SecProbe.io

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 April 15, 2025

Naveen Krishnarao Kulkarni
Chief Executive Officer and President
Quantumzyme Corp.
15656 Bernardo Center Drive Suite 801
San Diego, CA 92127

 Re: Quantumzyme Corp.
 Registration Statement on Form 10-12G
 Filed February 3, 2025
 File No. 000-56725
Dear Naveen Krishnarao Kulkarni:

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

 Sincerely,

 Division of Corporation
Finance
 Office of Industrial
Applications and
 Services
cc: Jessica Lockett, Esq.
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CORRESP
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 qtzm_corresp.htm April 1, 2025 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Industrial Applications and Services 100 F Street, N.E. Washington, DC 20549 Attn: Christie Wong, Jeanne Baker, Nicholas O'Leary, Margaret Sawicki Re: Quantumzyme Corp. Registration Statement on Form 10-12G Filed February 3, 2025 Amendment No. 1 to Registration Statement on Form 10-12G Filed March 10, 2025 File No. 000-56725 Ladies and Gentlemen: We are submitting this letter on behalf of Quantumzyme Corp. (the “Company”) in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by electronic mail dated March 21, 2025, relating to the Company’s Registration Statement on Form 10-12G (File No. 000-56725) originally filed with the Commission on February 3, 2025, as amended on March 10, 2025 (collectively, the “Filing”). The numbered paragraphs below correspond to the numbered comments in the Staff’s letter dated March 21, 2025, and the Staff’s comments are presented in italics. Additionally, the Company has amended its Registration Statement to reflect and address Staff’s comments as necessary, the Company’s Amendment No. 2 to the Registration Statement (“Amendment No. 2”) is being filed concurrently herewith. Amendment No. 1 to Form 10-12G, filed March 10, 2025 Item 1. Description of Business, page 4 1. We note your revisions in response to prior comments 2 and 3. We note your disclosure that "commercialization of your enzyme will be by and through third party manufacturers, who will ultimately supply the product to the consumer, such manufacturers will be required to comply with required all governmental regulatory issues, including the FDA and similar governmental agencies." We also note that you state "initially" you will not be subject to any regulatory or compliance issues. Please revise to clarify if regulatory approval will be needed by the Company or any third party. If so, please briefly describe the regulatory approval process that your products will need to complete, including any review required by regulators for enzymes used in biopharmaceutical applications. RESPONSE: In response to the Staff’s comment, the Company has revised the Filing, to clarify that while we will not be directly responsible for obtaining regulatory approvals, the third-party manufacturers commercializing our enzyme will be required to comply with all applicable regulatory requirements, including those set forth by the U.S. Food and Drug Administration (FDA) and similar regulatory bodies in other jurisdictions, see page 7 of the Filing for the complete revisions. 2. We note your statement on page 4: "As of the date hereof, we have engineered our first product, which is an enzyme for use in pharmaceutical API production of Ibuprofen. Specifically, our initial product is targeted at select pharmaceutical companies who produce generic drugs." We also note your statement on page 17: "We anticipate that we will file and prosecute patent applications and endeavor to maintain trade secrets in an ongoing effort to protect our intellectual property rights as we move the business forward." Please revise to state whether you have patent protection for your first product or any other products. If so, for each material patent please provide (i) the type of patent protection, (ii) the product the patent relates to, (iii) whether such patent is owned or licensed, (iv) the jurisdiction and (v) the expiration date. RESPONSE: : In response to the Staff’s comment, the Company has revised the Filing on pages 4 and 17 to clarify that as of the date of the Filing we have no Patents, or Patent applications issued or pending. 1 Item 1A. Risk Factors, page 14 3. We note your revisions in response to prior comment 4 that you pay for the use of testing facilities on an as needed basis, with no formal written agreement in place. Please also provide a separate risk factor regarding the risks associated with conducting all of your testing in these off-site locations with no formal agreements. RESPONSE: In response to the Staff’s comment, the Company has revised the Filing to include a risk factor regarding the risks associated with conducting testing in off-site locations with no formal agreements. 4. We note that you only have one employee. Please revise to describe how you plan to accomplish your business objectives in the near-term through the efforts of your one employee, noting whether you intend to hire independent contractors or other employees. Please include risk factor disclosure regarding the risks of employing only one employee. RESPONSE: In response to the Staff’s comment, the Company has revised the Filing to include a risk factor regarding the risks associated with employing only one employee. Item 4. Security Ownership of Certain Beneficial Owners and Management, page 22 5. We note your statement on page 23: "Conversion of the Series A and Series B Shares is voluntary at the discretion of the holder and the Series A and Series B Preferred Stock carry other rights, preferences, and privileges customary with series of preferred stock of this nature." We also note that your controlling stockholder, who is also your CEO and President, currently holds all outstanding preferred stock. Please revise to describe the rights, preferences and privileges of your preferred stock. Refer to Item 202(a)(4) of Regulation S-K. RESPONSE: In response to the Staff’s comment, the Company would point the Staff to the both the section immediately following the footnotes to the above referenced chart, captioned Control and Voting Rights of Preferred Shareholders, setting forth the rights, preferences and privileges of both the Series A and Series B Preferred Stock. Additionally, we have added additional disclosure relating to the Series A and Series B Preferred Stock on page 31 of the Filing. Exhibits 6. We note your response to prior comment 11. It appears that the Asset Purchase Agreement shown in the Exhibit Index as Exhibit 10.1 links to the Employment Agreement filed as Exhibit 10.2. Please revise or advise. RESPONSE: In response to the Staff’s comment, the Company has included the Asset Purchase Agreement as Exhibit 10.1 to this Amendment No. 2 and the link to the Employment Agreement has been corrected to 10.2. In response to the Staff’s comment, the Company has revised its disclosure to clarify our understanding of the existing and anticipated government regulations that may affect our business. Should the Staff have additional questions or comments regarding the foregoing, please do not hesitate to contact the undersigned at 954-903-7856. Very Truly Yours, By: /s/ Naveen Krishnarao Kulkarni Naveen Krishnarao Kulkarni 2

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 March 21, 2025

Naveen Krishnarao Kulkarni
Chief Executive Officer and President
Quantumzyme Corp.
15656 Bernardo Center Drive Suite 801
San Diego, CA 92127

 Re: Quantumzyme Corp.
 Amendment No. 1 to Registration Statement on Form 10-12G
 Filed March 10, 2025
 File No. 000-56725
Dear Naveen Krishnarao Kulkarni:

 We have reviewed your filing and have the following comment(s).

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

 After reviewing your response and any amendment you may file in
response to this
letter, we may have additional comments.

Amendment No. 1 to Form 10-12G, filed March 10, 2025
Item 1. Description of Business, page 4

1. We note your revisions in response to prior comments 2 and 3. We note
your
 disclosure that "commercialization of your enzyme will be by and through
third party
 manufacturers, who will ultimately supply the product to the consumer,
such
 manufacturers will be required to comply with required all governmental
regulatory
 issues, including the FDA and similar governmental agencies." We also
note that you
 state "initially" you will not be subject to any regulatory or
compliance issues. Please
 revise to clarify if regulatory approval will be needed by the Company
or any third
 party. If so, please briefly describe the regulatory approval process
that your products
 will need to complete, including any review required by regulators for
enzymes used
 in biopharmaceutical applications.
2. We note your statement on page 4: "As of the date hereof, we have
engineered our
 first product, which is an enzyme for use in pharmaceutical API
production of
 Ibuprofen. Specifically, our initial product is targeted at select
pharmaceutical
 March 21, 2025
Page 2

 companies who produce generic drugs." We also note your statement on
page 17: "We
 anticipate that we will file and prosecute patent applications and
endeavor to maintain
 trade secrets in an ongoing effort to protect our intellectual property
rights as we move
 the business forward." Please revise to state whether you have patent
protection for
 your first product or any other products. If so, for each material
patent please provide
 (i) the type of patent protection, (ii) the product the patent relates
to, (iii) whether such
 patent is owned or licensed, (iv) the jurisdiction and (v) the
expiration date.
Item 1A. Risk Factors, page 14

3. We note your revisions in response to prior comment 4 that you pay for
the use of
 testing facilities on an as needed basis, with no formal written
agreement in place.
 Please also provide a separate risk factor regarding the risks
associated with
 conducting all of your testing in these off-site locations with no
formal agreements.
4. We note that you only have one employee. Please revise to describe how
you plan to
 accomplish your business objectives in the near-term through the efforts
of your one
 employee, noting whether you intend to hire independent contractors or
other
 employees. Please include risk factor disclosure regarding the risks of
employing only
 one employee.
Item 4. Security Ownership of Certain Beneficial Owners and Management, page 22

5. We note your statement on page 23: "Conversion of the Series A and
Series B Shares
 is voluntary at the discretion of the holder and the Series A and Series
B Preferred
 Stock carry other rights, preferences, and privileges customary with
series of preferred
 stock of this nature." We also note that your controlling stockholder,
who is also your
 CEO and President, currently holds all outstanding preferred stock.
Please revise to
 describe the rights, preferences and privileges of your preferred stock.
Refer to Item
 202(a)(4) of Regulation S-K.
Exhibits

6. We note your response to prior comment 11. It appears that the Asset
Purchase
 Agreement shown in the Exhibit Index as Exhibit 10.1 links to the
Employment
 Agreement filed as Exhibit 10.2. Please revise or advise.
 March 21, 2025
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.

