SecProbe.io

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 March 27, 2026

Leonard Greene
Chief Executive Officer
Greene Concepts, Inc
13195 U.S. Highway 221 N.
Marion, NC 28752

 Re: Greene Concepts, Inc
 Offering Statement on Form 1-A
 Filed March 24, 2026
 File No. 024-12727
Dear Leonard Greene:

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

 We will consider qualifying your offering statement at your request. In
connection with
your request, please confirm in writing that at least one state has advised you
that it is prepared
to qualify or register your offering. If a participant in your offering is
required to clear its
compensation arrangements with FINRA, please have FINRA advise us that it has
no objections
to the compensation arrangements prior to qualification.

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

 Please contact Eranga Dias at 202-551-8107 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
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 filename1.htm

 Green Concepts, Inc.

 13195 U.S. Highway 221 N

 Marion, North Carolina, 28752

 March 27, 2026

 VIA EDGAR

 Office of Manufacturing

 Division of Corporation Finance

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Eranga Dias

 Re: Greene Concepts, Inc.

 Offering Statement on Form 1-A (the
"Offering Statement")

 Filed March 24, 2026

 File No. 024-12727

 Ladies and Gentlemen:

 On behalf of the Company, I respectfully request
that the qualification date of the Offering Statement be accelerated and that the Offering Statement be declared qualified Tuesday, March
31, 2026, at 3:00 p.m. EDT, or as soon thereafter as is reasonably practicable.

 In making this request, the Company represents
that the Post-Qualification Amendment will be approved in the State of Colorado, upon qualification by the Securities and Exchange Commission
(the "Commission"), and acknowledges the following:

 · should the Securities and Exchange Commission (the "Commission")
or the Staff, acting pursuant to delegated authority, declare the filing qualified, 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, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy
of disclosure in the filing; and

 · the Company may not assert staff comments and/or qualification
as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

 Very truly yours,

 /s/ Leonard Greene

 Leonard Greene

 Chief Executive Officer

 Greene Concepts, Inc.

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Greene Concepts,
Inc.

13195 Hwy 221N

Marion, NC 28752

February 26, 2024

VIA EDGAR

Office of Manufacturing

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Eranga Dias

Re: Greene Concepts, Inc. (the “Company”)

  Post-qualification Amendment No. 2 to

  Offering Statement on Form 1-A (the “Post-Qualification
Amendment”)

  Filed January 29, 2024

  Commission File No. 024-12157

Ladies and Gentlemen:

On behalf of the Company, I respectfully request
that the qualification date of the Post-Qualification Amendment be accelerated and that the Post-Qualification Amendment be declared qualified
Wednesday, February 28, 2024, at 10:00 a.m. EDT, or as soon thereafter as is reasonably practicable.

In making this request, the Company represents
that the Post-Qualification Amendment will be approved in the State of New York, upon qualification by the Securities and Exchange Commission
(the “Commission”), and acknowledges the following:

 · should the Securities and Exchange Commission (the “Commission”)
or the Staff, acting pursuant to delegated authority, declare the filing qualified, 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, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy of
disclosure in the filing; and

 · the Company may not assert staff comments and/or qualification as a
defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

Very truly yours,

/s/ Leonard Greene

Leonard Greene

Chief Executive Officer

Greene Concepts, Inc.

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NEWLAN LAW FIRM, PLLC

2201 Long Prairie Road, Suite 107-762

Flower Mound, Texas 75022

January 26, 2023

Office of Manufacturing

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

  Re:
  Greene Concepts, Inc

  Offering Statement on Form 1-A

  Post-qualification Amendment No. 1

  Filed October 23, 2023

  File No. 024-12157

Ladies and Gentlemen:

This is in response to the
letter of comment of the Staff dated November 16, 2023, relating to the captioned Offering Statement on Form 1-A of Greene Concepts, Inc.
(the “Company”). Each of the Staff’s comments are addressed below, seriatim:

Post-Qualification Amendment to Offering
Statement on Form 1-A filed October 23, 2023

Cover Page

1.       Please
revise this section to include the all the information required under Part II - Information Required in Offering Circular of Form 1-A,
including but not limited to, identifying which disclosure format is being followed for your financial statement disclosure obligations.

Please be advised that the Cover Page has been
revised, in response to such comment.

Description of Business

Stay Hemp 4 Life, page 23

2.       We
refer to your disclosure that you “acquired 100% of the membership interests of Stay Hemp 4 Life LLC as a wholly owned subsidiary
of Greene Concepts, Inc. for a purchase price of $275,000.00 and a royalty of $0.04 per product sold.” Please tell us when this
transaction occurred and how you determined that historical financial statements for Stay Hemp 4 Life and pro forma financial statements
were not required in your offering statement pursuant to Part F/S (b)(7)(iii) and (iv) of Form 1-A.

Please be advised that the financial statements
of Stay Hemp 4 Life LLC have been included in the disclosure.

