inc.
20511 East Walnut Drive North
Walnut, CA 91789
Re:Focus Universal Inc.
Form 10-K for Fiscal Year Ended December 31, 2017
Filed April 2, 2018
File No. 000-55247
Dear Mr. Wang:
            We issued comments to you on the above captioned filing on May 9, 2018.  As of the
date of this letter, these comments remain outstanding and unresolved.  We expect you to
provide a complete, substantive response to these comments by June 25, 2018.
            If you do not respond, we will, consistent with our obligations under the federal securities
laws, decide how we will seek to resolve material outstanding comments and complete our
review of your filing and your disclosure.  Among other things, we may decide to release
publicly, through the agency's EDGAR system, all correspondence, including this letter, relating
to the review of your filings, consistent with the staff's decision to publicly release comment and
response letters relating to disclosure filings it has reviewed.
            Please contact Courtney Lindsay, Staff Attorney, at 202-551-7237 or Kathleen Krebs,
Special Counsel, at 202-551-3350 with any questions.
Division of Corporation Finance
Office of Telecommunications
cc:       Gilbert Bradshaw

May 9, 2018
Desheng Wang
Chief Executive Officer
Focus Universal Inc.
20511 East Walnut Drive North
Walnut, CA 91789
Re:Focus Universal Inc.
Form 10-K for Fiscal Year Ended December 31, 2017
Filed April 2, 2018
File No. 000-55247
Dear Mr. Wang:
            We have reviewed your filing 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 these comments within ten business days by providing the requested
information and amending your Form 10-K, or advise us as soon as possible when you will
respond.  If you do not believe 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.
Form 10-K for the Fiscal Year Ended December 31, 2017
Cover Page
1.Please revise the cover page to the Form 10-K to disclose the aggregate market value of
the voting and non-voting common equity held by non-affiliates computed by reference to
the price at which the common equity was last sold, or the average bid and asked price of
such common equity, as of the last business day of the registrant’s most recently
completed second fiscal quarter.  Provide us with your calculation.  In this regard, we note
that you made this calculation as of March 30, 2018 and appear to have multiplied the
closing price by all of your outstanding common shares, rather than only the amount of
voting stock held by non-affiliates of the company.

 FirstName LastNameDesheng Wang
 Comapany NameFocus Universal Inc.
 May 9, 2018 Page 2
 FirstName LastName
Desheng Wang
Focus Universal Inc.
May 9, 2018
Page 2
2.Please revise the cover page to the Form 10-K to indicate that your common stock is
registered under Section 12(g).  We refer you to the Form 8-A12G filed on July 15, 2014.
Risk Factors
We will not be required to evaluate our internal control over financial reporting under Section
404 of the Sarbanes-Oxley Act..., page 13
3.Please update this risk factor and the first risk factor on page 11 to account for the fact that
you have filed your second annual report on Form 10-K and, thus, your management is
currently required to assess your internal control over financial reporting.  Disclose the
results of that assessment.
Item 15. Exhibits, page 30
4.Please list in the exhibit index and file all material contracts required by Item 601 of
Regulation S-K.  For example, please file the convertible promissory notes you issued on
June 30, 2017 and July 28, 2017.  If you have previously filed these exhibits, you may
incorporate them by reference.  Refer to Item 601(a)(2) of Regulation S-K.
            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 Joseph Kempf, Senior Staff Accountant, at 202-551-3352 or Terry
French, Accountant Branch Chief, at 202-551-3828 if you have questions regarding comments
on the financial statements and related matters.  Please contact Courtney Lindsay, Staff Attorney,
at 202-551-7237 or Kathleen Krebs, Special Counsel, at 202-551-3350 with any other questions.
Division of Corporation Finance
Office of Telecommunications

CORRESP
1
filename1.htm

April 11, 2018

U.S. Securities & Exchange Commission

Division of Corporation Finance

100 F. Street NE

Washington, D.C. 20549

Attn: Larry Spirgel, Assistant Director

Re: Focus Universal Inc.

Amendment No. 1 of Registration Statement on Form S-1,
Filed January 20, 2017

File No. 333-214455

Dear Mr. Spirgel:

We are counsel to Focus Universal Inc.,
a Nevada corporation (the “Company”), and are addressing and delivering this letter to you on the Company’s
behalf. The Company has revised the Amended Registration Statement filed on Form S-1 (file No. 3333-214455) (the “Registration
Statement”) to address each of the comments set forth in the staff’s comment letter dated January 30, 2017. Set forth
below are each of the staff’s comments (in bold) to the Registration Statement and the Company’s Responses thereto.
In relation thereto, the Company is filing with you concurrently with this letter Amendment No. 2 to the Registration Statement
(“Amendment No. 2”), which contains the revisions made to the Registration Statement pursuant to the staff’s
comments. A copy of Amendment No. 2 marked to show all changes is attached hereto for your convenience.

1. In response to our prior comment 1, you state that
“[w]e have revised the prospectus cover page and disclosure throughout the prospectus to indicate a fixed price of $1.75
at which the Company will sell the 10 million shares in its best efforts offering.” Your prospectus does not reflect this
change. Therefore, we reissue the comment.

We have updated the Registration Statement accordingly. Please note that we have updated the price to $2.50 per share.

2. Please disclose who will be selling the ten million
shares on behalf of the company. If your officers and directors will be selling the shares, please disclose how they meet the requirements
of Rule 3a4-1 so as not to be deemed brokers.