 Please contact Christie Wong at 202-551-3684 or Jeanne Baker at
202-551-3691 if
you have questions regarding comments on the financial statements and related
matters. Please contact Nicholas O'Leary at 202-551-4451 or Margaret Sawicki at
202-551-
7153 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Jessica Lockett, Esq.
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CORRESP
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 qtzm_corresp.htm March 10, 2025 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Industrial Applications and Services 100 F Street, N.E. Washington, DC 20549 Attn: Christie Wong, Jeanne Baker, Nicholas O'Leary, Margaret Sawicki Re: Quantumzyme Corp. Registration Statement on Form 10-12G Filed February 3, 2025 File No. 000-56725 Ladies and Gentlemen: We are submitting this letter on behalf of Quantumzyme Corp. (the “Company”) in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by electronic mail dated February 26, 2025, relating to the Company’s Registration Statement on Form 10-12G (File No. 000-56725) filed with the Commission on February 3, 2025 (the “Registration Statement”). The numbered paragraphs below correspond to the numbered comments in the Staff’s letter and the Staff’s comments are presented in bold italics. Additionally, the Company has amended its Registration Statement to reflect and address Staff’s comments as necessary, the Company’s Amendment No. 1 to the Registration Statement (“Amendment No. 1” or “Filing”) is being filed concurrently herewith. Registration Statement on Form 10-12G filed February 3, 2025 Item 1. Description of Business, page 4 1. We note that you have a dual class capital structure whereby Series A and B Preferred Stock have the voting power of 100 and 500 common shares, respectively, and it appears Mr. Kulkarni will have majority voting control of the Company. Please revise your disclosure here at the outset of your business section to discuss the dual class nature of your capital structure and quantify the voting control that Mr. Kulkarni has as the sole preferred stockholder. In addition, revise your disclosure here and throughout the filing, including the risk factor section, to detail the dilutive effect of the Series A and Series B Preferred Shares, including future issuances, and the controlling impact of the Series A and B Preferred Shares, such as Mr. Kulkarni’s ability to control matters requiring shareholder approval, including the election of directors, amendment of organizational documents, and approval of major corporate transactions, such as a change in control, merger, consolidation, or sale of assets. RESPONSE: We have revised the Filing throughout to discuss the dual class nature of our capital structure, quantify the voting control that Mr. Kulkarni has as the sole preferred stockholder, including the risk factor section, detailed the dilutive effect of the Series A and Series B Preferred Shares, and have clarified Mr. Kulkarni’s ability to control all matters requiring shareholder approval. 2. Please revise this section to expand your disclosure further to identify the governmental authorities and the laws and regulations relating to the manufacture of your products or related health and safety or other laws or regulations that are material to your business. Refer to Item 101(h)(4)(viii) and (ix) of Regulation S-K. RESPONSE: We have revised the Filing to include two new sections captioned “Regulatory and Legal Compliance” and “Key Safety Considerations”, see page 9. 1 The Quantumzyme Solution, page 6 3. We note your disclosure that you intend to seek financial success through commercialization of enzyme-based products and services. We note your disclosure on page 4 that you have engineered one product, an enzyme that you believe could be used in the manufacture of Ibuprofen. Please revise to clarify what further steps would be needed for you to commercialize this product, including any regulatory approvals. To the extent you have begun any other programs, and they are currently material to your business, disclose the phase of development you have reached with those programs. RESPONSE: In response to the Staff’s comment, the Company has revised the Filing on page 6, to clarify that we currently have one product and since our business model envisions us only selling/licensing any product to a third party manufacture, that such manufacture will ultimately be responsible for the regulatory procedures related to bringing that product to market and ultimately the end-user consumer. Additionally, we have clarified that currently we only have one product and no other products that are material to the business, but that we are consistently assessing and evaluating potential new projects. Quantumzyme Current Properties, Assets & Equipment, page 9 4. We note your disclosure that you test your technology at off-site locations, where you also conduct your research and development. Revise to clarify whether you lease or own those facilities and any agreements you have for their use. Please also provide a separate risk factor regarding the risks associated with operating in these off-site locations. RESPONSE: In response to the Staff’s comment, the Company has revised the Filing on page 9 to clarify that the space we utilize for research and development is rented on an as needed basis. Corporate History The Company, page 11 5. We note your disclosure that you “require funding from this offering to expand and further develop our operations.” Please remove this statement as there is not an offering being conducted in connection with this registration statement. RESPONSE: In response to the Staff’s comment, the Company has revised the Filing to remove the aforementioned statement. Item 1A. Risk Factors, page 12 6. We note your disclosure here and on page 17 where you refer to this registration statement as an offering circular. Please revise this language throughout the filing to reflect that this is a registration statement on Form 10 and not an offering circular. RESPONSE: In response to the Staff’s comment, the Company has revised the Filing to remove the aforementioned statement. As an "Emerging Growth Company" any decision to comply with the reduced disclosure requirements applicable to emerging growth . . . , page 16 7. Please update your disclosure to reflect that the current revenue threshold for an Emerging Growth Company (EGC) is $1.235 billion. Refer to the definition of EGC in Rule 405 under the Securities Act. Also, since you are a smaller reporting company, please add a separate risk factor disclosing that even if you no longer qualify as an EGC, you may still be subject to reduced reporting requirements so long as you are a smaller reporting company. RESPONSE: In response to the Staff’s comment, the Company has revised the Filing disclosing that even if we no longer qualify as an EGC, we may still be subject to reduced reporting requirements. 2 Item 4. Security Ownership of Certain Beneficial Owners and Management, page 20 8. We note your table on page 20. Please explain why the title and number of shares owned by Manu Bharath Khareedhi is shown as "NIL" but the percentage is "1.05%." Additionally, we note there are footnotes (2), (3), and (4) that are not described under the table. Please revise. RESPONSE: In response to the Staff’s comment, the Company has revised the Filing accordingly, please see page 20. 9. Please revise to disclose the percentage of outstanding shares that preferred shareholders must keep to continue to control the outcome of matters submitted to shareholders for approval. Disclose that the disparate voting rights may have anti-takeover effects preventing a change in control transaction. Describe the circumstances or events in which the conversion of preferred shares is mandatory or optional. RESPONSE: In response to the Staff’s comment, the Company has revised the Filing accordingly, please see page 20. Item 6. Executive Compensation, page 23 10. We note your disclosure that Mr. Kulkarni received restricted shares under his Executive Employment Agreement. Please revise to provide the information required by Item 402(p) of Regulation S-K or advise. Additionally, you disclose that the term of the Executive Employment Agreement with Mr. Kulkarni expired in May of 2024. Please revise to disclose if you entered into a new Executive Employment Agreement with Mr. Kulkarni. RESPONSE: In response to the Staff’s comment, the Company has revised the Filing to include the information required by Item 402(p) of Regulation S-K and added disclosure relating to the extension of the Executive Employment Agreement. Exhibits 11. Please file as an exhibit the Asset Purchase Agreement between you, Reliant Service Inc. and Mr. Kulkarni, your Chief Executive Officer and President. RESPONSE: In response to the Staff’s comment, the Company has revised the Filing accordingly 12. Please be advised that your registration statement will automatically become effective 60 calendar days after filing. Upon effectiveness, you will become subject to the reporting requirements of the Securities Exchange Act of 1934, even if we have not cleared comments. In the event it appears that you will not be able to respond to all of our comments by the 60th day, you may wish to consider withdrawing your registration statement and refiling it. Please confirm your understanding. RESPONSE: We acknowledge and confirm our understanding of the foregoing. 13. Please revise the discussion of your business to define or explain specialized terms at first use, including biotransformation, biocatalysis and legacy reactions. RESPONSE: We have revised the Filing to include a new section captioned “Glossary”, see page 6. In response to the Staff’s comment, the Company has revised its disclosure to clarify our understanding of the existing and anticipated government regulations that may affect our business. Should the Staff have additional questions or comments regarding the foregoing, please do not hesitate to contact the undersigned at 954-903-7856. Very Truly Yours, By: /s/ Naveen Krishnarao Kulkarni Naveen Krishnarao Kulkarni 3