      1

Management's Discussion and Analysis of
Financial Condition and Results of Operations, page 36

3.       Please
revise this section to substantially expand your management's discussion and analysis to include information required by Item 9 of Form
1-A. This section should provide disclosure in the form of a discussion and analysis from management's perspective and should not merely
contain factual statements about your company and its operations. Provide the discussion and analysis in a format that facilitates easy
understanding and that supplements, and does not merely duplicate, disclosure already provided in the filing. The objective of the discussion
and analysis is to provide material information relevant to an assessment of the financial condition and results of operations of Greene
Concepts including industry specific trend information. A discussion and analysis that meets the requirements of Item 9 of Form 1-A is
expected to better allow investors to view Greene Concepts from management's perspective.

Please be advised that the Management’s
Discussion and Analysis section has been revised, in response to such comment.

Consolidated Balance Sheets, page F-2

4.       Your
consolidated balance sheets are dated as of January 31, 2023 and January 31, 2022. However, it appears to us that your balance sheets
are as of July 31, 2023 and July 31, 2022. Please revise the dates in the heading of your consolidated balance sheet as appropriate.

Please be advised that the headings of the consolidated
balance sheets have been revised, in response to such comment.

_______________________

We believe that this filing
is now in order for qualification.

Please feel free to contact
the undersigned at (940) 367-6154, should you have any questions regarding any of the Company's responses.

Thank you for your attention
in this matter.

Sincerely,

NEWLAN LAW FIRM, PLLC

By: /s/ Eric Newlan

Eric Newlan

Managing Member

cc: Greene Concepts, Inc.

      2

United States securities and exchange commission logo
November 16, 2023
Leonard Greene
Chief Executive Officer
Greene Concepts, Inc
13195 U.S. Highway 221 N
Marion, NC 28752
Re:Greene Concepts, Inc
Offering Statement on Form 1-A
Post-qualification Amendment No. 1
Filed October 23, 2023
File No. 024-12157
Dear Leonard Greene:
            We have reviewed your amendment and have the following comment(s).
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response. After
reviewing any amendment to your offering statement and the information you provide in
response to this letter, we may have additional comments.
Post-Qualification Amendment to Offering Statement on Form 1-A filed October 23, 2023
Cover Page
1.Please revise this section to include the all the information required under Part II -
Information Required in Offering Circular of Form 1-A, including but not limited to,
identifying which disclosure format is being followed for your financial statement
disclosure obligations.
Description of Business
Stay Hemp 4 Life, page 23
2.We refer to your disclosure that you “acquired 100% of the membership interests of Stay
Hemp 4 Life LLC as a wholly owned subsidiary of Greene Concepts, Inc. for a purchase
price of $275,000.00 and a royalty of $0.04 per product sold.” Please tell us when this
transaction occurred and how you determined that historical financial statements for Stay
Hemp 4 Life and pro forma financial statements were not required in your offering

 FirstName LastNameLeonard Greene
 Comapany NameGreene Concepts, Inc
 November 16, 2023 Page 2
 FirstName LastName
Leonard Greene
Greene Concepts, Inc
November 16, 2023
Page 2
statement pursuant to Part F/S (b)(7)(iii) and (iv) of Form 1-A.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
36
3.Please revise this section to substantially expand your management's discussion and
analysis to include information required by Item 9 of Form 1-A. This section should
provide disclosure in the form of a discussion and analysis from management's
perspective and should not merely contain factual statements about your company and its
operations. Provide the discussion and analysis in a format that facilitates easy
understanding and that supplements, and does not merely duplicate, disclosure already
provided in the filing. The objective of the discussion and analysis is to provide material
information relevant to an assessment of the financial condition and results of operations
of Greene Concepts including industry specific trend information. A discussion and
analysis that meets the requirements of Item 9 of Form 1-A is expected to better allow
investors to view Greene Concepts from management's perspective.
Consolidated Balance Sheets, page F-2
4.Your consolidated balance sheets are dated as of January 31, 2023 and January 31, 2022.
However, it appears to us that your balance sheets are as of July 31, 2023 and July 31,
2022. Please revise the dates in the heading of your consolidated balance sheet as
appropriate.
            We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Dale Welcome at 202-551-3865 or Melissa Gilmore at 202-551-3777 if
you have questions regarding comments on the financial statements and related matters. Please
contact Eranga Dias at 202-551-8107 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Eric Newlan

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Greene Concepts, Inc.

13195 U.S. Highway 221 N

Marion, North Carolina  28752

March 30, 2023

Bradley Ecker, Esq.

Staff Attorney

Division of Corporation
Finance

Office of Manufacturing

United States Securities
and Exchange Commission

Washington, DC 20549

    Re:

    Greene Concepts, Inc.

Offering Statement on Form 1-A, filed February 16, 2023

File No. 024-12157

Dear Mr. Ecker,

On behalf of Greene Concepts, Inc. (the “Company”), I hereby
request qualification of the above-referenced offering statement at 12:00 noon, Eastern Time, on Monday, April 3, 2023, or as soon thereafter
as is practicable.

The Company is authorized to offer and sell its securities qualified
under the offering statement pursuant to qualification, registration or exemption therefrom in at least one state.

Sincerely,

/s/ Leonard Greene

Leonard Greene

Chief Executive Officer

Greene Concepts, Inc.