The shares will be sold either through a registered broker/dealer
or by the officers and directors of the company. The officers and directors of the company are not subject to a “statutory
disqualification” as defined in Section 3(a)(39) of the Exchange Act, will not be compensated in connection with the sale
of the Company’s securities, and are not associated with a broker or a dealer.

3. We note that your officers and directors are offering
shares they own in the offering as selling shareholders. If your officer and directors are also selling shares on behalf of the
company, disclose how they will decide whether to sell their own shares or the company’s shares. Provide appropriate risk
factor disclosure regarding their conflicts in this offering.

The Registration Statement has been amended to reflect that the officers and directors will not register any of the shares they
own in this offering.

4. Any amendments should contain a signed and currently-dated
accountant's consent as required by Rule 402(e) of Regulation C.

We have submitted a revised and current Auditor Consent Letter.

9110 Irvine
Center Drive, Irvine, CA 92618

353 W.
48th Street, Suite 340 New York, NY 10036

www.wilsonoskam.com

Page 2

5. We note that in response to our prior comment 2 that
you have provided your planned use of proceeds in the event that 25%, 50% and 75% of the offering is achieved. Please also include
summary information on your planned use of proceeds in the event that 100% of the offering is achieved. In addition, please revise
your disclosure for each level of proceeds to take into account the expenses of the offering.

We have updated the Registration Statement accordingly.

6. Please update your discussions of results of operations,
liquidity and capital resources to reflect your most recent required financial statements.

We have updated the MD&A Registration Statement to reflect
the most recently-filed financial statements for the years ended December 31, 2017 and 2016. See response to comments #9 and #10
regarding the restated financial statements.

7. We note that your fiscal year ends on December 31.
Please update your Summary Compensation Table at page 32 to include information for the two most recently completed fiscal years
(i.e., fiscal years 2015 and 2016). Please refer to Item 402(n) of Regulation S-K.

We have updated the Registration Statement accordingly.

8. In response to
our prior comment 3, you revised the selling stockholders table to disclose in the last column the percentage of registered shares
owned in the offering. Please revise this column to disclose, instead, the amount and percentage of the class to be owned by security
holders after completion of the offering. Please refer to the last clause of Item 507 of Regulation S-K.

We have updated the
Registration Statement accordingly.

9. Please disclose how you accounted for the business combination
of Focus Universal, Inc. and Perfecular, Inc. Identify the accounting acquirer in this transaction and provide the business combination
disclosures required by ASC 805-10-50.

Upon further review,
the Company has determined that the business combination of Focus Universal, Inc. and Perfecular, Inc. should be accounted
for as a combination between entities under common control. During all the relevant periods
for which the financial statements are presented, Dr. Desheng Wang, CEO and directors of Focus, owned 2,271,000 (41.2%) shares
of Focus common stock and Mr. Yan Chen, Senior Vice President and director of Focus, owned 600,000 (9.1%) shares of Focus common
stock. During all relevant periods, Focus had 6,580,000 common shares issued and outstanding. Dr. Wang and Mr. Chen together owned
a controlling interest (greater than 50%) in Focus. Mr. Chen resigned his positions at Focus in October 2015, just two months prior
to the business combination with Pefecular. In October 2015, Dr. Edward Lee was appointed as a director of Focus. During all of
2015, two of the three directors of Focus, Dr. Wang and Mr.Chen/Dr. Lee, were also stockholders of Pefecular. Due to Dr. Wang’s
large stock position (41.2%) in Focus and his position as CEO and director of Focus, the Company believes that Dr. Wang controlled
Focus. Dr. Wang, owned 14,290,000 (51.0%) shares of Perfecular common stock, Dr. Lee owned 10,000,000 (35.7%) shares of Perfecular
common stock and Mr. Chen owned 2,400,000 (8.6%) shares of Perfecular common stock. Due to Dr. Wang’s large stock position
(51.0%) in Pefecular he had control of Perfecular. Thus, the Company believes that the business combination between Focus and Perfecular
should be accounted for as a combination between entities under common control due to Dr. Wang, Mr. Chen and Dr. Lee’s ownership
of common stock in both companies and because of the influence they could exercise in their positions as officers and directors.

ASC 805-50-25-2
“When accounting for a transfer of assets or exchange of shares between entities under common control, the entity that receives
the net assets or the equity interests shall initially recognize the assets and liabilities
transferred at the date of transfer.”

ASC 805-50-45-2 further states that, “the financial
statements of the receiving entity shall report results of operations for the period in which the transfer occurs as though the
transfer of net assets or exchange of equity interests had occurred at the beginning of the period. Results of operations for that
period will thus comprise those of the previously separate entities combined from the beginning of the period to the date the transfer
is completed and those of the combined operations from that date to the end of the period. By eliminating the effects of intra-entity
transactions in determining the results of operations for the period before the combination, those results will be on substantially
the same basis as the results of operations for the period after the date of combination. The effects of intra-entity transactions
on current assets, current liabilities, revenue, and cost of sales for periods presented and on retained earnings at the beginning
of the periods presented shall be eliminated to the extent possible.”

Page 3

In accordance with
ASC 805-50-45, the Company as restated its 2015 and 2016 (2016 was only restated for a reclassification between additional paid
in capital and accumulated deficit) to combine the financial statements of Focus and Perfecular as of the earliest period presented
in the financial statements which is January 1, 2015.