February 26, 2025
Naveen Krishnarao Kulkarni
Chief Executive Officer and President
Quantumzyme Corp.
15656 Bernardo Center Drive Suite 801
San Diego, CA 92127
Re:Quantumzyme Corp.
Registration Statement on Form 10-12G
Filed February 3, 2025
File No. 000-56725
Dear Naveen Krishnarao Kulkarni:
            We have reviewed your filing and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to this
letter, we may have additional comments.
Registration Statement on Form 10-12G filed February 3, 2025
Item 1. Description of Business, page 4
1.We note that you have a dual class capital structure whereby Series A and B Preferred
Stock have the voting power of 100 and 500 common shares, respectively, and it
appears Mr. Kulkarni will have majority voting control of the Company. Please revise
your disclosure here at the outset of your business section to discuss the dual class
nature of your capital structure and quantify the voting control that Mr. Kulkarni has
as the sole preferred stockholder. In addition, revise your disclosure here and
throughout the filing, including the risk factor section, to detail the dilutive effect of
the Series A and Series B Preferred Shares, including future issuances, and the
controlling impact of the Series A and B Preferred Shares, such as Mr. Kulkarni’s
ability to control matters requiring shareholder approval, including the election of
directors, amendment of organizational documents, and approval of major corporate
transactions, such as a change in control, merger, consolidation, or sale of assets.

February 26, 2025
Page 2
2.Please revise this section to expand your disclosure further to identify the
governmental authorities and the laws and regulations relating to the manufacture of
your products or related health and safety or other laws or regulations that are material
to your business. Refer to Item 101(h)(4)(viii) and (ix) of Regulation S-K.
The Quantumzyme Solution, page 6
3.We note your disclosure that you intend to seek financial success through
commercialization of enzyme-based products and services. We note your disclosure
on page 4 that you have engineered one product, an enzyme that you believe could be
used in the manufacture of Ibuprofen. Please revise to clarify what further steps would
be needed for you to commercialize this product, including any regulatory approvals.
To the extent you have begun any other programs, and they are currently material to
your business, disclose the phase of development you have reached with those
programs.
Quantumzyme Current Properties, Assets & Equipment, page 9
4.We note your disclosure that you test your technology at off-site locations, where you
also conduct your research and development. Revise to clarify whether you lease or
own those facilities and any agreements you have for their use. Please also provide a
separate risk factor regarding the risks associated with operating in these off-site
locations.
Corporate History
The Company, page 11
5.We note your disclosure that you “require funding from this offering to expand and
further develop our operations.” Please remove this statement as there is not an
offering being conducted in connection with this registration statement.
Item 1A. Risk Factors, page 12
6.We note your disclosure here and on page 17 where you refer to this registration
statement as an offering circular. Please revise this language throughout the filing to
reflect that this is a registration statement on Form 10 and not an offering circular.
As an "Emerging Growth Company" any decision to comply with the reduced disclosure
requirements applicable to emerging growth . . . , page 16
7.Please update your disclosure to reflect that the current revenue threshold for an
Emerging Growth Company (EGC) is $1.235 billion. Refer to the definition of EGC
in Rule 405 under the Securities Act. Also, since you are a smaller reporting
company, please add a separate risk factor disclosing that even if you no longer
qualify as an EGC, you may still be subject to reduced reporting requirements so long
as you are a smaller reporting company.

February 26, 2025
Page 3
Item 4. Security Ownership of Certain Beneficial Owners and Management, page 20
8.We note your table on page 20. Please explain why the title and number of shares
owned by Manu Bharath Khareedhi is shown as "NIL" but the percentage is "1.05%."
Additionally, we note there are footnotes (2), (3), and (4) that are not described under
the table. Please revise.
9.Please revise to disclose the percentage of outstanding shares that preferred
shareholders must keep to continue to control the outcome of matters submitted to
shareholders for approval. Disclose that the disparate voting rights may have anti-
takeover effects preventing a change in control transaction. Describe the
circumstances or events in which the conversion of preferred shares is mandatory or
optional.
Item 6. Executive Compensation, page 23
10.We note your disclosure that Mr. Kulkarni received restricted shares under his
Executive Employment Agreement. Please revise to provide the information required
by Item 402(p) of Regulation S-K or advise. Additionally, you disclose that the term
of the Executive Employment Agreement with Mr. Kulkarni expired in May of 2024.
Please revise to disclose if you entered into a new Executive Employment Agreement
with Mr. Kulkarni.
Exhibits
11.Please file as an exhibit the Asset Purchase Agreement between you, Reliant Service
Inc. and Mr. Kulkarni, your Chief Executive Officer and President.
General
12.Please be advised that your registration statement will automatically become effective
60 calendar days after filing. Upon effectiveness, you will become subject to the
reporting requirements of the Securities Exchange Act of 1934, even if we have not
cleared comments. In the event it appears that you will not be able to respond to all of
our comments by the 60th day, you may wish to consider withdrawing your
registration statement and refiling it. Please confirm your understanding.
13.Please revise the discussion of your business to define or explain specialized terms at
first use, including biotransformation, biocatalysis and legacy reactions.

February 26, 2025
Page 4
            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 Christie Wong at 202-551-3684 or Jeanne Baker at 202-551-3691 if
you have questions regarding comments on the financial statements and related
matters. Please contact Nicholas O'Leary at 202-551-4451 or Margaret Sawicki at 202-551-
7153 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Jessica Lockett, Esq.

CORRESP
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filename1.htm

qtzm_corresp.htmQUANTUMZYME CORP.

 May 24, 2024

 United States Securities & Exchange Commission

 Division of Corporate Finance – Office of Real Estate & Construction

 Washington, DC 20549

   Re:

   QUANTUMZYME CORP. (the “Company”)

 Offering Statement 1-A/A

 Filed: May 13, 2024

 File No. 024-12403

 Dear Sir or Madam:

 We respectfully request that the Commission qualify the Offering on or before 2pm EST, May 29, 2024, and agree that:

 On behalf of the Company, the undersigned: (i) confirms that at least one state has advised the Company that it is prepared to qualify the offering, and (ii) acknowledges that:

 1. Should the Commission or the Staff, acting pursuant to delegated authority, declare the filing of the Offering Statement qualified, it 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 the filing qualified, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 3. We do not require FINRA to approve any of our compensation agreements, as we are self-underwriting and not engaging any third parties to assist in the sale or marketing of this Offering. Note, the management fee that the Company receives upon the sale of any real estate does not require us to register as a broker/dealer or an investment adviser under the 1940 Act or any other applicable state statute; and

 4. The Company may not assert Staff comments and the declaration of qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 If you have any questions or comments regarding the foregoing, please do not hesitate to contact the undersigned via email at naveen@quantumzymecorp.com.

 By: /s/ Naveen Kulkarni

 Name: Naveen Kulkarni

 Title: CEO

CORRESP
1
filename1.htm

qtzm_corresp.htmMay 13, 2024

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Industrial Applications and Services

 100 F Street, N.E.

 Washington, DC 20549

     Attn:

   Robert Augustin,

   Abby Adams

   Re:

   Quantumzyme Corp.

   Offering Statement on Form 1-A

 Filed February 29, 2024

 File No. 024-12403

 Ladies and Gentlemen:

 We are submitting this letter on behalf of Quantumzyme Corp. (the “Company”) in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by electronic mail dated May 10, 2024, relating to the Company’s Offering Statement on Form 1-A (File No. 024-12403) filed with the Commission on February 29, 2024 (the “Offering Statement”). The numbered paragraphs below correspond to the numbered comments in the Staff’s letter and the Staff’s comments are presented in bold italics. Additionally, the Company has amended its Offering Statement to reflect and address Staff’s comments as necessary, the Company’s Amendment No. 3 to the Offering Statement (“Amendment No. 3”) is being filed concurrently herewith.