United States securities and exchange commission logo
February 23, 2023
Leonard Greene
Chief Executive Officer
Greene Concepts, Inc
13195 U.S. Highway 221 N
28752
Re:Greene Concepts, Inc
Offering Statement on Form 1-A
Filed on February 16, 2023
File No. 024-12157
Dear Leonard Greene:
            This is to advise you that we do not intend to review your offering statement.
            We will consider qualifying your offering statement at your request. In connection with
your request, please confirm in writing that at least one state has advised you that it is prepared
to qualify or register your offering. If a participant in your offering is required to clear its
compensation arrangements with FINRA, please have FINRA advise us that it has no objections
to the compensation arrangements prior to qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Bradley Ecker at (202) 551-4985 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

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Greene Concepts, Inc.

13195 U.S. Highway 221 N

Marion, North Carolina  28752

August 24, 2021

Sergio Chinos, Esq.

Staff Attorney

Division of Corporation
Finance

Office of Manufacturing

United States Securities
and Exchange Commission

Washington, DC 20549

    Re:

    Greene Concepts, Inc.

Post-Qualification Amended Offering Statement on Form 1-A Filed July 21, 2021

File No. 024-11090

Dear Mr. Chinos,

On behalf of Greene Concepts, Inc. (the “Company”), I hereby
request qualification of the above-referenced offering statement at 12:00 noon, Eastern Time, on Friday, August 27, 2021, or as soon thereafter
as is practicable.

The Company is authorized to offer and sell its securities qualified
under the offering statement pursuant to qualification, registration or exemption therefrom in at least one state.

Sincerely,

/s/ Leonard Greene

Leonard Greene

Chief Executive Officer

Greene Concepts, Inc.

STATE OF NEW YORK

OFFICE OF THE ATTORNEY GENERAL

    LETITIA
    JAMES
    (212) 416-8200
    DIVISION OF ECONOMIC JUSTICE

    ATTORNEY GENERAL

    INVESTOR PROTECTION BUREAU

December 23, 2019

Bevilacqua PLLC

1050 Connecticut Avenue, N.W., Suite 500

Washington, DC 20036

Attn:
Kathy Rasler

    Entity Name:
    Greene Concepts, Inc.

    Date Recd:
    12/5/2019

    File Number:
    S34-56-42

    Registration Type:
    M-11

    Fee:
    $1,200.00

Dear Sir/Madam:

This letter is to acknowledge the registration of Greene
Concepts, Inc. and the receipt of the above filing fee.

The effective registration date is 12/5/2019.

Please note that your registration number MUST appear
on all future correspondence.

    Very truly yours,

    INVESTOR PROTECTION BUREAU

THIS REGISTRATION EXPIRES FOUR YEARS

FROM THE EFFECTIVE REGISTRATION DATE.

28 LIBERTY STREET,
NEW YORK, NY 10005 • PHONE (212) 416-8222 • WWW.AG.NY.GOV

United States securities and exchange commission logo
July 23, 2021
Leonard Greene
Chief Executive Officer
Greene Concepts, Inc
13195 U.S. Highway 221 N
Marion, North Carolina 28752
Re:Greene Concepts, Inc
Offering Statement on Form 1-A
Filed July 21, 2021
File No. 024-11090
Dear Mr. Greene:
            This is to advise you that we do not intend to review your offering statement.
            We will consider qualifying your offering statement at your request. In connection with
your request, please confirm in writing that at least one state has advised you that it is prepared
to qualify or register your offering. If a participant in your offering is required to clear its
compensation arrangements with FINRA, please have FINRA advise us that it has no objections
to the compensation arrangements prior to qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Sergio Chinos, Staff Attorney, at (202) 551-7844 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Donnell Suares, Esq.

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Greene
Concepts, Inc.

13195 U.S.
Highway 221 N

Marion, North
Carolina, 28752

(844) 889-2837

February 26, 2020

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC. 20549

Attn: Thomas Jones and Kate McHale

 Re: Greene
                                         Concepts, Inc.

Offering
Statement on Form 1-A

File
No. 024-11090

Ladies and Gentlemen:

We understand
that the staff of the U.S. Securities and Exchange Commission (the “Commission”) has completed its review of the Offering
Statement on Form 1-A, as amended (the “Offering Statement”) of Greene Concepts, Inc. (the “Company”)
and we hereby request that the Commission approve the qualification of the Offering Statement as of 4:00 PM Eastern Standard Time
on Friday, February 28, 2020.

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

Sincerely,

Greene Concepts, Inc.

By: /s/ Leonard Greene

Leonard
Greene

Chief
Executive Officer & Director

 cc: Louis
                                         A. Bevilacqua, Esq.

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Greene
Concepts, Inc.

13195
U.S. Highway 221 N

Marion,
North Carolina, 28752

(844)
889-2837

February 14, 2020

U.S. Securities and Exchange
Commission

100 F Street, N.E.

Washington, DC. 20549

Attn: Thomas Jones and
Kate McHale

Re:
Greene Concepts, Inc.

Amendment
No. 1 to Offering Statement on Form 1-A Filed January 10, 2020

File No. 024-11090

Dear
Ladies and Gentlemen:

We
hereby submit the response of Greene Concepts, Inc. (the “Company”) to the comments of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission set forth in the Staff’s letter, dated January 27, 2020, providing the Staff’s
comments with respect to the Company’s Amendment No. 1 to Regulation A Offering Statement on Form 1-A (“Amendment
No. 1”).