10. In your response to comment 4, you identified Perfecular,
Inc. as the accounting acquirer in the December 30, 2015 business combination with Focus Universal, Inc. However we note that
you included the financial statements of Focus Universal, Inc. in the Form S-1. Please note that since Perfecular, Inc., is the
accounting acquirer, Perfecular, Inc. is considered the registrant for accounting purposes. Accordingly, please revise
your presentation in the Form S-1 to include the historical financial statements of Perfecular, Inc. for all periods presented
giving effect to the acquisition of Focus Universal, Inc. on December 30, 2015. Revise your Management’s Discussion and
Analysis to discuss these financial statements. Also amend your Form 10-KT for the transition period from March 31, 2015 to December
31, 2015 and your subsequent Forms 10-Q accordingly.

See our response to
comments #9 and #6. We will amend our Form 10K and Form 10Qs for the accounting change discussed in our response to comment #9
once the SEC accepts our new position on how we accounted for the transaction between Focus and Perfecular.

11. Please revise your pro forma presentations to reflect
the periods required by Rule 8-05(b)(1) of Regulation S-X.

We believe the Registration
Statement Amendment No. 2 addresses this issue.

12. We note your response to prior comment 7. Your registration
statement must be signed by your controller or principal accounting officer. In your next amendment, please have your principal
accounting officer or controller sign your registration statement by identifying the person who is signing in that capacity under
the person’s signature. Refer to Instructions 1 and 2 to Form S-1.

The Company intends
to address this comment in the subsequent amendment to the Registration Statement.

Sincerely,

/s/ Gilbert J.
Bradshaw

Gilbert J. Bradshaw

CORRESP
1
filename1.htm

April 2, 2018

United States

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attn: Larry Spirgel

Assistant Director,

AD Office 11 – Telecommunications

Attn: Courtney Lindsay

Staff Attorney

T: (202) 551-7237

    Re:
    Focus Universal Inc.

    Registration Statement on Form S-1

    Filed November 4, 2016

    File No. 333-214455

Dear Messrs. Spirgel and Lindsay:

We are counsel for Focus Universal Inc. (the “Company”).
This correspondence is to inform you that the Company intends to file amendment No. 2 to the Registration Statement on Form S-1
filed on November 4, 2016 as soon as reasonably practical with audited financial statements for years ended December 31, 2017 and
2016.

Thank you.

Respectfully,

WILSON & OSKAM LLP,

By: /s/ Gilbert J. Bradshaw

Gilbert J. Bradshaw

Esq. Of Counsel

9110 Irvine Center Drive, Irvine, CA 92618

353 W. 48th Street, Suite 340 New York, NY 10036

www.wilsonoskam.com

Mail Stop 3720

March 1, 2018

CERTIFIED MAIL
RETURN RECEIPT REQUESTED

Desheng Wang
Chief Executive Officer
Focus Universal  Inc.
829 Lawson Street
City of Industry, CA 91748

Re: Focus Universal Inc.
 Registration Statement on Form S-1
 Filed  November 4, 2016
 File No.  333-214455

Dear Mr. Wang :

It has been more than nine months since you last amended  this registration statement
and it is now out of date.  Within 30 days from the date of this letter, you should either:

 amend it to comply with  the applicable requirements of the Securities Act of 1933, the rules
and regulations under the Act, and the requirements of the form; or

 file a request for withdrawal.

If you requested confidential treatment for portions of any exhibits to your registration
statement and you request withdrawal of that registration statement, please submit a concurrent
request for withdrawal of your application for confidential treatment.

If you do not amend the registration statement or file a request for withdrawal (or provide us
with a satisfactory explanation of why you have not done either) within 30 days, we may enter an
order declaring the registration statement abandoned under ru le 479 of the Act.

Desheng Wang
Focus Universal Inc.
March 1, 2018
Page 2

 Please contact Courtney Lindsay, Staff Attorney, at (202) 551 -7237 with any questions.

Sincerely,

 /s/ Kathleen Krebs, for

Larry Spirgel
Assistant Director
 AD Office 11 – Telecommunications

cc: Gilbert J. Bradshaw, Esq.
 Wilson & Oskam, LLP
CERTIFIED MAIL
RETURN RECEIPT REQUESTED

Mail Stop 3720

January 30, 2017

Desheng Wang
Chief Executive Officer
Focus Universal, Inc.
829 Lawson Street
City of Industry, CA 91748

Re: Focus Universal, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed January 20, 2017
  File No. 333-214455

Dear Mr. Wang :

We have reviewed your amended 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 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.   Unless  we note
otherwise , our references to prior comments are to comments in our November 28, 2016  letter .

General

1. In response to our prior comment 1, you state that “[w]e have revised the pr ospectus
cover page and disclosure throughout the prospectus to indicate a fixed price of $1.75 at
which the Company will sell the 10 million shares in its best efforts offering.”  Your
prospectus does not reflect this change.  Therefore, we reissue the co mment.

2. Please disclose who will be selling the ten million shares on behalf of the company.  If
your officers and directors will be selling the shares, please disclose how they meet the
requirements of Rule 3a4 -1 so as not to be deemed brokers.

Desheng Wang
Focus Universal, Inc.
January 30, 2017
Page 2

 3. We note  that your officers and directors are offering shares they own in the offering as
selling shareholders.  If your officer and directors are also selling shares on behalf of the
company, disclose how they will decide whether to sell their own shares or the
company’s shares.  Provide appropriate risk factor disclosure regarding their conflicts in
this offering.

4. Any amendments should contain a signed and currently -dated accountant's consent as
required by Rule 402(e) of Regulation C.

