United States securities and exchange commission logo





                            February 26, 2021

       John McKowen
       Chief Executive Officer
       VetaNova Inc.
       335 A Josephine St.
       Denver, CO 80206

                                                        Re: VetaNova Inc.
                                                            Registration
Statement on Form 10-12G
                                                            Filed February 1,
2021
                                                            File No. 000-51068

       Dear Mr. McKowen:

              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 and any amendment you may file in
response to these
       comments, we may have additional comments.

       Registration Statement on Form 10-12G

       Item 1. Business, page 4

   1.                                                   We note your disclosure
on page F-15 that you did not maintain your own bank
                                                        account during the
years ended December 31, 2018 and 2019 and the nine months ended
                                                        September 30, 2020, and
that "[m]anagement plans to open a separate account for [you];
                                                        however, stringent
banking laws are making even a hemp-only-based business difficult to
                                                        open." To the extent
you engage or intend to engage in any hemp-based business, please
                                                        revise your business
description to discuss such operations.
       Item 1A. Risk Factors.
       Risks Relating to our Business, page 5

   2.                                                   In light of the recent
coronavirus (COVID-19) pandemic, please include risk factor
                                                        disclosure related to
the potential impact of COVID-19 to your business. For guidance,
 John McKowen
FirstName LastNameJohn McKowen
VetaNova Inc.
Comapany26,
February  NameVetaNova
            2021       Inc.
February
Page 2 26, 2021 Page 2
FirstName LastName
         consider the Division of Corporation Finance's Disclosure Guidance
Topics Nos. 9 & 9A,
         available on our website.
Risks Relating to Our Common Stock, page 5

3.       We note your CEO, John McKowen, holds 48% of your outstanding shares
of common
         stock. We further note that Mr. McKowen is also the CEO and director
of VitaNova
         Partners, LLC, a related party who separately holds 30% of your
outstanding shares.
         Please include a risk factor addressing Mr. McKowen's voting control
over the company
         and related conflicts of interest.
Our common stock trades on the OTC Bulletin Board, which may make it more
difficult for you
to resell shares, page 6

4.       Please revise this risk factor as it appears that your common stock is
quoted only on the
         OTC Pink marketplace. In this regard, we note your disclosure on pages
4 and 9.
Item 2. Financial Information, page 7

5.       Revise your disclosure to provide Management   s Discussion and
Analysis of Financial
         Condition and Results of Operations. Refer to Rule 303 of Regulation
S-K.
Item 4. Security Ownership of Certain Beneficial Owners and Management, page 7

6.       Your disclosure indicates that VitaNova Partners LLC owns 56,052,837
shares of your
         common stock, which represents 30% of your common stock based on
186,991,576 shares
         outstanding as of January 15, 2021. Please revise your security
ownership table to include
         VitaNova Partners LLC's holdings and to disclose the natural persons
or persons who
         directly or indirectly exercise sole or shared voting or investment
control over these
         shares. Refer to Item 403 of Regulation S-K and Exchange Act Rule
13d-3.
Item 5. Directors and Executive Officers., page 8

7.       Please expand Ms. Lowe's biographical information to include her
business experience
         and principal occupations and employment during the past five years.
See Item 401(e) of
         Regulation S-K.
Item 6. Executive and Director Compensation, page 8

8.       Please revise your disclosure to provide executive compensation
information for your
         most recent completed fiscal year. Refer to Item 402 of Regulation
S-K.
Item 10. Recent Sales of Unregistered Securities, page 10

9.       Please revise your disclosure to provide the dates of sale of the
securities and the
         applicable exemptions from registration. In addition, please name the
purchasers or
         identify the class of persons to whom the 35,109,194 shares and
warrants were sold.
         Refer to Item 701 of Regulation S-K
 John McKowen
FirstName LastNameJohn McKowen
VetaNova Inc.
Comapany26,
February  NameVetaNova
            2021       Inc.
February
Page 3 26, 2021 Page 3
FirstName LastName
Financial Statements
General, page F-1

10.      Please update your financial statements in accordance with Rule
3-12(d) of Regulation S-
         X. Please note that as an Emerging Growth Company that is not a
Smaller Reporting
         Company you are required to include audited financial statements for
your three most
         recent fiscal years. If you qualify and intend to report as a Smaller
Reporting Company,
         please check the box on the cover page of the Form 10 so indicating.
In that case, update
         your financial statements in accordance with Rule 8-08(b) of
Regulation S-X and include
         audited financial statements for at least your two most recent fiscal
years.
Condensed Balance Sheets
Trust account funds, page F-11