 Amendment 2 to Offering Statement on Form 1A submitted April 29, 2024

 Description of Business

 The Quantumzyme Solution, page 25

 1. We note your revised disclosure in response to comment 4. I appears from the revised disclosure that, thus far, you have engineered one product, an enzyme that you believe could be used in the manufacture of Ibuprofen, as disclosed on page 21. If so, please revise to clarify what further steps would be needed for you to commercialize this product. For example, does it require FDA approval, and if so, disclose what type of FDA review would be required. To the extent you have begun any other programs and they are currently material to your business, disclose at what phase of development you have reached with those programs. Finally, we note that you conduct your research and development activities at offsite facilities. Revise to clarify whether you lease or own those facilities and any agreements you have for their use.

 In response to the Staff’s comment, the Company has revised Page 25, to clarify that we currently have one product and since our business model envisions us only selling/licensing any product to a third party manufacture, that such manufacture will ultimately be responsible for the regulatory procedures related to bringing that product to market and ultimately the end-user consumer. Additionally, we have clarified that currently we only have one product and no other products that are material to the business, but that we are consistently assessing and evaluating potential new projects. Also, we have revised Page 27 to clarify that the space we utilize for research and development is rented on an as needed basis.

 Should the Staff have additional questions or comments regarding the foregoing, please do not hesitate to contact the undersigned at 954-903-7856.

      Very Truly Yours,

    By:  /s/ Jonathan Leinwand, Esq.

   Jonathan Leinwand, Esq.

   Cc:

   Quantumzyme Corp.

United States securities and exchange commission logo
May 10, 2024
Naveen Krishnarao Kulkarni
Chief Executive Officer and President
Quantumzyme Corp.
15656 Bernardo Center Drive
Suite 801
San Diego, CA 92127
Re:Quantumzyme Corp.
Amendment No. 2 to Offering Statement on Form 1-A
Filed April 29, 2024
File No. 024-12403
Dear Naveen Krishnarao Kulkarni:
            We have reviewed your amended offering statement 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. Unless we note otherwise,
any references to prior comments are to comments in our April 18, 2024 letter.
Amendment 2 to Offering Statement on Form 1A submitted April 29, 2024
Description of Business
The Quantumzyme Solution, page 25
1.We note your revised disclosure in response to comment 4.  I appears from the revised
disclosure that, thus far, you have engineered one product, an enzyme that you believe
could be used in the manufacture of Ibuprofen, as disclosed on page 21.  If so, please
revise to clarify what further steps would be needed for you to commercialize this
product.  For example, does it require FDA approval, and if so, disclose what type of FDA
review would be required.  To the extent you have begun any other programs and they are
currently material to your business, disclose at what phase of development you have
reached with those programs.  Finally, we note that you conduct your research and
development activities at offsite facilities.  Revise to clarify whether you lease or own
those facilities and any agreements you have for their use.

 FirstName LastNameNaveen Krishnarao Kulkarni
 Comapany NameQuantumzyme Corp.
 May 10, 2024 Page 2
 FirstName LastName
Naveen Krishnarao Kulkarni
Quantumzyme Corp.
May 10, 2024
Page 2
            Please contact Robert Augustin at 202-551-8483 or Abby Adams at 202-551-6902 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services

United States securities and exchange commission logo
April 18, 2024
Naveen Krishnarao Kulkarni
Chief Executive Officer and President
Quantumzyme Corp.
15656 Bernardo Center Drive
Suite 801
San Diego, CA 92127
Re:Quantumzyme Corp.
Amendment No. 1 to Offering Statement on Form 1-A
Filed April 3, 2024
File No. 024-12403
Dear Naveen Krishnarao Kulkarni:
            We have reviewed your amended offering statement 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. Unless we note otherwise,
any references to prior comments are to comments in our March 14, 2024 letter.
Amendment No. 1 to Offering Statement on Form 1A submitted April 3, 2024
Cover Page
1.We reissue comment 1.  Please revise the chart on the cover page and on page 9 to clarify
the conversion ratios and the meaning of "NTL."
Description of Business
Company Overview, page 21
2.We note your disclosure on pages 31 that you plan “to establish [y]ourselves as industry
leaders by solving complex chemistry problems in the pharmaceutical, fragrances, and
flavors sectors." Additionally, on page 26 when referring to your Scientifics Advisory
Board, you state that it "consists of world class scientist."  For all statements throughout
the offering statement regarding industry leadership, please substantiate your claims or
remove such statements. In addition, where you disclose these statements, please briefly

 FirstName LastNameNaveen Krishnarao Kulkarni
 Comapany NameQuantumzyme Corp.
 April 18, 2024 Page 2
 FirstName LastName
Naveen Krishnarao Kulkarni
Quantumzyme Corp.
April 18, 2024
Page 2
describe how you will measure and compared against other companies.
3.We note the revised disclosure on page 21.  Please revise to identify your first product,
which you describe as "an enzyme engineered for use in pharmaceutical API production,"
where "API" is defined as active pharmaceutical ingredients.  On page 25, you state that
"the first developed biocatalyst is for Ibuprofen."  Clarify if that is your product, and if it
is your first product, please revise page 21 accordingly.
The Quantumzyme Solution, page 25
4.We note your response to our previous comments 2 and 3 and reissue the comments  It is
unclear where in the document you have described your current programs.  Please revise
the document to clarify how many programs you have underway.  For the phases
described on page 25, describe the current phase for each program.  Please explain how
you use the OZyme Workbench in relation to your product development and/or these
phases, to the extent you do.  It is unclear how these items relate to one another.  On page
21, where you state that your first product "has been validated in the lab and is ready for
commercial application and launch," please revise to clarify what you mean by
"validated." In addition, revise the last two sentences to identify the product, the type of
manufacturers, pharmaceuticals, distributors and enzymes and the relevant markets.
USA and Europe, page 27
5.We note your revised disclosure to our previous comment 6 relating to government
regulations applicable to the bioengineer enzymes industry. Please expand your disclosure
further to identify the governmental authorities and the laws and regulations relating to the
manufacture of your products or related, health and safety and environmental laws or
regulations that are material to your business, for example, in those countries where you
plan to operate or market your products.
Report of Independent Registered Public Accounting Firm, page 53
6.We note that the Public Company Accounting Oversight Board (“PCAOB”) has revoked
the registration of your auditor, Gries & Associates, LLC. You can find a copy of the
order on the PCAOB’s website at https://assets.pcaobus.org/pcaob-dev/docs/default-
source/enforcement/decisions/documents/105-2024-011-gries.pdf?sfvrsn=b9b25830_4.
As this auditor is no longer registered with the PCAOB, you may not include their audit
reports or consents that reference PCAOB standards in your filings with the Commission
on or after the date of deregistration. We also note that in Part I, Item 4 you checked the
box that this is a Tier 1 offering, and as permitted, you have included unaudited financial
statements. Furthermore, we note that on page 58 of the offering circular you referred to
the financial statements as unaudited in the heading to the notes of the July 31, 2023 and
2022 financial statements. Please revise your filing to remove the audit report from Gries
& Associates, LLC and label each of the primary financial statements as unaudited.

 FirstName LastNameNaveen Krishnarao Kulkarni
 Comapany NameQuantumzyme Corp.
 April 18, 2024 Page 3
 FirstName LastName
Naveen Krishnarao Kulkarni
Quantumzyme Corp.
April 18, 2024
Page 3
            Please contact Robert Augustin at 202-551-8483 or Abby Adams at 202-551-6902 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services

CORRESP
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     JONATHAN D. LEINWAND, P.A.

   18305 Biscayne Blvd.

  Suite 200

 Aventura, FL 33160

 Tel: (954) 903-7856

 Fax: (954) 252-4265

 E-mail: jonathan@jdlpa.com

 April 3, 2024

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Industrial Applications and Services

 100 F Street, N.E.

 Washington, DC 20549

     Attn:

   Robert Augustin,

   Abby Adams

   Re:

   Quantumzyme Corp.

   Offering Statement on Form 1-A

 Filed February 29, 2024

 File No. 024-12403

 Ladies and Gentlemen:

 We are submitting this letter on behalf of Quantumzyme Corp. (the “Company”) in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by electronic mail dated March 14, 2024, relating to the Company’s Offering Statement on Form 1-A (File No. 024-12403) filed with the Commission on February 29, 2024 (the “Offering Statement”). The numbered paragraphs below correspond to the numbered comments in the Staff’s letter and the Staff’s comments are presented in bold italics. Additionally, the Company has amended its Offering Statement to reflect and address Staff’s comments as necessary, the Company’s Amendment No. 1 to the Offering Statement (“Amendment No. 1”) is being filed concurrently herewith.

