September 26, 2024

Frank Gomez
President
Neuralbase AI Ltd.
Calle 98 No.19 A - 79
AP 410 Localidad De Chapinero
Bogota CU 00000, Colombia

       Re: Neuralbase AI Ltd.
           Amendment No. 1 to Registration Statement on Form 10-12G
           Filed September 11, 2024
           File No. 000-33325
Dear Frank Gomez:

       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 Registration Statement on Form 10-12G Filed September 11,
2024
Item 1. Description of Business, page 4

1.     We note your amended disclosure in response to prior comment 2. Please
revise to state
       that you are a development stage company, with limited active business
operations, no
       revenues, and no assets. Additionally, we note that you have added the
"Anticipated
       Financing Plan," which describes your plans to raise $250,000. Please
revise to clearly
       state the amount needed to continue in business over the next 12 months.
2.     We note your response to prior comment 3 and we reissue it. Please
revise to clarify the
       current status of business operations, as your disclosure appears to
describe the intended
       functions of your platform, but not current operations. For example,
please disclose how
       many subscriptions or licenses you have sold to date, how many customers
and/or
       users are currently using your MultiDoc.ai platform, how you integrate
your product with
       cloud-based infrastructure (if any), and plans for further development
of the platform and
       future operation(s), etc. Please refer to the specific disclosures
required by Item 101(h) of
 September 26, 2024
Page 2

       Regulation S-K. To the extent you have any agreements with third
parties, please
       summarize the material terms of such agreements and file them as
exhibits. Refer to Item
       601(b)(10) of Regulation S-K.
3.     We note your revised disclosure in response to prior comment 4. Please
revise to remove
       the disclosure in the second sentence of the risk factor that states
that you rely on
       copyright, trademark, and patent laws, as your revised disclosure states
that you have not
       and likely will not rely on such protections. Also, revise further to
explain the risks to
       your business if your intellectual property is not protected.
Anticipated Financing Plan, page 5

4.     Please revise to clearly state, if true, that you have no current
ability to obtain financing to
       achieve this anticipated financing plan. Otherwise, please revise to
state how you intend
       to obtain financing.
How Multidoc.AI Works, page 8

5.     Please clarify whether the current Multidoc.ai platform uses any of the
eight
       techniques/tools listed in this section. The disclosure here appears to
be describing general
       AI functions, but does not necessarily speak to your current operations.
If any of these
       functions are in use, please revise to provide more specific details and
examples of each
       AI capability.
Employees, page 17

6.     Please revise to state the current number of total employees and number
of full-time
       employees. Refer to Item 101(h)(4)(xii).
Risk Factors, page 19

7.     Please revise to include a risk factor that addresses the security of
your customer's data,
       documents, proprietary information, etc. that is required to be uploaded
to the Multidoc.ai
       platform in order to receive AI assistance.
We are dependent on our management team, page 25

8.     We note your revised disclosure in response to prior comment 5 and we
reissue in part.
       Please revise to explain specifically why you are dependent on the CEO,
Frank Gomez,
       including his specific expertise and skills that you are reliant upon.
Liquidity and Capital Resources, page 28

9.     We note your response to prior comment 7, but do not see any responsive
revised
       disclosure. As such, we reissue the comment. Please clearly state how
long you can
       satisfy your cash requirements based upon cash on hand and revenues from
operations
       and explain whether you will have to raise additional funds in the next
twelve
       months. Please also include a reasonably detailed discussion of your
ability to continue in
       existence as a going concern and your ability or inability to generate
sufficient cash to
       support your operations during the next twelve months. Please refer to
Item 303(a)(1) of
       Regulation S-K.
 September 26, 2024
Page 3
Item 3. Properties, page 30

10.    We note your amended disclosure in response to comment 8. Please revise
to add
       disclosure that addresses specific risks related to operating in
Colombia, if any.
Item 7. Certain Relationships and Related Transactions, and Director
Independence, page 32

11.    We note your response to prior comment 10 and we reissue it. Please
revise to disclose
       the transaction between the company and Frank Gomez/Grupo FG SAS that
resulted in
       Frank Gomez becoming the President and Chief Executive Officer of the
company.
       Additionally, it appears that Fred Schiemann and Henry Manayan became
greater than
       5% shareholders of common stock based on transaction(s) with the
company. Please add
       such transactions to this disclosure as well. Please refer to Item
404(d) of Regulation S-K
       and Regulation S-K Compliance & Disclosure Interpretation 130.03.
Item 10. Recent Sales of Unregistered Securities, page 33

12.    We note your amended disclosure in response to prior comment 12. Please
revise to
       include the required disclosure for the common stock and Class B common
stock issued to
       Fred Schiemann and Health and Hope, LLC, respectively, and the common
stock issued
       to Henry Manayan.
Consolidated Statements of Cash Flows, page F-4

13.    Please ensure the net loss for the six months ended June 30, 2024 agrees
with the net loss
       for the same period reported in the statements of operations.
General

14.    We note your references to your senior management team and board of
directors. Please
       revise throughout to clarify, if true, that Frank Gomez is the sole
officer and director of
       the company at this time.

        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 Nasreen Mohammed at 202-551-3773 or Doug Jones at
202-551-3309 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Cara Wirth at 202-551-7127 or Dietrich King at 202-551-8071 with any
other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Trade &
Services