For
the convenience of the Staff, each of the Staff’s comments is included followed by the corresponding response of the Company.
Unless the context indicates otherwise, references in this letter to “we,” “us” and “our”
refer to the Company on a consolidated basis.

Amendment
No. 1 to Form 1-A filed January 10, 2020 Government Regulation, page 28

 1. We
                                         note your response to prior comment 7. Please reconcile your disclosure on page 28 that
                                         it will take approximately six months to prepare your facility with your disclosure on
                                         page 27 that you expect to launch your white label spring water "sometime during
                                         the first quarter of 2020."

Response:
In response to the Staff’s comments, we have revised our disclosure on page 28 and our “Management’s Discussion
and Analysis of Financial Condition and Results of Operations – Plan of Operation” section to clarify that the six-month
time period during which we prepared our North Carolina Facility to comply with FDA regulations for CGMPs and for the production
of dietary supplements will conclude in the first quarter of 2020.

Compensation
of Directors and Executive Officers, page 35

 2. Please
                                         clarify the cash compensation disclosed in the table on page 35 for the fiscal year ended
                                         July 31, 2019. Please disclose by footnote why Mr. Greene's cash compensation is
                                         not showing up as total compensation. We also note the footnote to the table references

Page
2

Ms.
Howard's term as CEO, which conflicts with the disclosure included in the description of consulting agreements. If Mr. Greene
was the CEO prior to Ms. Howard's appointment in January, please make this clear from the disclosure. Please revise to disclose
the status of Ms. Howard's consulting agreement set to expire on January 31, 2020.

Response:
In response to the Staff’s comments, we have added a footnote on page 35 that states the following: “Mr. Greene’s
total compensation for the most recent fiscal year ended July 31, 2019 was $36,847. This compensation was paid to Mr. Greene for
his services rendered as CEO of the Company during the period of August 1, 2018 through January 17, 2019.” We have further
amended the compensation table on page 35 to reflect that Mr. Greene’s total compensation for the most recent fiscal year
ended July 31, 2019 is $36,847.

We
have also revised the erroneous statement in the footnote of the compensation table on page 35 to clarify that Ms. Howard’s
term as CEO of the Company commenced on January 18, 2019 and not April 23, 2019. We corrected the value of the 30,000 shares of
Preferred Class A Stock Ms. Howard received on January 18, 2019 to reflect the January 18, 2019 share price of $0.0250 per share.

Finally,
Ms. Howard’s consulting agreement was assumed by our subsidiary, Mammoth Ventures, Inc., upon Ms. Howard’s simultaneous
resignation as CEO and appointment as Mammoth Ventures, Inc.’s Chief Innovation Officer on November 19, 2019. Ms. Howard’s
consulting agreement expired on January 31, 2020, however, Mammoth Ventures, Inc. continues to pay Ms. Howard the same compensation
and Ms. Howard continues to provide the same services as contemplated by the consulting agreement under an at-will verbal arrangement
on a month to month basis. We have added a disclosure in the footnote of the compensation table on page 35 to this effect.

Security
Ownership of Management and Certain Securityholders, page 37

 3. We
                                         note your response to prior comment 9. Please clarify how you determined the amount of
                                         shares mentioned in the second column of the table on page 37. We note that Mr. Levit
                                         and Mr. Brown, as beneficial owners of BNL would each own 12,000,000 shares of preferred
                                         stock rather than 6,000,000. In addition, please expand the disclosure in footnote (5)
                                         on page 37 to disclose when BNL acquired the shares of preferred stock and the amount
                                         paid to acquire the shares. Please provide all data as of a more recent date.

Response:
To correct the error identified by the Staff in the above comment, we changed the reference to the number of Preferred Class
A shares beneficially ownedby each of Mr. Levit and Mr. Brown from 6,000,000 to 12,000,000 in the second column of the security
ownership table. We also expanded the disclosure in footnote (5) on page 37 to disclose that BNL acquired 10,000,000 of the shares
from Mr. Greene on November 19, 2018 pursuant to a Stock Purchase and Sale Agreement between BNL and Mr. Greene as of such date
for an aggregate purchase price of $18,000. Finally, we expanded the disclosure to indicate that BNL acquired 2,000,000 shares
of Preferred Class A Stock from the Company on February 6, 2019 for no consideration other than as an inducement for BNL to enter
into the Stock Purchase Acquisition Agreement and Merger Agreement and Promissory Note pursuant to which the Company acquired
Mammoth Ventures from BNL.

We
are also confirming that the data provided in the Beneficial Ownership chart on page 37 of Amendment No. 1 is accurate as of the
date hereof.