 Offering Statement on Form 1-A

 Cover Page

 1. Please revise your cover page to disclose the differences between the common stock being offered and your Series A and Series B preferred stock, including any disparate voting and dividend rights. Also disclose the number of shares outstanding of each series. We note your disclosure in Note 4 on page 33 regarding the voting rights and control of Mr. Kulkarni. Please also revise the cover page to disclose that Mr. Kulkarni controls the company, disclose his beneficial ownership percentages and the amount of voting power he will own following the completion of the offering. Also provide this disclosure in the offering circular summary and revise the risk factors to disclose the associated risks.

                  In response to the Staff’s comment, the Company has revised its disclosure on the cover page reflect the information concerning the Company’s disparate classes of shares, including voting right, dividends, etc. Additionally, we have added disclosure regarding voting and control of the Company, the enhanced disclosure includes an additional risk factor relating to the same.

 Description of Business

 The Quantumzyme Solution, page 24

 2. Please generally revise the business section to describe the business you engage in and the business you intend to engage in. Please be more specific in describing the products or services you offer or intend to offer, their stage of development, if there is a principal market you intend to target, and how your products would be distributed. Refer to Item 7(a)(1) of Form 1-A. For example, we note the discussion of QZyme Workbench. Please revise to clarify if you created this technology or license it from another source. Clarify how the technology relates to your business. If this is technology under development by you, please revise to disclose the stage of development and additional steps needed until it is ready to be commercialized. Please revise to clarify the core features of the technology depicted in the graphic on page 25. Please revise the text to the right of the graphic to clarify how it relates to your product and the significance of the bolded language. For example, clarify whether it is significant that the 3D model created by algorithms does not have exact structural information.

 In response to the Staff’s comment, the Company has revised its disclosure discussion to address and enhance our disclosure relating to our present a future business plans and our intended plan of operation.

 3. We note your discussion of your 5 step development plan. Please expand your disclosure to briefly describe what the program is and the different phases of the program so that an investor will understand the stage at which you are developing this technology.

 In response to the Staff’s comment, the Company has revised its expand to briefly describe the Company’s current programs and the different phases of each program we are in developing our technology.

 4. Please revise the discussion of your business to define or explain specialized terms at first use, including biotransformation, biocatalysis, and legacy reactions.

 In response to the Staff’s comment, the Company has revised its “definitions” disclosure to define and explain specialized terms.

 Our Technology, page 25

 5. We note that the company "seeks daily to understand the science involved in enzyme engineering which [you] will evolve and incorporate into [your] plan of operations," the references to current and future projects, and that, "[a]s a biotransformation company [you] will constantly focus and seek to implement [your] advances in the following selected areas to continually drive and advance the growth of Quantumzyme." Please substantially expand the discussion of the selected areas to address each of the categories identified describe your advances and how you intend to implement them. In doing so, clarify what expertise you have in "the science involved in enzyme engineering," and the current efforts to gain understanding in that area. Finally, clarify the current projects you reference here.

 In response to the Staff’s comment, the Company has revised its disclosure to expand on the discussion of the selected areas of anticipated growth and how we intend to implement the same and we have clarified our current projects.

 Government Regulation, page 26

 6. Please revise to clarify whether there are existing or anticipated government regulations affecting your business, and if so, describe the material regulations and their effects. Refer to Item 7(a)(2) of Form 1-A.

 In response to the Staff’s comment, the Company has revised its disclosure to clarify our understanding of the existing and anticipated government regulations that may affect our business.

 Should the Staff have additional questions or comments regarding the foregoing, please do not hesitate to contact the undersigned at 954-903-7856.

        Very Truly Yours,

    By:  /s/ Jonathan Leinwand, Esq.

   Jonathan Leinwand, Esq.

   Cc: Quantumzyme Corp.

  2

United States securities and exchange commission logo
March 14, 2024
Naveen Krishnarao Kulkarni
Chief Executive Officer and President
Quantumzyme Corp.
15656 Bernardo Center Drive
Suite 801
San Diego, CA 92127
Re:Quantumzyme Corp.
Offering Statement on Form 1-A
Filed February 29, 2024
File No. 024-12403
Dear Naveen Krishnarao Kulkarni:
            We have reviewed your offering statement and have the following comments.
            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.
Offering Statement on Form 1-A
Cover Page
1.Please revise your cover page to disclose the differences between the common stock being
offered and your Series A and Series B preferred stock, including any disparate voting and
dividend rights. Also disclose the number of shares outstanding of each series. We note
your disclosure in Note 4 on page 33 regarding the voting rights and control of
Mr. Kulkarni. Please also revise the cover page to disclose that Mr. Kulkarni controls the
company, disclose his beneficial ownership percentages and the amount of voting power
he will own following the completion of the offering. Also provide this disclosure in the
offering circular summary and revise the risk factors to disclose the associated risks.

 FirstName LastNameNaveen Krishnarao Kulkarni
 Comapany NameQuantumzyme Corp.
 March 14, 2024 Page 2
 FirstName LastName
Naveen Krishnarao Kulkarni
Quantumzyme Corp.
March 14, 2024
Page 2
Description of Business
The Quantumzyme Solution, page 24
2.Please generally revise the business section to describe the business you engage in and the
business you intend to engage in.  Please be more specific in describing the products or
services you offer or intend to offer, their stage of development, if there is a principal
market you intend to target, and how your products would be distributed.  Refer to Item
7(a)(1) of Form 1-A. For example, we note the discussion of QZyme Workbench. Please
revise to clarify if you created this technology or license it from another source.
Clarify how the technology relates to your business. If this is technology under
development by you, please revise to disclose the stage of development and additional
steps needed until it is ready to be commercialized.  Please revise to clarify the core
features of the technology depicted in the graphic on page 25. Please revise the text to the
right of the graphic to clarify how it relates to your product and the significance of the
bolded language. For example, clarify whether it is significant that the 3D model created
by algorithms does not have exact structural information.
3.We note your discussion of your 5 step development plan. Please expand your disclosure
to briefly describe what the program is and the different phases of the program so that an
investor will understand the stage at which you are developing this technology.
4.Please revise the discussion of your business to define or explain specialized terms at first
use, including biotransformation, biocatalysis, and legacy reactions.
Our Technology, page 25
5.We note that the company "seeks daily to understand the science involved in enzyme
engineering which [you] will evolve and incorporate into [your] plan of operations," the
references to current and future projects, and that, "[a]s a biotransformation company
[you] will constantly focus and seek to implement [your] advances in the following
selected areas to continually drive and advance the growth of Quantumzyme." Please
substantially expand the discussion of the selected areas to address each of the categories
identified, describe your advances and how you intend to implement them.  In doing so,
clarify what expertise you have in "the science involved in enzyme engineering," and the
current efforts to gain understanding in that area.  Finally, clarify the current projects you
reference here.
Government Regulation, page 26
6.Please revise to clarify whether there are existing or anticipated government regulations
affecting your business, and if so, describe the material regulations and their effects. Refer
to Item 7(a)(2) of Form 1-A.

 FirstName LastNameNaveen Krishnarao Kulkarni
 Comapany NameQuantumzyme Corp.
 March 14, 2024 Page 3
 FirstName LastName
Naveen Krishnarao Kulkarni
Quantumzyme Corp.
March 14, 2024
Page 3
            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 Robert Augustin at 202-551-8483 or Abby Adams at 202-551-6902 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services

CORRESP
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RELIANT SERVICE INC

3 Rabí, Rabí, Czech Republic 34201

(775)996-0287

servicesreliant@gmail.com

October 4, 2016

Ms. Jennifer Lopez

United States Securities and Exchange Commission

Washington D.C. 20549-4631

 Re: Reliant Service Inc.

 Amendment No. 7 to Registration Statement on Form S-1

Filed September 28, 2016

File No. 333-208934

Dear Ms. Lopez,

This letter shall serve as the request of Reliant Service Inc., pursuant to Rule 461, to accelerate the effectiveness of the above-referenced Registration Statement to Thursday, October 6, 2016, 4:30PM EST, or the soonest practicable date thereafter.

The company acknowledges that:

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

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

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

Sincerely,

/s/ Stanislav Augustin

Stanislav Augustin

President & Director

Mail Stop 3561

September 1 6, 2016

Stanislav Augustin
President and Chief Executive Officer
Reliant Service Inc.
3 Rabí
Rabi, Czech Republic 34201

Re: Reliant Service Inc.
 Amendment No. 6  to Registration Statement on Form S-1
 Filed  September 2 , 2016
 File No.  333-208934

Dear Mr. Augustin :

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 no t 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.