Use of Proceeds, page 14

5. We note that in response to our prior comment 2 that you have provided your planned use
of proceeds in the event that 25%, 50% and 75% of the offering is achieved.  Please also
include summary information on your planned use of proceeds in the event that 100% of
the offering is achieved.  In addition, please revise your disclosure for each level of
proceeds to take into account the expenses of the offering.

Management’s Discussion and Analysis

6. Please update your discussions of results of operations, liquidity and capit al resources to
reflect your most recent required financial statements.

Summary Compensation Table, page 32

7. We note that your fiscal year ends on December 31.  Please update your Summary
Compensation Table at page 32 to include information for the two mo st recently
completed fiscal years (i.e., fiscal years 2015 and 2016).  Please refer to Item 402(n) of
Regulation S -K.

Selling Stockholders, page 36

8. In response to our prior comment 3, you revised the selling stockholders table to disclose
in the last co lumn the percentage of registered shares owned in the offering.  Please
revise this column to disclose, instead, the amount and percentage of the class to be
owned by security holders after completion of the offering.  Please refer to the last clause
of Item 507 of Regulation S -K.

Desheng Wang
Focus Universal, Inc.
January 30, 2017
Page 3

 Financial Statements

Note 2 – Summary of Significant Accounting Policies

Change In Control, page F -7

9. Please disclose how you accounted for the business combination of Focus Universal, Inc.
and Perfecular, Inc.  Identify the  accounting acquirer in this transaction and provide the
business combination disclosures required by ASC 805 -10-50.

10. In your response to comment 4, you identified Perfecular, Inc. as the accounting acquirer
in the December 30, 2015 business combination wi th Focus Universal, Inc.  However we
note that you included the financial statements of Focus Universal, Inc. in the Form S -1.
Please note that since Perfecular, Inc., is the accounting acquirer, Perfecular, Inc . is
considered the registrant for accounting  purposes.  Accordingly, please  revise your
presentation in the Form S -1 to include the historical financial statements of Perfecular,
Inc. for all periods presented giving effect to the acquisition of Focus Universal, Inc. on
December 30, 20 15.   Revise your Management ’s Discussion and Analysis to discuss
these financial statements.  Also amend your Form 10 -KT for the transition period  from
March 31, 2015 to December 31, 2015  and your subsequent Forms 10 -Q according ly.

Pro Forma Consolidated Statements, page F -32

11. Please revise your pro forma presentations to reflect the periods required by Rule 8 -
05(b)(1) of Regulation S -X.

Signature Page

12. We note your response to prior comment 7.  Your registration statement must be signed
by your controller or principal accounting officer.  In your next amendment, please have
your principal accounting officer or controller sign your registration statement b y
identifying the person who is signing in that capacity under the person’s signature.  Refer
to Instructions 1and 2 to Form S -1.

Desheng Wang
Focus Universal, Inc.
January 30, 2017
Page 4

 You may contact Joseph Kempf, Senior Staff Accountant, at (202) 551 -3352 or Carlos
Pacho, Senior Assistant Chief Accountant, at (202) 551 -3835 if you have questions regarding
comments on the financial statements and related matters.  Please contact Courtney Lindsay,
Staff Attorney, at (202) 551 -7237 or Kathleen Krebs , Special Counsel,  at (202) 551 -3350 with
any other questions.

Sincerely,

 /s/ Kathleen Krebs, for

Larry Spirgel
Assistant Director
AD Office 11 – Telecommunications

Cc: Gilbert J. Bradshaw, Esq.
 Wilson & Oskam, LLP

CORRESP
1
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January 20, 2017

U.S. Securities & Exchange Commission

Division of Corporation Finance

100 F. Street NE

Washington, D.C. 20549

Attn: Larry Spirgel, Assistant Director

Re: Focus Universal Inc. Registration Statement on Form S-1,
Filed November 4, 2016 File No. 333-214455

Dear Mr. Spirgel:

We are counsel to Focus Universal Inc.,
a Nevada corporation (the “Company”), and are addressing and delivering this letter to you on the Company’s
behalf. The Company has revised the Registration Statement filed on Form S-1 (file No. 3333-214455) (the “Registration Statement”)
to address each of the comments set forth in the staff’s comment letter dated November 28, 2016. Set forth below are each
of the staff’s comments (in bold) to the Registration Statement and the Company’s Responses thereto. In relation thereto,
the Company is filing with you concurrently with this letter Amendment No. 1 to the Registration Statement (“Amendment No.
1”), which contains the revisions made to the Registration Statement pursuant to the staff’s comments. A copy of Amendment
No. 1 marked to show all changes is attached hereto for your convenience.

General

1. Please revise your prospectus cover page and disclosure
throughout the prospectus to indicate a fixed price at which the company will sell the 10 million shares in its best efforts offering.
As you are not eligible to conduct an at-the-market offering under Rule 415(a)(4), you may not offer your shares “at market
prices prevailing at the time of sale,” as you disclose on pages 2 and 37. Instead, you must offer the shares at a fixed
price for the duration of the offering.

We have revised the prospectus cover page and disclosure throughout
the prospectus to indicate a fixed price of $1.75 at which the Company will sell the 10 million shares in its best efforts offering.

Item 4. Use of Proceeds, page 14

2. You indicate that the offering by the company will be
conducted on a best-efforts basis. Please revise your disclosures throughout to also discuss how the amount and use of proceeds
will be affected if you only sell 25%, 50% and 75% of the shares being offered, identifying the amount of proceeds to be used for
each stated purpose.

We have revised the prospectus to discuss the amount and use
of proceeds will be affected if we only sell 25%, 50%, and 75% of the shares being offered, identifying the amount of proceeds
to be used for each stated purpose.

