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                                June 1, 2021

       Scott D. Kaufman
       Chief Executive Officer
       Wizard Brands, Inc.
       2700 Homestead Road
       Park City, UT 84098

                                                        Re: Wizard Brands, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed May 19, 2021
                                                            File No. 333-255445

       Dear Mr. Kaufman:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our May
7, 2021 letter.

       Amendment No. 1 to Form S-1 filed May 19, 2021

       General

   1.                                                   We note your response
to our prior comment two, however we are unable to agree that
                                                        this is a resale
transaction. In addition to the size of the offering, it does not appear that
                                                        the investor is at
market risk with respect to its investment. In particular, we note your
                                                        additional disclosure
in the prospectus where you indicate the number of shares that you
                                                        would issue to the
investor at various market prices. Even at the floor price of $1.00, it
                                                        appears that the
investor will realize gross profit of $1.2 million. To the extent that you
                                                        continue to believe
that the investor is at market risk, please provide specific examples
                                                        showing the market risk
to the investor at various trading prices and how the value of the
                                                        securities currently
held by the investor may decrease, as you state in your response.
 Scott D. Kaufman
Wizard Brands, Inc.
June 1, 2021
Page 2
         Please note that are comment does not relate to the ability to
register the transaction as a
         PIPE transaction in accordance with Question 139.11 of the Securities
Act Sections
         Compliance and Disclosure Interpretations, but instead whether the
transaction is an
         indirect primary offering.

         In the alternative, please name the investor as an underwriter and
disclose the price at
         which it will sell the shares of common stock.
2.       We note your revised disclosure in response to our prior comment four.
Please remove
         the statements stating that you are "uniquely situated to enter the
NFT marketplace on a
         scale at which no other new market entrant in this space can achieve,"
that you are "very
         favorably-positioned to attract attention and market share," and that
the potential to realize
         impressive margins is manifest. Given the early-stage of the digital
products market and
         the uncertainty in this space, it does not appear appropriate to
predict your success in the
         market or to provide a guarantee of your financial success.
       You may contact Jacqueline Kaufman at 202-551-3797 or Erin Jaskot at
202-551-3442 at
with any questions.



FirstName LastNameScott D. Kaufman                              Sincerely,
Comapany NameWizard Brands, Inc.
                                                                Division of
Corporation Finance
June 1, 2021 Page 2                                             Office of Trade
& Services
FirstName LastName