Prospectus Summar y

Our Company, page 5

1. Reference is made to the tenth paragraph on page 6.  Please revise to disclose that the net
gain from inception on March 20, 2015 through July 31, 2016 was $6,201 rather than
$3,201.

Summary Financial Information, page 7

2. The summary financial information as of and for the year ended July 31, 2016 is labeled
“(Unaudited)” and the summary financial information as of and for the year ended July
31, 2015 is labeled “(Audited).”  The first paragraph under the “Summary Financial
Information” subheading states that all this financial information was derived from your

Stanislav Augustin
Reliant Service Inc.
September 1 6, 2016
Page 2

 audited financial statements.  As such, please remove the labels of “(Unaudited)” and
“(Audited).”

3. The “Total Liabilities &  Stockholder’s Equity” as of July 31, 2015 line item does not
agree to the financial statements.  Please revise to present the correct amount.

Financial Statements, page 34

4. Please revise to present the audited July 31, 2015 and 2016 financial statement s in a
comparative format rather than as two separate sets of financial statements.

Statement of Changes in Stockholders’ Equity, page 50

5. The “Beginning Balance” line item presented is net profit accumulated through July 31,
2015 and the “Common Stock” line item does not represent activity in the period
beginning August 1, 2015 and ending July 31, 2016.  Please revise to present a Statement
of Changes in Stockholders’ Equity from August 1, 2015 through July 31, 201 6.

You may contact Adam Phippen, Staff  Accountant, at (202) 551 -3336,  or James
Allegretto, Senior Assistant Chief Accountant, at (202) 551 -3849, if you have questions
regarding comments on the financial statements and related matters .  Please contact Scott
Anderegg , Attorney -Advisor, at (202) 551-3342, or Lisa Kohl, Legal Branch Chief, at (202) 551 -
3252 or me at (202) 551 -3720 with any other questions.

Sincerely,

 /s/ Lisa M. Kohl for

Mara Ransom
Assistant Director
Consumer Products

Mail Stop 3561

August 5, 2016

Stanislav Augustin
President and Chief Executive Officer
Reliant Service Inc.
3 Rabí
Rabi, Czech Republic 34201

Re: Reliant Service Inc.
 Amendment No. 5  to Registration Statement on Form S-1
 Filed  July 26 , 2016
 File No.  333-208934

Dear Mr. Augustin :

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 ame ndment 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.

General

1. Please update the disclosure regarding the beneficial ownership  of your com mon
stock and the number of record holders  of your securities as of a recent practicable
date.  Please refer to I tems 403(a) and 201(b) of Regulation S -K.  In this regard,
certain disclosures in your  registra tion statement, including  stock ownership , are as of
January 2016 .  Throughout the course of the review , please continue to update this
information to provide current information as of the most recent date practicable.

Executive Compensation, page 30

2. Please update your executive compensation disclosure to include your recently
completed fiscal year .  Please refer to Item 402 of Regulation S -K and Regulation S -
K Compliance and Disclosure Interpretation 117. 05

Stanislav Augustin
Reliant Service Inc.
August 5, 2016
Page 2

 Report of Independent Registered Public Accounting Firm, page 34

3. We reviewed the revisions to the explanatory paragraph in response to comment 1.
The first sentence in the explanatory paragraph is unclear and appears incomplete.
Please review the disclosure illustrated in paragraph .13 of PCAOB Auditing
Standard 2415 and revise to provide substantially similar disclosure.

4. Reference is made to the last sentence in the last paragraph which states, “Our
opinion is unmodified for this matter.”  Please remove this sentence from the audit
report or explain in detail why i t should be included.

Statement of Operations, page 36

5. We reviewed the response to comment 2.  You refer to an “income tax payable
amount of 35%.”  However, income tax payable and your provision for income taxes
is not 35% of income before taxes.  Plea se explain the difference.

Notes to Financial Statements  from March 20, 2015 (Inception) through July 31, 2015, page 39

6. The disclosures added in response to comment 3 do not satisfy the disclosure
requirements at ASC 740 -10-50.  As such, the comment i s repeated in the following
paragraph.

Please revise to add a separate note for income taxes to include the applicable
disclosures prescribed by ASC 740 -10-50.

Unaudited Financial Statements

7. Please update the financial statements and financial informa tion included in the filing
to include interim periods ended April 30, 2016 and April 30, 2015.  Refer to Rule 8 -
08 of Regulation S -X.

Notes to Financial Statements for the Six Months Ended January 31, 2016

Note 2 – Summary of Significant Accounting Po licies

Advertising, page 50

8. We reviewed the response to comment 5.  On page 50 you continue to disclose that
advertising expense for the year ended July 31, 2015 was $12,510.  Please revise to
remove this disclosure.

Stanislav Augustin
Reliant Service Inc.
August 5, 2016
Page 3

 You may contact Adam Phippen, Staff Accountant, at (202) 551 -3336 or James
Allegretto, Senior Assistant Chief Accountant, at (20 2) 551 -3849 if you have questions regarding
comments on the financial statements and related matters.  Plea se contact Scott Ande regg,
Attorney -Advisor, at (202) 551 -3342 or Lisa Kohl, Legal Bra nch Chief, at (202) 551 -3252 or me
at (202) 551 -3720 with any other questions.

Sincerely,

 /s/ Lisa M. Kohl for

Mara Ransom
Assistant Director
Consumer Products

Mail Stop 3561

June 2, 2016

Stanislav Augustin
President and Chief Executive Officer
Reliant Service Inc.
3 Rabí
Rabi, Czech Republic 34201

Re: Reliant Service Inc.
 Amendment No. 4 to Registration Statement on Form S-1
 Filed  May 20, 2016
 File No.  333-208934

Dear Mr. Augustin :

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 bel ieve 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.

Financial Statements

Audited Financial Statements

Report of Independent Registered Public Accounting Firm, page F -2

1. We reviewed the explanatory paragraph added in response to comment 7.  Please tell us
if, after considering identified conditions and ev ents and management's plans, your
auditor concluded  that there was substantial doubt about your  ability to continue as a
going concern for a reasonable period of time .  If so,  the auditor's conclusion about your
ability to continue as a going concern should be expressed through  the use of the phrase
“substantial doubt about Reliant Service, Inc. ’s abil ity to continue as a going concern” or
similar wording that includes the terms substantial doubt and  going concern  as illustrated

Stanislav Augustin
Reliant Service Inc.
June 2 , 2016
Page 2

 in paragraph .13 of PCAOB Auditing Standard 2415.  Refer to paragraph .12 of PCAOB
Auditing Standard 2415.

Statement of Operations, page F -4

2. We reviewed the revisions made in response to comment 8.  Please tell us why restating
your financial statements to recognize income tax expense was appropriate referencing
authoritative literature that supports your accounting treatment.  Please also tell  us your
tax year and explain to us why no income tax benefit was recognized for the six months
ended January 31, 2016 referencing authoritative literature that supports your accounting
treatment.

Further, since your financial statements were restated to recognize income tax expense,
please revise to clearly label the financial statements as restated.  Please also r evise your
footnotes to disclose that your previously issued financial statements have been restated
along with  a narrative description of t he nature of each of th e errors .  For each financial
statement line item affected by the restatements, please reconcile in table format between
the previously reported and restated amounts.   Refer to ASC 250 -10-50-7.  In addition,
your auditor should refer  to the restatements and the related footnote disclosure  in the
audit report and date the report accordingly.

Notes to Financial Statements  from March 20, 2015 (Inception) through July 31, 2015, page F -7

3. Please revise to add a separate note for income taxes to include the applicable disclosures
prescribed by ASC 740 -10-50.

Unaudited Financial Statements

4. We note that the compilation report was removed in response to comment 11.  As we
previously stated, the presence of a compilation report may indica te a violation of SEC
independence standards prohibiting bookkeeping and other services related to the
accounting records for financial statements of an the audit client.  Please tell us whether
your auditor provided compilation services.  If not, explain why the complication report
was originally filed and why an auditor would issue a report if no such services were
provided.  If so, tell us why the compilation services provided by your auditor are not a
violation of Rule2 -01(c)(4)(i)(B) of Regulation S -X.  Please note that if your accountant
is not independent, a new auditor would need to be engaged to re -audit all previous
periods.   Please ensure your response indicates the extent to which your auditor was
involved in the preparation of the July 31, 2015 financial statements.