      1

Selling Stockholders, page 35

3. Please revise the selling stockholders table to disclose
all the information required by Item 507 of Regulation S-K. In particular, please add the following information:

 · the amount of securities owned by each selling stockholder prior
to the offering, and

 · the amount and (if one percent or more) the percentage of securities
to be owned by each selling stockholder after completion of the offering.

We have revised the selling stockholders table to disclose the
amount of securities owned by each selling stockholder prior to the offering and the amount and the percentage of securities to
be owned by each selling stockholder after the completion of the offering.

Financial Statements

Change In Control, page F-7

4. We note that you issued 27,994,706 shares of your common
stock to the shareholders of Perfecular Inc. representing approximately 80% the outstanding shares of the company and resulting
in a change in control of the company’s ownership. Addressing ASC 805-10-55-11 through 55-15, tell us how you identified
the accounting acquirer in the merger transaction.

Response: In evaluating the accounting acquirer in the merger
transaction, the Company reviewed the applicable guidance in ASC 805-10-55-11 through 15. Based
on the guidance, the Company concluded that Perfecular Inc. should be identified as the acquiring company for accounting
purposes, while Focus Universal, Inc was the acquirer for legal purposes.

ASC 805-10-55-12 states “In a business combination effected
primarily by exchanging equity interests, the acquirer usually is the entity that issues its equity interests.” The merger
was primarily effected by an exchange of equity interests, with shares of the Company’s common stock issued by Focus to stockholders
of Perfecular Inc. However, ASC 805-10-55-12 also provides the additional factors to consider when identifying the accounting acquirer
in business combinations primarily effected by an exchange of equity interests:

 1. The relative voting rights in the combined entity after
the business combination. The acquirer usually is the combining entity whose owners as a group retain or receive the largest portion
of the voting rights in the combined entity. In determining which group of owners retains or receives the largest portion of the
voting rights, an entity shall consider the existence of any unusual or special voting arrangements and options, warrants, or
convertible securities.

Each share of our common stock
entitles the owner to one vote. There is no cumulative voting. A simple majority can elect all of the directors at a given meeting,
and the minority would not be able to elect any director at that meeting. Management currently beneficially owns a majority of
our outstanding common stock. Consequently, management has the ability to influence control of the operations of the Company and,
acting together, will have the ability to influence or control substantially all matters submitted to stockholders for approval.
Pre-merger Pefecular Inc. owns over 80% of the outstanding common stock, which accounts for the largest portion of the voting rights
in the combined entity.

      2

 2. The existence of a large minority voting interest in the
combined entity if no other owner or organized group of owners has a significant voting interest. The acquirer usually is the
combining entity whose single owner or organized group of owners holds the largest minority voting interest in the combined entity.

The combined company’s
largest stockholder will be Desheng Wang, executive of pre-merger Focus and majority owner of Perfecular Inc., with approximately
49% of the combined entity. One other stockholder, Edward Lee, President of Perfecular Inc. will hold approximately 29% of the
combined company’s common stock. Based on the ownership of outstanding common stock and structure of the board of directors
of the combined entity, minority voting interest of pre-merger Focus is not expected to be able to exert significant influence
over the combined entity.

 3. The composition of the governing body of the combined entity.
The acquirer usually is the combining entity whose owners have the ability to elect or appoint or to remove a majority of the
members of the governing body of the combined entity.

Pre-merger, Board of Directors
of Focus, Inc. was comprised of one individual, Dr. Desheng Wang, and Board of Directors of Perfecular, Inc. was comprised of Edward
Lee and Jennifer Gu, effective October 21, 2015. At the time of their nominations neither Edward Lee nor Jennifer Gu were shareholders
of Focus Universal Inc. Accordingly, each of Dr. Jennifer Gu, and Dr. Edward Lee, former President of Perfecular Inc. became members
of the Board of Directors, and the entire Board of Directors now consists of Dr. Desheng Wang, Dr. Jennifer Gu, and Dr. Edward
Lee. Our director, Edward Lee, is also President of the combined entity; our director Desheng Wang is also Chief Executive Officer,
and Chief Financial Officer of the combined entity. As such, Perfecular Inc. will comprise the majority of the governing body of
the combined entity, with ability to elect or appoint or to remove a majority of the members.

 4. The composition of the senior management of the combined
entity. The acquirer usually is the combining entity whose former management dominates the management of the combined entity.

The management from Perfecular
Inc., Desheng Wang and Edward Lee, became the dominant management of the combined entity, with approximately 78% combined beneficial
ownership after the merger. At the effective time of merger, Desheng Weng, Chief Executive Officer of Perfecular, was appointed
Chief Executive Officer, Chief Financial Officer, and Secretary of the combined entity Focus Inc. Edward Lee, President of Perfecular,
was appointed President of the combined entity Focus Inc. Desheng Wang and Edward Lee make up the majority of members on the board
of directors and will have majority vote in determining the composition of senior management of the combined entity.

ASC 805-10-55-13 states “The
acquirer usually is the combining entity whose relative size (measured in, for example, assets, revenues, or earnings) is significantly
larger than that of the other combining entity or entities. Based on the assets, revenues, and earnings of Perfecular Inc. in comparison
to pre-merger Focus Inc. noted in the pro-forma statements, Perfecular Inc. is larger than the combining entity. As such, per the
guidance, Perfecular Inc. is considered the accounting acquirer.

Based on the applicable accounting
guidance noted above, we have concluded that the analysis favors Perfecular Inc. as the accounting acquirer.