11.      We note your disclosure in Note 2, under the caption    Trust account
funds   , on page F-15
         that during the years ended December 31, 2018 and 2019 and the nine
months ended
         September 30, 2020 you did not maintain your own bank account, that
bank transactions
         were entered into through an account owned and operated by VitaNova
Partners,
         and therefore your cash is labeled as trust account funds. Please tell
us, and revise your
         disclosures to clarify, whether all amounts labeled as Trust account
funds are held in a
         Trust account for your benefit with VitaNova Partners serving as
Trustee, or not. If not, it
         appears you should revise the label to a more accurate caption,
possibly Due from Related
         Party, to avoid the implication that such amounts are held in a Trust
account. You should
         also revise your statements of cash flows to similarly reflect these
amounts in accordance
         with their nature, as appropriate.
Condensed Statement of Operations, page F-12

12.      You disclose in Note 2 on page F-16 under the caption    Accounting
for leases    that you
         recognized revenue of $7,875 from the sublease at a monthly rate of
$2,750 of farmland
         leased by you. Based on your disclosure in Note 5 on page F-10 your
cost to lease this
         property is $5,250 per month. Please revise your statement of
operations to reflect your
         lease cost associated with the portion of this property subleased to a
third party as a direct
         cost of the related lease revenue, or explain why you believe no
revision is necessary.
Statement of Changes in Stockholders    Equity, page F-14

13.      You disclose in Note 3 on page F-17 that you sold 16,168,485 units for
$0.01 per unit,
         each unit consisting of one share of your common stock and one warrant
to purchase a
         share of common stock to outside investors and raised $161,685. Please
revise your
         financial statements to allocate the total capital raised between the
warrants and the
         common stock with the warrants recognized at fair value and the common
stock
         recognized at the amount of proceeds not allocated to the warrants.
Refer to ASC 470-20-
         25-2. Additionally, tell us why you recorded incremental cash proceeds
of $14,644
         related to the warrants on your cash flow statement. In this regard,
your cash flow
 John McKowen
FirstName LastNameJohn McKowen
VetaNova Inc.
Comapany26,
February  NameVetaNova
            2021       Inc.
February
Page 4 26, 2021 Page 4
FirstName LastName
         statement reflects total unit proceeds of $176,329 which does not
agree with your footnote
         disclosure on page F-17.
Note 6     Subsequent Events, page F-17

14.      In various places in your filing, you appear to include inconsistent
disclosures related to
         stock issuances. For example, you disclose under this footnote that
you authorized the
         issuance of shares to VitaNova Partners LLC and to three individuals,
including certain
         executives, on December 3, 2020, totaling in the aggregate 151,695,392
of your common
         shares. However, disclosure under Note 7 on page F-10 appears to
indicate that
         124,483,121 of these common shares were issued on June 19, 2020.
Review and revise
         your disclosure throughout the filing to provide clear, complete and
consistent disclosure
         regarding the material terms of all stock issuances, including the
dates on which all shares
         were issued and the nature and amount of consideration received or to
be received.
15.      Disclosure in Note 6 on page F-17 indicates that two-thirds of the
shares issued to Mr.
         McKowen and Ms. Lowe are subject to clawback. However, disclosure
under Item 7 on
         pages 8 and 9 indicates that 50% of the shares issued to Mr. McKowen
and Ms. Lowe are
         subject to repurchase by VetaNova at a price of $0.0001 per share if
the    Warrant
         Performance Metric    is not satisfied and the other 50% of such
shares are subject to
         repurchase at such price if the    Secondary Performance Metric    is
not satisfied. Review
         and revise your disclosure throughout the filing to provide clear,
complete and consistent
         disclosure regarding the repurchase or clawback provisions applicable
to these shares.
Exhibits

16.      Please file the consulting agreement you entered into with VitaNova on
July 15, 2020
         for management services, including the amendments entered thereto on
each of September
         15, 2020 and December 15, 2020, and the agreements governing the
restricted shares
         issued to each of Mr. McKowen and Ms. Lowe that are subject to
repurchase if certain
         performance metrics are not satisfied.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Sondra Snyder, Staff Accountant, at 202-551-3332 or
Robert Babula,
Staff Accountant, at 202-551-3339 if you have questions regarding comments on
the financial
statements and related matters. Please contact Irene Barberena-Meissner, Staff
Attorney, at 202-
551-6548 or Karina Dorin, Staff Attorney, at 202-551-3763 with any other
questions.



                                                               Sincerely,
 John McKowen
VetaNova Inc.
February 26, 2021
FirstName
Page 5    LastNameJohn McKowen
Comapany NameVetaNova Inc.
                                 Division of Corporation Finance
February 26, 2021 Page 5         Office of Energy & Transportation
FirstName LastName