[Remainder
of Page Intentionally Left Blank]

If you would like to discuss any
of the responses to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned
at 559-434-1000 or Louis Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

Sincerely,

cc:	Louis A. Bevilacqua

By:/s/
Leonard Greene

Leonard Greene

Chief Executive Officer

January 27, 2020
Leonard Greene
Chief Executive Officer
Greene Concepts, Inc.
13195 U.S. Highway 221N
Marion, North Carolina 28752
Re:Greene Concepts, Inc.
Amendment No. 1 to Offering Statement on Form 1-A
Filed January 10, 2020
File No. 024-11090
Dear Mr. Greene:
            We have reviewed your amended offering statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your offering statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your offering statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our October 29, 2019 letter.
Amendment No. 1 to Form 1-A filed January 10, 2020
Government Regulation, page 28
1.We note your response to prior comment 7.  Please reconcile your disclosure on page 28
that it will take approximately six months to prepare your facility with your disclosure on
page 27 that you expect to launch your white label spring water "sometime during the first
quarter of 2020."
Compensation of Directors and Executive Officers, page 35
2.Please clarify the cash compensation disclosed in the table on page 35 for the fiscal year
ended July 31, 2019.  Please disclose by footnote why Mr. Greene's cash compensation is
not showing up as total compensation.   We also note the footnote to the table references

 FirstName LastNameLeonard Greene
 Comapany NameGreene Concepts, Inc.
 January 27, 2020 Page 2
 FirstName LastName
Leonard Greene
Greene Concepts, Inc.
January 27, 2020
Page 2
Ms. Howard's term as CEO, which conflicts with the disclosure included in the
description of consulting agreements.   If Mr. Greene was the CEO prior to Ms. Howard's
appointment in January, please make this clear from the disclosure.   Please revise to
disclose the status of Ms. Howard's consulting agreement set to expire on January 31,
2020.
Security Ownership of Management and Certain Securityholders, page 37
3.We note your response to prior comment 9.  Please clarify how you determined the
amount of shares mentioned in the second column of the table on page 37.  We note that
Mr. Levit and Mr. Brown, as beneficial owners of BNL would each own 12,000,000
shares of preferred stock rather than 6,000,000.  In addition, please expand the disclosure
in footnote (5) on page 37 to disclose when BNL acquired the shares of preferred stock
and the amount paid to acquire the shares.   Please provide all data as of a more recent
date.
            You may contact Dale Welcome at 202-551-3865 or John Cash, Accounting Branch
Chief, at 202-551-3768 if you have questions regarding comments on the financial statements
and related matters.  Please contact Thomas Jones at 202-551-3602 or Kate McHale, Staff
Attorney, at 202-551-3464 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Louis A. Bevilacqua

CORRESP
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Greene
Concepts, Inc.

13195 U.S.
Highway 221 N

Marion, North
Carolina, 28752

(844) 889-2837

January 7, 2019

U.S. Securities and Exchange
Commission

100 F Street, N.E.

Washington, DC. 20549

Attn: Thomas Jones and
Kate McHale

Re:
Greene Concepts, Inc.

Offering
Statement on Form 1-A Filed October 2, 2019

File No. 024-11090

Dear Ladies and Gentlemen:

We
hereby submit the response of Greene Concepts, Inc. (the “Company”) to the comments of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission set forth in the Staff’s letter, dated October 29, 2019, providing the Staff’s
comments with respect to the Company’s Regulation A Offering Statement on Form 1-A (as amended, the “Offering Statement”).

For
the convenience of the Staff, each of the Staff’s comments is included followed by the corresponding response of the Company.
Unless the context indicates otherwise, references in this letter to “we,” “us” and “our”
refer to the Company on a consolidated basis.

Form 1-A
filed October 2, 2019 General

 1. We
                                         note that you acquired Mammoth Ventures Inc., formerly known as North Cove Springs Bottling
                                         and Beverage, Inc., for $1,350,000. Please tell us how you determined that financial
                                         statements for Mammoth and pro forma financial information were not required in your
                                         offering statement pursuant to Part F/S(b)(7)(iii) and (iv) of Form 1-A of
                                         Regulation A. Additionally, please clarify whether the date of the acquisition
                                         was December 24, 2018 or February 6, 2019.

Response:
On November 29, 2018 Mammoth Ventures Inc. (“Mammoth”) was incorporated by BNL Capital LLC, whose principals
are Robert Levit and Loren Brown (“BNL Capital”) in the State of Florida for the purpose of acquiring the water
plant located at 13195 Highway 221N, Marion, North Carolina 28752 comprised of real property, a building and certain water rights
(the “North Carolina Facility”) from North Cove Springs Bottling and Beverage, Inc. and its owner Chris Mencis
(collectively, “North Cove”). The acquisition of the assets constituting the North Carolina Facility by Mammoth
closed on February 5, 2019. For at least six years prior to the acquisition of the assets of the North Carolina Facility, North
Cove had no operations whatsoever, had no employees and generated no revenue from any source. The North Carolina Facility was
dormant during that entire period. Thereafter, on the next day, February 6, 2019, the Company acquired all of the issued and outstanding
capital stock of Mammoth from BNL Capital. Mammoth had no operations other than the ownership of the assets constituting the North
Carolina Facility, which did not operate, from the date of its acquisition of the North Carolina Facility on February 5, 2019
to the date that BNL Capital sold all of the outstanding capital stock of Mammoth to the Company on the next day, February 6,
2019.

The
Company respectfully advises the Staff that it considered the provisions of FASB Accounting Standards Codification Topic 805,
Business Combinations (“Topic 805”), to determine whether an acquisition of all of the outstanding capital
stock of Mammoth should be treated as business combination or an asset acquisition in accordance with GAAP. If the acquisition
of Mammoth does not meet the definition of a “business” under Topic 805, the Company accounts for the transaction
as an asset acquisition rather than a business combination. On the other hand, if the acquisition of Mammoth meets the definition
of a business under Topic 805, the Company applies the acquisition method of accounting for a business combination as provided
for in Topic 805.