Stanislav Augustin
Reliant Service Inc.
June 2 , 2016
Page 3

 Notes to Financial Statements for the Six Months Ended January 31, 2016

Note 2 – Summary of Significant Accounting Policies

Advertising, page F -18

5. Your disclosure of advertising expense for the year ended July 31, 2015 of $12,510 does
not agree to the amount disclosed on page F -8.  Please revise to remove your disclosure
of advertising expense for the year ended July 31, 2015 and disclose your advertising
expense for the six months ended January 31, 2016.

You may contact Adam Phippen, Staff Accountant, at (202) 551 -3336,  or James
Allegretto, Senior Assistant Chief Accountant, at (202) 551 -3849, if you have questions
regarding comments on the financial statements and related matters.   Please contact Scott
Anderegg , Attorney -Advisor, at (202) 551 -3342, or Lisa Kohl, Legal Branch Chief, at (202) 551 -
3252  or me at (202) 551 -3264 with any other questions.

Sincerely,

 /s/ Lisa M. Kohl for

Mara Ransom
Assistant Director
Consumer Products

Mail Stop 3561

April 8, 2016

Stanislav Augustin
President and Chief Executive Officer
Reliant Service Inc.
3 Rabí
Rabi, Czech Republic 34201

Re: Reliant Service Inc.
 Amendment No. 3  to Registration Statement on Form S-1
 Filed  March 24, 2016
 File No.  333-208934

Dear Mr. Augustin :

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 bel ieve 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.

Prospectus Summary

Our Company, page 5

1. Please augment your disclosure here and in your Management’s Discussion and Analysis
of Financial Condition and Results of Operations to briefly describe the allocation of
your proceeds to your U.S. operations and your Czech operations.  Please indicate
whether you plan to focus on your expansion in the U.S. market, or if you plan to also
expand your Czech operations.

Stanislav Augustin
Reliant Service Inc.
April 8 , 2016
Page 2

 Summary Financial Information, page 7

2. We reviewed the revisions made in response to comment 4.  Certain amounts in the tables
still do not agree to the financial statements.  We also noted similar inconsistencies with
amounts on pages 9, 20 and 26.  Please revise amounts throughout the filing to match the
financial statements.

Dilution, page 16

3. We reviewed the revisions made in response to comment 8.  In the fourth full paragraph
you disclose net tangible book value of $7,624 as of January 31, 2016.  We are unable to
reconcile this amount t o the balance sheet on page F -14.  Please show us how the amount
reconciles to the balance sheet on page F -14 or revise the amount disclosed and show us
how the revised amount reconciles to the balance sheet.

Description of Business, page 20

4. Please dis close that you purchase your file cabinets from China.  Please disclose whether
the file cabinets are shipped directly to your customers or to you, and who is responsible
for applicable shipping costs.  Please also disclose the process you must follow in o rder
to import goods into the Czech Republic , if applicable.

5. We note your statement that Mr. Augustin “will start drawing a small salary ($1,000 per
month).”  However, your disclosure on page 10 states Mr. Augustin “will receive a one -
time salary of $5,000 for the first  12 months of operation.”  Please revise.

Plan of Operation, page 25

6. Please update your disclosure to include your cash balance as of January 31, 2016.

Financial Statements

Audited Financial Statements

Report of Independent Registered Public Accounting Firm, page F -2

7. We reviewed the revisions made in response to comment 18.  Please have your auditor
explain to us their consideration of your ability to continue as a going concern.  Please
also have your auditor tell us their consideration of including an  explanatory paragraph
stating there is substantial doubt about your ability to continue as a going concern.  Refer
to PCAOB Auditing Standards 2415 and 3101.11.

Stanislav Augustin
Reliant Service Inc.
April 8 , 2016
Page 3

 Statement of Operations, page F -4

8. Your response to comment 19 states that a provision for i ncome tax is included in the
statement of operations; however, the statement of operations still does not appear to
reflect any income tax expense.  Please tell us why no income tax expense was
recognized referencing authoritative literature that supports your accounting treatment.

Notes to Financial Statements, page F -7

9. We reviewed the revisions made in response to comment 22.  As previously requested,
please also disclose long -lived assets in your country of domicile and located in all
foreign countrie s in total in which you hold assets.  If assets in an individual foreign
country are material, those assets shall be disclosed separately.  Refer to ASC 280 -10-50-
41.

Schedule of Operating Expenses, page F -11

10. Your response to comment 23 does not provid e the explanation requested.  As such, we
have repeated the same comment in the next paragraph.

Please tell us your consideration of removing the schedules of operating expenses and
separately disclosing depreciation expense and advertising expense in t he notes to the
financial statements pursuant to ASC 360 -10-50-1a and ASC 720 -35-50-1b.

Independent Accountant’s Compilation Report, page F -13

11. Compilation reports are not appropriate in public company filings because the association
of the accountant provides no basis for reliance.  Please remove the compilation report.
In addition, the presence of a compilation report may indicate a violation of SEC
independence standards prohibiting bookkeeping and other services related to the
accounting records of  financial statements of an the audit client.  Please tell us why the
compilation service provided by your auditor is not a violation of Rule  2-01(c)(4)(i)(B) of
Regulation S -X.  Please note that if your accountant is not independent, a new auditor
would n eed to be engaged to re -audit all previous periods.   Please ensure your response
indicates the extent to which your auditor was involved in the preparation of the July 31,
2015 financial statements.

Stanislav Augustin
Reliant Service Inc.
April 8 , 2016
Page 4

 You may contact Adam Phippen, Staff Accountant, at  (202) 551 -3336,  or James
Allegretto, Senior Assistant Chief Accountant, at (202) 551 -3849, if you have questions
regarding comments on the financial statements and related matters .  Please contact Scott
Anderegg , Attorney -Advisor, at (202) 551 -3342, or Li sa Kohl, Legal Branch Chief, at (202) 551 -
3252  or me at (202) 551 -3264 with any other questions.

Sincerely,

 /s/ Lisa M. Kohl

Mara Ransom
Assistant Director
Consumer Products

Mail Stop 3561

February 25, 2016

Stanislav Augustin
President and Chief Executive Officer
Reliant Service Inc.
3 Rabí
Rabi, Czech Republic 34201

Re: Reliant Service Inc.
 Amendment No. 2 to Registration Statement on Form S-1
 Filed  February 5, 2016
 File No.  333-208934

Dear Mr. Augustin :

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 no t 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.

General

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

Prospectus Cover Page

2. Please revise your disclosure to clarify that because there is no minimum to your
offering, if you fail to raise enough capital to commence operations, investors could lose
their entire investment and will not be entitled to a refund.  Additionally,  disclose the
minimum number of shares needed to generate sufficient proceeds to enable you to
implement your business plan within the next twelve months.

Stanislav Augustin
Reliant Service Inc.
February  25, 2016
Page 2

 Our Company, page 5

3. Your disclosure in regard to your plan of operation in the United States and the Czech
Republic is unclear.  Please revise here and in Management’s Discussion and Analysis of
Financial Condition and Results of Operations to clarify what your plans are in the
United States and Czech Republic and the expected allocation of offering proceeds to
each.

Summary Financial Information, page 7

4. Certain amounts in the tables do not agree to the financial statements.  We noted similar
inconsistencies with amounts and report dates on pages 8, 19, and 25.  Please revise
amounts and report dates throughout the filing to match the financial statements and audit
report date.

Risk Factors, page 8

5. Please  provide a risk factor pertaining to the difficulty U.S. stockholders would face
enforcing judgments against you obtained in U.S. courts or bringing  an original  action
against you in foreign courts.   In this regard, we note that all your assets and operations
are in the Czech Republic.
6. We note  that you have a non -U.S. resident as your sole officer and director.  Please
include a state ment concerning the enforceability of civil liabilities against  foreign
persons.

7. It appears that your assets, including your cash and cash equivalents , are held in the
Czech Republic.   Please tell us what consideration you gave to including a risk factor
regarding the effect this could have in your company’s liquidity.

Dilution, page 15

8. In the fourth full paragraph you disclose net tangible book value of $15,844 as of October
31, 2015.  However, the balance sheet on page F -12 presents a net tangible book v alue of
$13,518.  Please revise the amount disclosed in the fourth full paragraph or advise.

9. Reference is made to the first table which presents a “ [p]otential gain to existing
shareholder net of offering expenses ($8,511)” of $85,152.  Please tell us how you
computed this amount and why it represents a potential gain to the existing shareholder.