      3

5. Tell us also, why you reflected the acquisition of Perfecular
Inc. in your consolidated statements of changes in stockholders’ equity and cash flows as an issuance of shares for cash.

Response: We have reviewed
both statements and noted that the proceeds from issuing stock reported in the consolidated statement of cash flows was related
to the issuance of additional shares by Perfecular, Inc. on December 28, 2015 for cash, prior to the acquisition on December 30,
2016. As such, these additional issuances were also reflected through the consolidated statement of changes in stockholders’
equity as common stock issued as of December 31, 2015. The acquisition on December 30, 2015 was properly accounted for as
a stock exchange, and as such, any related transactions and investment in subsidiary accounts
were appropriately eliminated in the consolidated statements of Focus, Inc.

6. Tell us how you considered whether you should have accounted
for the merger transaction as a reorganization of entities under common control. In this regard, please identify the shareholders
of Perfecular, Inc. and Focus Universal, Inc. and provide us with analysis of their respective holdings from December 31, 2014
through December 30/31, 2015. Similarly, please identify the persons and/or groups which in the aggregate control over 50% of each
of those companies during the same time periods.

Response:
In ASC 850, A “controlling financial interest” is generally defined as ownership of a majority voting interest by one
entity, directly or indirectly, of more than 50 percent of the outstanding voting shares of another entity. Of
the time periods requested, the largest majority shareholder Desheng Weng held majority voting interest in Perfecular Inc. with
51.1% ownership, and 41.185% ownership of Focus Universal Inc. prior to the merger. Per the guidance, “Transfers among entities
that have a high degree of common ownership, but in which no one shareholder controls the entities, are not common control transactions.”
The largest shareholder, Desheng Wang, held 49.169% ownership of the combined entity as of the effective date of the merger.

Shareholders from 12/31/2014-12/30/2015:

    FOCUS Pre-Acquisition:

    Name
    Number of Shares
    Percentage Ownership

    Qin Cai
    200,000
    3.040%

    CEDE & CO
    10,000
    0.152%

    Yan Chen
    600,000
    9.119%

    Desheng Weng
    2,710,000
    41.185%

    Youjuan Xiong
    500,000
    7.599%

    Shiyao Xu
    150,000
    2.280%

    Shuhua Xu
    150,000
    2.280%

    Shuqin Xu
    1,300,000
    19.757%

    Tianzeng Xu
    500,000
    7.599%

    Tiecheng Zhang
    200,000
    3.040%

    Wenshuang Zou
    260,000
    3.951%

    Total
    6,580,000
    100.000%

      4

    Perfecular Inc. Pre-Acquisition:

    Name
    Number of Shares
    Percentage Ownership

    Wenshuang Zou
    5,038
    0.857%

    HwaKay Mao
    14,259
    2.426%

    Lee-An Mao
    1,235
    0.210%

    CC & C Investment LLC
    560
    0.095%

    Wenjin Qian
    4,199
    0.714%

    Yan Chen
    50,385
    8.573%

    Desheng Wang
    300,000
    51.045%

    Edward Lee
    209,937
    35.721%

    Ping Wang
    2,099
    0.357%

    Total
    587,713
    100.000%

Shareholders as of Post-Acquisition 12/31/2015:

    FOCUS Post-Acquisition:

    Name
    Number
    of Perfecular Shares
    Percentage Ownership

    Qin Cai
    200,000
    0.578%

    CEDE & CO
    10,000
    0.029%

    Youjuan Xiong
    500,000
    1.446%

    Shiyao Xu
    150,000
    0.434%

    Shuhua Xu
    150,000
    0.434%

    Shuqin Xu
    1,300,000
    3.760%

    Tianzeng Xu
    500,000
    1.446%

    Tiecheng Zhang
    200,000
    0.578%

    Yan Chen
    3,000,000
    8.677%

    Desheng Weng
    17,000,000
    49.169%

    Wenshuang Zou
    500,000
    1.446%

    HwaKay Mao
    679,215
    1.964%

    Lee-An Mao
    58,824
    0.170%

    CC & C Investment LLC
    26,667
    0.077%

    Wenjin Qian
    200,000
    0.578%

    Eward Lee
    10,000,000
    28.923%

    Ping Wang
    100,000
    0.289%

    Total
    34,574,706
    100.000%

Of the time periods requested, Desheng Weng held 51.1% ownership
in Perfecular Inc. from December 31, 2014 through December 30, 2015, prior to the acquisition.

      5

Signature Page

7. Please have your principal accounting officer or controller
sign your registration statement or confirm that an individual performing in such capacity has signed the filing. In your next
amendment, please identify the person serving in such capacity under the person’s signature. Refer to Instructions 1and 2
to Form S-1.

The Company currently
prepares financial statements by using an in-house bookkeeper and certain outside CPA consultants familiar with SEC accounting
who prepare all financial statements which are then reviewed by the Company’s management before they are sent to the external
auditors. The Company is currently attempting to hire a Chief Financial Officer to be the principal accounting officer.

The Company and its management
acknowledge their responsibility for the accuracy and adequacy of the disclosures they have made in the Registration Statement
and subsequent amendments.

Please contact the undersigned
if you have further questions or comments regarding the Registration Statement as amended by Amendment No. 1.

Sincerely,

/s/Gilbert J. Bradshaw

Gilbert J. Bradshaw

      6

Mail Stop 3720

November 28, 2016

Desheng Wang
Chief Executive Officer
Focus Universal, Inc.
829 Lawson Street
City of Industry, CA 91748

Re: Focus Universal, Inc.
  Registration Statement on Form S-1
Filed  November 4, 2016
  File No.  333-214455

Dear Mr. Wang :

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 com ments 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, w e may have  additional comments.