Topic
805 defines the term “business” as “[a]n integrated set of activities and assets that is capable of being conducted
and managed for the purpose of providing a return in the form of dividends, lower costs, or other economic benefits directly to
investors or other owners, members, or participants.” Topic 805 also sets forth additional guidance on what constitutes
a business and provides that a business is comprised of three elements: input; process; and output. Topic 805 defines the first
element, input, as “[a]ny economic resource that creates, or has the ability to create, outputs when one or more processes
are applied to it.” Topic 805 defines the second element, process, as “[a]ny system, standard, protocol, convention,
or rule that when applied to an input or inputs, creates or has the ability to create outputs.” Topic 805 provides examples
of what constitutes a process, which include “strategic management processes, operational processes, and resource management
processes.” With respect to the third element, output, Topic 805 provides that outputs are created by the combination of
the first two elements (i.e. inputs and processes applied to those inputs), but are not required for an integrated set to qualify
as a business.

BNL
Capital formed Mammoth as a holding company for the sole purpose of facilitating its acquisition of the North Carolina Facility
and subsequent transfer of the North Carolina Facility (through the transfer of all of the capital stock of Mammoth) to the Company.
For at least the last six years, there have been no operating activities at North Cove, including its North Carolina Facility.
All equipment was inactive, there were no employees or any operational activities or binding agreements with third parties since
such date. The Company also considered Rule 11-01 of Regulation S-X to determine if the acquisition of the capital stock of Mammoth
from BNL Capital was an acquisition of a business for the purposes of providing historical financial statements of Mammoth/North
Cove. The Company concluded that disclosure of any prior financial information of Mammoth/North Cove would not be material to
an understanding of future operations, and also considered the following facts and circumstances, each in accordance with Rule
11-01(d) of Regulation S-X:

 · North
                                         Cove had no revenue or customer base;

 · Although
                                         North Cove owned the North Carolina Facility, which included equipment and other tangible
                                         assets, the North Carolina Facility was not operational, and a significant investment
                                         would be (is) required in order to refurbish or replace the existing equipment to make
                                         the North Carolina Facility operational. The North Carolina Facility did not have the
                                         ability to manufacture any products;

 · The
                                         North Carolina Facility required significant capital improvements and development efforts
                                         and needed to obtain necessary governmental approvals before commencing operations. It
                                         took several months from the date of acquisition of the North Carolina Facility to refurbish
                                         and improve the facility and to get it ready for the manufacture of bottled water. The
                                         Company does not expect to be able to begin selling bottled water until sometime during
                                         the first half of 2020;

 · Mammoth/North
                                         Cove had no employees and a skilled workforce would need to be hired and trained in order
                                         to refurbish the North Carolina Facility, obtain regulatory approvals and begin to manufacture
                                         products;

 · There
                                         is no market distribution system or sales force in place;

 · There
                                         is no customer base;

 · There
                                         are no tradenames that were acquired from North Cove; and

 · There
                                         were no processes in place at the time the Company acquired Mammoth. Mammoth had not
                                         formalized any development plans, obtained regulatory approvals required to commence
                                         operations or finalized any agreements with persons or entities with the capacity to
                                         develop and commercialize any products.

Accordingly,
the Company concluded that the acquisition of the capital stock of Mammoth from BNL Capital does not represent the acquisition
of a business and that the Company is not required to include financial statements or pro forma financial information for Mammoth/North
Cove in accordance with Rule 11-01 of Regulation S-X.

 2. We
                                         note that Exhibit 6.2 refers to Ms. Howard, the Chief Executive Officer and Principal
                                         Accounting Officer, as a contractor. Please tell us and disclose whether you consider
                                         Ms. Howard to be a contractor or an employee of the company. If she is a contractor,
                                         please provide analysis with regard to New York Business Corporation Law and your Bylaws
                                         as to how the Company may legally fill this position with a contractor. Include a discussion
                                         regarding the difference in state and federal liability of a contractor compared to an
                                         employee of the company.

Response:
After filing the Offering Statement, on November 19, 2019, Ms. Howard resigned from her position as Chief Executive Officer of
the Company and as sole director of the Company and was replaced by Leonard Greene, who has become the Company’s Chief
Executive Officer, President and sole director of the Company. Mr. Greene was previously associated with the Company when the
Company ran its legacy business which was the manufacture and distribution of a line of 25 high quality consumer focused
inkjet kits. Ms. Howard was simultaneously appointed as the chief innovation officer of our subsidiary, Mammoth Ventures
Inc., and acts in such capacity as a contractor to the Company. Mr. Greene has entered into an employment offer letter with
the Company, which is now summarized in the “Directors, Executive Officers and Significant Employees”
section of the Offering Statement and acts as an employee to (and not a contractor of) the Company.

Overview, page 1

 3. Please
                                         reconcile your disclosure on page 1 that on February 6, 2019, BNL Capital agreed
                                         to sell 100% of the outstanding shares of Mammoth to you with your disclosure
                                         on page 26 that in November 2018 you formed Mammoth as a wholly owned subsidiary and
                                         on December 24, 2018 Mammoth entered into an agreement to acquire the Marion facility.
                                         Please make conforming changes throughout the offering statement.