Terms of the Offering, page 17

10. Please state here, as you do in the prospectus cover page , that the offer may be extended
at the discretion of the Board of Directors.

Stanislav Augustin
Reliant Service Inc.
February  25, 2016
Page 3

 Description of Business, page 19

11. Please revise this section to clarify and better describe how your sole officer and director
will manage operations in the U. S.  In this regard, we note that your current operations
are in the Czech Republic and that your sole officer and director only devote s
approximately 20 hours per week to your business.  The d escriptions of your planned
business activities  in the U.S.  should  be accompanied by a discussion of how you will
achieve your plans in enough detail so that investors can evaluate your business plan.

Services Description, page 20

12. Please discuss how you sold your merchandise to your first customer.  In this regard,
your disclosure appears to indicate that your produ cts will be displayed and sold on your
website, which has not been developed.

13. Please discuss  any agreements with suppliers and expand your discussion of the proposed
distribution methods for your products.  See Item 101(h)(4)(i i) and (v) of  Regulation S -K

Government Regulation, page 22

14. As all y our operations and assets are presently in the Czech Republic, please further
discuss the government regulations in the Czech Republic that impact your operations.

Management’s Discussion and Analysis

Liquidity and Capital Resources, page 26

15. We note that you  have a verbal agreement with your sole officer and director for a loan.
Please file a wri tten description of the agreement .  Refer to Ite m 601(b)(10) of Regulation
S-K and Question 146.04 in the Regulation S -K section of our Compliance and
Disclosu re Interpretations.

Financial Statements

Audited Financial Statements

Report of Independent Registered Public Accounting Firm, page F -2

16. Please revise the first sentence of the first paragraph to refer to the balance sheet  as of
July 31, 2015 rather tha n the “financial statements” as of July 31, 2015.  Please also
revise paragraph three to refer the financial position as of  July 31, 2015 rather than “for
the year ended” July 31, 2015.  Refer to PCAOB Auditing Standard 3101.08.

17. Please tell us why it is a ppropriate to include the last two paragraphs of the report.  Please
also reconsider the need for these paragraphs in your next amendment in light of the

Stanislav Augustin
Reliant Service Inc.
February  25, 2016
Page 4

 comment below regarding the schedule of operating expenses.  In addition, we note the
reference to cas h basis financial statements in the fourth paragraph.  As noted in our letter
dated January 19, 2016, Rule 4 -01(a)(1) of Regulation S -X requires financial statements
to be prepared in accordance with generally accepted accounting principles (GAAP).
GAAP r equires financial statements to be prepared using accrual basis accounting as
opposed to cash basis accounting.

18. Reference is made to the sixth paragraph on page 5 which states that the audit report
includes a statement expressing substantial doubt as to your ability to continue as a going
concern.  No such language is included in the audit report.  Further, we note the going
concern disclosure in Note 3 on page F -8.  Please have your auditor explain to us their
consideration of your ability to continue as  a going concern and their consideration of
including an explanatory paragraph to reflect their conclusion.  Refer to PCAOB
Auditing Standards 2415 and 3101.11.

Statement of Operations, page F -4

19. Please tell us why no income tax expense was recognized re ferencing authoritative
literature that supports your accounting treatment.

20. Please present basic per share amounts for net income (loss) on the face of your audited
and unaudited statements of operations.  Refer to ASC 260 -10-45-2.

Notes to Financial Statements, page F -7

21. Please tell us your functional currency(ies) and support this determination referencing
authoritative literature.  Refer to ASC 830 -10-45.  Please also explain how applying the
guidance in ASC 830 impacted your financial statements.  In doing so, tell us the
currency of your “Cash in Bank” asset.  Please also consider adding disclosure in the
notes to the financial statements regarding your application of ASC 830.

22. Please disclose revenues  attributed to your country of domicile and att ributed to all
foreign countries in total from which you derive revenues.  If revenues attributed to an
individual foreign country are material, those revenues shall be disclosed separately.
Please also disclose long -lived assets in your country of domici le and located in all
foreign countries in total in which you hold assets.  If assets in an individual foreign
country are material, those assets shall be disclosed separately.  Refer to ASC 280 -10-50-
41.

Schedule of Operating Expenses, page F -11

23. Please tell us your consideration of removing the schedules of operating expenses and
separately disclosing depreciation expense and advertising expense in the notes to the
financial statements pursuant to ASC 360 -10-50-1a and ASC 720 -35-50-1b.

Stanislav Augustin
Reliant Service Inc.
February  25, 2016
Page 5

 Exhibit 23. 2

24. The consent refers to a report on cash basis financial statements which is not included in
this registration statement.  As noted in our letter dated January 19, 2016, Rule 4 -01(a)(1)
of Regulation S -X requires financial statements to be prepared in acc ordance with
generally accepted accounting principles (GAAP).  GAAP requires financial statements
to be prepared using accrual basis accounting as opposed to cash basis accounting.
Please file a new consent with your next amendment which refers to the rep ort included
in the amendment.

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.

Notwithstanding our comments, in the event  you request acceleration of the effective date
of the pending regist ration statement, please provide  a written statement from the company
acknowledging that:

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

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

 the company may not assert staff comments and the declaration of effect iveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for accele ration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate  to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Stanislav Augustin
Reliant Service Inc.
February  25, 2016
Page 6

 You may contact Adam Phip pen, Staff Accountant, at (202) 551 -3336,  or James
Allegretto, Senior Assistant Chief Accountant, at (202) 551 -3849, if you have questions
regarding comments on the financial statements and related matters.   Please contact Scott
Anderegg , Attorney -Advisor,  at (202) 551 -3342, or Jennifer L ópez-Molina, Attorney -Advisor, at
(202) 551 -3792 or me at (202) 551 -3264 with any other questions.

Sincerely,

 /s/ Jennifer L ópez for

Mara Ransom
Assistant Director
Office of Consumer Products

Mail Stop 3561
January 19 , 2016

Stanislav Augustin
President and Chief Executive Officer
Reliant Service Inc.
3 Rabí
Rabi, Czech Republic 34201

Re: Reliant Service Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed  January 19 , 2016
 File No.  333-208934

Dear Mr. Augustin :

Our preliminary review of your registration statement indicates that it fails in numerous
material respects to comply with the requirements of the Securities Act of 1933, the rules and
regulations under that Act, and the requirements of the form.  In this regard, we note that your
auditor’s report indicates the financial statements have been prepared in accordance with the
cash basis of accounting.   Please note that Rule 4 -01(a)(1) of Regulation S -X requires financial
statements to be prepared in accordance with  generally accepted accounting principles
(GAAP).   GAAP requires financial statements to be prepared using accrual basis accounting as
opposed to the cash basis accounting.  We will not perform a detailed examination of the
registration statement and we wi ll not issue comments.  We suggest that you consider filing a
substantive amendment to correct the deficiencies.

If you were to request acceleration of the effective date of the registration statement in its
present form, we would likely recommend that  the Commission deny your request.

If you have any questions, please contact Scott Anderegg , Staff A ttorney , at (202) 551 -
3342, Jennifer López, Staff A ttorney,  at (202) 551 -3792 or me at (202) 551 -3720.

Sincerely,

 /s/ Jennifer López for

Mara Ransom
Assistant Director
Office of Consumer Products

Mail Stop 3561
January 1 3, 2016

Stanislav Augustin
Chief Executive Officer
Reliant Service Inc.
3 Rabí
Rabi, Czech Republic 34201

Re: Reliant Service Inc.
 Registration Statement on Form S-1
 Filed  January 11, 2016
 File No.  333-208934

Dear Mr. Augustin :

Our preliminary review of your registration statement indicates that it fails in numerous
material respects to comply with the requirements of the Securities Act of 1933, the rules and
regulations under that Act, and the requirements of the form.  For example, we note your failure to
file an  audit report  as required by Form S -1 and Regulation S -X.  We will not perform a detailed
examination of th e registration statement and we will not issue comments.  We suggest that you
consider filing a substantive amendment to correct the deficiencies.

If you were to request acceleration of the effective date of the registration statement in its
present fo rm, we would likely recommend that the Commission deny your request.

If you have any questions, please contact Scott Anderegg , Staff Attorney , at (202) 551 -
3342, Jennifer López, Staff Attorney , at (202) 551 -3792 or me at (202) 551 -3720.

Sincerely,

 /s/ Jennifer López for

Mara Ransom
Assistant  Director
Office of Consumer Products