General

1. Please revise your prospectus cover page and disclosure throughout the prospectus to
indicate a fixed price at which the company will sell the 10 million shares in its best
efforts offering.  As you are not eligi ble to conduct an at -the-market offering under Rule
415(a)(4), you may not offer your shares “ at market prices prevailing at the time of sale,”
as you disclose on page s 2 and 37 .  Instead, you must offer the shares at a fixed price for
the duration of the  offering.

Desheng Wang
Focus Universal, Inc.
November 2 8, 2016
Page 2

 Item 4. Use of Proceeds, page 14

2. You indicate that the offering by the company will be conducted on a best -efforts  basis.
Please revise your disclosures throughout to also discuss how the amount and use of
proceeds will be affected if you only sell 25%, 50% and 75% of the shares being offered,
identifying the amount of proceeds to be used for each stated purpose.

Selling Stockholders, page 35

3. Please revise the selling stoc kholders table to disclose all the information required by
Item 507 of Regulation S -K.  In particular, please add the following information:
 the amount of securities owned by each selling stockholder prior to the offering, and
 the amount and (if one percen t or more) the percentage of securities to be owned by
each selling stockholder after completion of the offering.

Financial Statements

Change In Control, page F -7

4. We no te that you issued 27,994,706 shares of your common stock to the shareholders of
Perfecular, Inc. representing approximately 80% the outstanding shares of the company
and resulting in a change in control of the company’s ownership.   Addressing ASC 805 -
10-55-11 through 55 -15, tell us how you identified the accounting acquirer in the merger
transaction.

5. Tell us also, why you reflected the acquisition of Perfecular, Inc. in your consolidated
statements of changes in stockholders’ equity and cash flows as an  issuance of shares for
cash.

6. Tell us how you considered whether you should have accounted for the merger
transaction as a reorganization of entities under common control.   In this regard, please
identify the shareholders of Perfecular, Inc. and Focus Uni versal, Inc. and provide us
with analysis of their respective holdings  from December 31, 2014 through December
30/31, 2015.   Similarly please identify the persons and/or groups which in the aggregate
control over 50% of each of those companies during the s ame time periods.

Signature Page

7. Please have your principal accounting officer or controller sign your registration
statement or confirm that an individual pe rforming in such capacity has signed the filing.
In your next amendment, please identify the person serving in such capacity under the
person’s signature.  Refer to Instructions 1and 2 to Form S -1.

Desheng Wang
Focus Universal, Inc.
November 2 8, 2016
Page 3

 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.

You may contact Joseph Kempf, Senior Staff Accountant , at (202) 551 -3352  or Carlos
Pacho, Seni or Assistant Chief Accountant,  at (202) 551 -3835  if you have questions regarding
comments on the financial statements and related matters.  Please contact Courtney Lindsay,
Staff Attorney , at (202) 551 -7237  or Kathleen Krebs , Special Counsel,  at (202) 551 -3350  with
any othe r questions.

Sincerely,

 /s/ Kathleen Krebs, for

Larry Spirgel
Assistant Director
AD Office 11 – Telecommunications

cc:  Gilbert J. Bradshaw, Esq.
Wilson & Oskam, LLP

CORRESP
1
filename1.htm

   focusuniversalaccltr.htm - Generated by SEC Publisher for SEC Filing

FOCUS UNIVERSAL

8275 S. Eastern Ave. Ste. 200-674

Las Vegas, NV 89123

U.S. Securities & Exchange Commission                                                                                March 12, 2014

Division of Corporate Finance

100 F Street NE

Washington, D.C. 20549

Attn:     Mr. Larry Spirgel, Assistant Director

Re:        Focus Universal Inc.

              Registration Statement on Form S-1

              Filed March 3, 2014

              File No. 333-193087

Dear Mr. Spirgel:

In accordance with Regulation C, Rule 461, we hereby request acceleration of the effective date of our registration statement on Form S-1, such that it be deemed effective on March 14, 2014, at 2:00 pm (Eastern time), or as soon as practicable thereafter.

We are aware of our obligations under the Act in this regard and acknowledge that:

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

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

3.         we may not assert staff comments and the declaration of effectiveness as a defence in any proceeding initiated by the commission or any person under the federal securities laws of the United States.

Sincerely,

/s/ Tatyana Popova

Tatyana Popova

President

February 19, 2014

Via E -mail
Tatyana Popova
Chief Executive Officer
Focus Universal, Inc.
8275 S. Eastern Avenue
Suite 200 -674
Las Vegas, Nevada 89123

Re: Focus Universal , Inc.
Amendment No. 1 to Registration Statement on Form S -1
Filed February 10, 2014
  File No. 333-193087

Dear Ms. Popova :

We have reviewed your amended 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.

Pleas e 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.

Our Officers, directors, consultants and advisors are involved in other businesses…, page 10

1. We note your response to comment 9 in our letter dated January 22, 2014.  Please revise
your disclosure to clarify what type of business Most Marketing, Inc. is and Ms.
Popova’s relationship to that entity, and describe more fully the nature of her fiducia ry
duty to that company and the conflict with her duties to the registrant.  Also please clarify
what conflicts, actual or potential, exist with respect to your consultants and advisors.

2. Please revise to provide examples of potential “self -dealing” trans actions that could
possibly occur due to the overlapping businesses of the company and Most Marketing,
Inc.

