May 30, 2019

Simon Westbrook
Chief Financial Officer
Kyto Technology & Life Science, Inc.
13050 La Paloma Road
Los Altos Hills, CA 94022

       Re: Kyto Technology & Life Science, Inc.
           Preliminary Proxy Statement on Schedule 14A
           Filed May 22, 2019
           File No. 000-50390

Dear Mr. Westbrook:

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

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

       After reviewing your response to these comments, we may have additional
comments.

Preliminary Proxy Statement on Schedule 14A

Proposal 6 -- Reincorporation Proposal, page 14

1.    We note that a vote by shareholders to approve the Reincorporation is
also a vote to
      approve the Delaware Certificate of Incorporation which will (i) contain
an exclusive
      forum provision, (ii) effect a decrease in your authorized common stock,
(iii) effect an
      increase in your authorized preferred stock and (iv) authorize the Board
of Directors to
      issue blank check preferred stock without shareholder approval. Please
tell us how you
      determined that a separate vote regarding these changes was not required.
Refer to
      Exchange Act Rule 14a-4(a)(3).
General

2.    We note that the twelfth provision of the Delaware Certificate of
Incorporation identifies
      the Court of Chancery of the State of Delaware as the exclusive forum for
certain
      litigation, including any "derivative action." Please disclose whether
this provision
 Simon Westbrook
Kyto Technology & Life Science, Inc.
May 30, 2019
Page 2
      applies to actions arising under the Securities Act or the Exchange Act.
In this regard, we
      note that Section 27 of the Exchange Act creates exclusive federal
jurisdiction over all
      suits brought to enforce any duty or liability created by the Exchange
Act or the rules and
      regulations thereunder, and Section 22 of the Securities Act creates
concurrent jurisdiction
      for federal and state courts over all suits brought to enforce any duty
or liability created by
      the Securities Act or the rules and regulations thereunder. If the
provision applies to
      Securities Act claims, please also revise your disclosure to state that
there is uncertainty as
      to whether a court would enforce such provision and that investors cannot
waive
      compliance with the federal securities laws and the rules and regulations
thereunder. If
      this provision does not apply to actions arising under the Securities Act
or Exchange Act,
      please also ensure that the exclusive forum provision in the governing
documents states
      this clearly, or tell us how you will ensure that investors will be
informed in future filings
      that the provision does not apply to any actions arising under the
Securities Act or
      Exchange Act.
        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 Ada D. Sarmento at 202-551-3798 or Erin Jaskot at
202-551-3442 with
any questions.



                                                             Sincerely,
FirstName LastNameSimon Westbrook
                                                             Division of
Corporation Finance
Comapany NameKyto Technology & Life Science, Inc.
                                                             Office of
Healthcare & Insurance
May 30, 2019 Page 2
cc:       Anthony Epps, Esq.
FirstName LastName