Response:
In response to the Staff’s comment, we have revised the disclosure on page 1 and made conforming changes throughout the
offering statement to clarify that the Company did not form Mammoth, rather the Company acquired Mammoth on February 6, 2019 from
BNL Capital as described in more detail in response to comment number 1 above. We will also clarify throughout the offering statement
that Mammoth owned the North Carolina Facility prior to the Company’s acquisition of all of the outstanding capital stock
of Mammoth.

The Offering, page
5

 4. We
                                         note your disclosure on page 5 that the minimum subscription amount is

$100. Please tell
us with specificity which provision in the subscription agreement mentions a minimum subscription amount of $100.

Response: In response to the Staff’s comment, we have revised the subscription agreement to clearly specify in new
Section 1(d) that the minimum subscription amount is $100, unless the Company otherwise agrees.

Since our officers
and directors have substantial influence over the company, page 12

 5. On
                                         page 12 you refer to your directors and executive officers have significant control over
                                         stockholder matters and the substantial equity interest held by your CEO. However,
                                         you disclose on page 33 that your officers and directors as a group beneficially own
                                         0.23% of the total voting stock of the company. Please reconcile. Also, tell us how you
                                         calculated the percentage ownership of your officers and directors mentioned on page
                                         12 if all of the shares offered are sold.

Response:
In response to the Staff’s comment, we revisited our disclosure and determined that this risk factor does not apply to our
company, as our directors and officers only own a small percentage of the Company. We have removed all references in the offering
statement regarding the directors and executives officers having significant control over stockholder matters and substantial
equity interests.

Use of Proceeds,
page 19

 6. Please
                                         revise the disclosure in this section to explain how the proceeds will be used for the
                                         four phases mentioned on page 29.

Response:
In response to the Staff’s comment, we have revised the disclosure in the Section captioned “Management’s Discussion
and Analysis of Financial Condition and Results of Operation – Plan of Operation” to explain how the proceeds of the
Offering will be broken down under different expenditure categories identified in the Use of Proceeds Section (other than working
capital reserves) given the different phases of our twelve month Plan of Operation. The total amount to be spent during the first
twelve months under our Plan of Operation excludes an $87,000 working capital reserve. Assuming we are able to raise at least
$750,000 in gross proceeds (25% of our maximum aggregate offering amount), we would spend those funds over a twelve month period
as provided in our Plan of Operation. We have added a cross reference in our Use of Proceeds section to refer readers to this
breakdown. The revised Plan of Operation is as follows:

Phase
One - Estimated cost of $60,000, allocated as follows: $20,000 – Engineering and Prototyping, $20,000 - Production and
Inventory; and $20,000 Administrative and Corporate Expenses.

Phase
Two - Estimated cost of $150,000 allocated as follows: $130,000 - Production and Inventory; and $20,000 Administrative and
Corporate Expenses.

Phase
Three – Estimated cost of $200,000 allocated as follows: $100,000 – Production and Inventory; $50,000 Administrative
and Corporate Expenses; $45,000 – Marketing; and $5,000 – Professional Fees and Compensation.

Phase
Four – Estimated cost of $200,000, allocated as follows: $155,000 – Marketing; $35,000 – Administrative
and Corporate Expenses; and $10,000 Professional Fees and Compensation.

Description
of Business Government Regulation, page 20

 7. Please
                                         include a discussion regarding your plans to bring your "nutritionally enhanced"
                                         beverage to market and the regulatory process with the FDA and other agencies you mention
                                         o

October 29, 2019
Karen Howard
Chief Executive Officer
Greene Concepts, Inc.
13195 U.S. Highway 221N
Marion, North Carolina 28752
Re:Greene Concepts, Inc.
Offering Statement on Form 1-A
Filed October 2, 2019
File No. 024-11090
Dear Ms. Howard:
            We have reviewed your offering statement and have the following comments.  In some of
our comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to this letter by amending your offering statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.  After reviewing any amendment to your offering statement and the information you
provide in response to these comments, we may have additional comments.
Form 1-A filed October 2, 2019
General
1.We note that you acquired Mammoth Ventures Inc., formerly known as North Cove
Springs Bottling and Beverage, Inc., for $1,350,000. Please tell us how you determined
that financial statements for Mammoth and pro forma financial information were not
required in your offering statement pursuant to Part F/S(b)(7)(iii) and (iv) of Form 1-A of
Regulation A. Additionally, please clarify whether the date of the acquisition was
December 24, 2018 or February 6, 2019.
2.We note that Exhibit 6.2 refers to Ms. Howard, the Chief Executive Officer and Principal
Accounting Officer, as a contractor. Please tell us and disclose whether you consider Ms.
Howard to be a contractor or an employee of the company.  If she is a contractor, please
provide analysis with regard to New York Business Corporation Law and your Bylaws as
to how the Company may legally fill this position with a contractor. Include a discussion
regarding the difference in state and federal liability of a contractor compared to an