Tatyana Popova
Focus Universal, Inc.
February 19 , 2014
Page 2

 Liquidity, page 27

3. Please revise to disclose whether you expect to have sufficient funds to sustain your
business for 12 months if you receive t he minimum and maximum proceeds from the
offering, respectively.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 You may contact Joseph Cascarano , Staff Accountant , at (202) 551 -3376, or Robert
Littlepage , Accountant Branch Chief, at (202) 551 -3361, if you have questions regarding
comments on the financial statements and related matters.  Please contact Gregory Dundas,
Attorney -Adviso r, at (202) 551 -3436, or me at (202) 551 -3810  with any other questions.

Sincerely,

 /s/ Larry Spirgel

 Larry Spirgel
Assistant Director

cc: Via E -mail
Eric M. Stein, Esq.
Szaferman Lakind Blumstein & Blader, PC

January 22, 2014

Via E -mail
Tatyana Popova
Chief Executive Officer
Focus Universal, Inc.
8275 S. Eastern Avenue
Suite 200 -674
Las Vegas, Nevada 89123

Re: Focus Universal , Inc.
Registration Statement on Form S -1
Filed December 26 , 2013
  File No. 333-193087

Dear Ms. Popova :

We have reviewed your 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 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 reviewi ng any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.

General

1. It appears that your Company is considered a “shell company” as defined in Rule 405 of
Regulation C.   In this regard, we note that your Company has had nominal operations and
assets since inception in December 2012.  Please revise the cover page of your prospectus
to prominently disclose that you are considered a shell company and discuss under
“Shares E ligible for Future Sale,” the resale limitations imposed by Rule 144(i) due to
your shell company status.

2. If true, c onfirm thr ough added disclosure that the C ompany and its promoters have  no
plans or intentions to engage in a merger or acquisition with a n unidentified company  or
person or, once it is a reporting company, to be used as a vehicle for a private company to
become a reporting company.

Tatyana Popova
Focus Universal, Inc.
January 22 , 2014
Page 2

 3. Please supplementally provide us with any written materials that you or anyone
authorized to do so on your b ehalf provide s in reliance on Section 5(d) of the Securities
Act to potential investors that are qualified institutional buyers or institutional accredited
investors.  Similarly, please supplementally provide us with any research reports about
you that are  published or distributed in reliance upon Section 2(a)(3) of the Securities Act
of 1933 added by Section 105(a) of the Jumpstart Our Business Startups Act by any
broker or dealer that is participating or will participate in your offering.

Prospectus Cove r Page

4. Please state that if the minimum is not reached by the end of the offering, funds will be
“promptly” returned  without interest  and include a cross reference to your description of
the procedures for return of funds under “Plan of Distribution.”  Re fer to Rule 10b -9 of
the Securities Exchange Act of 1934.

5. Highlight that your common stock will be an illiquid security without an active trading
market.

6. You state on page 6 that you intend to take advantage of all the reduced regulatory and
reporting re quirements available to an Emerging Growth Company, yet on the following
page you state that you have opted out of the extended transition period available under
section 107(b) of the JOBS Act.  Please revise to reconcile these statements.

Risk Factors, p age 8

7. Please include  a risk factor discussing the amount of discretion the Company will have
over the use of proceeds.

8. Please discuss the risk that, because the officers and directors reside outside the United
States, investors  may have limited legal rec ourse against them including difficulties in
enforcing judgments made against them by U.S. courts.

Our officers, directors, consultants and advisors are involved in other businesses…, page 10

9. You state that your office rs and directors owe a fiduciary duty to other entities.  Please
revise to clarify the nature of those other entities and clarify any actual conflicts of
interest.

There is no public (trading) market for our common stock…, page 14

10. Please delete the reference to selling stockholders.

Tatyana Popova
Focus Universal, Inc.
January 22 , 2014
Page 3

 Use of Proceeds, page 18

11. Please revise to add a table showing the use of proceeds if you receive 50% of the total
amount.

Management’s Discussion and Analysis or Plan of Operations, page 23

12. Please disclose your anticipated expenses of being a public rep orting company with the
SEC.

Results of Operations, page 24

13. Provide more detail as to the source of the Company’s revenues to date.  Describe the
nature of the services performed, the number of contracts entered into and who performed
the work for the Co mpany.

Liquidity, page 26

14. Please revise your statement that you “believe that revenues are increasing and operations
should be sustainable in the long -term” to clarify a) the basis for your statement; b) the
extent of the increases you refer to; and c) t he level of sustainability.

Description of our Business and Properties, page 27

15. We note the statement at the top of page 28 that Web Marketing “represents the fastest
growing new channel.”  Please revise to provide a basis for this statement.

Executive Compensation, page 3 4

16. Please disclose whether the company has plans to pay a salary to the officers in the
foreseeable future.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the fi ling includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and ade quacy of the disclosures they have made.

Tatyana Popova
Focus Universal, Inc.
January 22 , 2014
Page 4

 You may contact Joseph Cascarano , Staff Accountant , at (202) 551 -3376, or Robert
Littlepage , Accountant Branch Chief, at (202) 551 -3361, if you have questions regarding
comments on the financial statements and related matters.  Please contact Gregory Dundas,
Attorney -Advisor, at (202) 551 -3436, or me at (202) 551 -3810  with any other questions.

Sincerely,

 /s/ Larry Spirgel

 Larry Spirgel
Assistant Director

cc: Via E -mail
Eric M. Stein, Esq.
Szaferman Lakind Blumstein & Blader, PC