 FirstName LastNameKaren  Howard
 Comapany NameGreene Concepts, Inc.
 October 29, 2019 Page 2
 FirstName LastNameKaren  Howard
Greene Concepts, Inc.
October 29, 2019
Page 2
employee of the company.
Overview, page 1
3.Please reconcile your disclosure on page 1 that on February 6, 2019, BNL Capital agreed
to sell 100% of the outstanding shares of Mammoth to you with your disclosure on page
26 that in November 2018 you formed Mammoth as a wholly-owned
subsidiary and on December 24, 2018 Mammoth entered into an agreement to acquire the
Marion facility.  Please make conforming changes throughout the offering statement.
The Offering, page 5
4.We note your disclosure on page 5 that the minimum subscription amount is
$100.   Please tell us with specificity which provision in the subscription agreement
mentions a minimum subscription amount of $100.
Since our officers and directors have substantial influence over the company, page 12
5.On page 12 you refer to your directors and executive officers have significant control over
stockholder matters and the substantial equity interest held by your CEO.  However,
you disclose on page 33 that your officers and directors as a group beneficially own
0.23% of the total voting stock of the company.  Please reconcile.  Also, tell us how you
calculated the percentage ownership of your officers and directors mentioned on page 12
if all of the shares offered are sold.
Use of Proceeds, page 19
6.Please revise the disclosure in this section to explain how the proceeds will be used for the
four phases mentioned on page 29.
Description of Business
Government Regulation, page 20
7.Please include a discussion regarding your plans to bring your "nutrionally enhanced"
beverage to market and the regulatory process with the FDA and other agencies you
mention on page 24.  Please include an estimate of time and cost to receive approval for
your products to be sold to consumers and the type of approval you will seek. Please make
sure your Phase Three plan of operation is consistent with the time and expense
disclosed.   In addition, include a discussion regarding the "strong science and
documentation" to which you refer on page 34 and the foundation for your claims CBD
products have nutritionally enhancing properties and are beneficial for health and
wellness.
Interests of Management and Others in Certain Transactions, page 33
8.Please describe the transactions in which Loren Brown and Robert Levitt acquired 12
million shares of your Preferred Class A Stock. Also, tell us why you have not included in

 FirstName LastNameKaren  Howard
 Comapany NameGreene Concepts, Inc.
 October 29, 2019 Page 3
 FirstName LastNameKaren  Howard
Greene Concepts, Inc.
October 29, 2019
Page 3
this section disclosure concerning Leonard Greene.  In this regard we note your disclosure
on page F-13 about the loan payable to Mr. Greene and the disclosure on page F-15 that
Mr. Greene is a beneficial shareholder.
Security Ownership of Management and Certain Securityholders, page 33
9.We note for the fiscal year ended July 2018, Mr. Leonard Greene owned ten million
shares of your preferred stock and continued to serve as president of the corporation in
2019.  You disclose the Company issued Messrs. Brown and Levitt preferred stock in
exchange for financing the acquisition in February of 2019 equaling 12 million shares.
However, we note your disclosure on page 34 that there are 12,085,500 shares of your
preferred stock issued and outstanding.  Please revise the beneficial ownership table on
page 33 or revise the business section to disclose the repurchase of Mr. Greene's shares.
In addition, in Part I of your offering statement, you disclose the issuance of only 85,500
preferred shares, when it appears you issued 12 million within the last 12 month period.
Please revise or explain this discrepancy to us.

10.Please confirm Ms. Kaye and Mr. Kraemer are no longer significant shareholders in the
company and disclose the mechanism by which they disposed of their shares.  In addition,
please tell us how many shares were outstanding as of July 31, 2018.  On page F-15, you
indicate the 445,000,000 shares owned by Ms. Kaye constituted 43% of the outstanding
common stock of the company, which exceeds the number set forth in the footnotes to the
beneficial ownership table on page 33.   Please reconcile this disclosure.
Unaudited Financial Statements for the Nine Months Ended April 30, 2019
Note 1 – Significant Accounting Policies
E. Fixed Assets, page F-5
11.We note your disclosure that the Marion, North Carolina facility was valued by a third
party appraisal and is depreciated based on that valuation. Although you are not required
to make reference to this independent third-party expert, to the extent that you do refer to
experts in your offering statement, we remind you that you should disclose the name of
the expert and include the expert’s consent pursuant to Item 17(11) to Part III of Form 1-
A. Please revise your offering statement accordingly, remove the reference to the third
party appraiser, or explain to us why a consent is not required.
Exhibit Index, page F-17
12.Please file as exhibits the Asset Purchase Contract and Receipt agreement mentioned on
page 26 and the agreement underlying the shareholder loan payable mentioned on page F-
13.
            We will consider qualifying your offering statement at your request.  In connection with
your request, please confirm in writing that at least one state has advised you that it is prepared
to qualify or register your offering.  If a participant in your offering is required to clear its

 FirstName LastNameKaren  Howard
 Comapany NameGreene Concepts, Inc.
 October 29, 2019 Page 4
 FirstName LastName
Karen  Howard
Greene Concepts, Inc.
October 29, 2019
Page 4
compensation arrangements with FINRA, please have FINRA advise us that it has no objections
to the compensation arrangements prior to qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Dale Welcome at 202-551-3865 or John Cash, Accounting Branch
Chief, at 202-551-3768 if you have questions regarding comments on the financial statements
and related matters.  Please contact Thomas Jones at 202-551-3602 or Kate McHale, Staff
Attorney, at 202-551-3464 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Louis A. Bevilacqua