United States securities and exchange commission logo





                              January 25, 2021

       James Koh
       Chief Executive Officer and Chief Financial Officer
       BlueOne Card, Inc.
       4695 MacArthur Court Suite 1100
       Newport Beach, CA 92660

                                                        Re: BlueOne Card, Inc.
                                                            Registration
Statement on Form 10-12G
                                                            Filed December 29,
2020
                                                            File No. 000-56060

       Dear Mr. Koh:

              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.

       Form 10 Filed December 29, 2020

       Business, page 5

   1.                                                   Please revise
throughout to make sure it is clear to the investor that your sole business is
                                                        your intent to act as a
reseller of prepaid cards which are issued by EndlessOne Global,
                                                        Inc. As currently
drafted, your disclosure suggests that you are issuing the prepaid cards
                                                        and the "innovative
payout solutions," when these appear to be products of EndlessOne.
                                                        We note, for example,
your discussion on page 5 where you explain the benefits of "our
                                                        GPR BlueOne prepaid
cards." Please clarify that the benefits of the prepaid cards are
                                                        offered by EndlessOne,
and remove the inference that you are offering these benefits, and
                                                        clarify whether there
is any difference between the prepaid cards offered by EndlessOne
                                                        and the "GPR BlueOne"
prepaid cards. This is just one example. Please also remove the
                                                        statement that you are
a "FinTech company aiming to provide innovative payout
                                                        solutions," as this
does not appear to accurately describe your business.
 James Koh
FirstName  LastNameJames Koh
BlueOne Card,  Inc.
Comapany
January 25,NameBlueOne
            2021       Card, Inc.
January
Page 2 25, 2021 Page 2
FirstName LastName
2.       Please revise your disclosure throughout to clearly state that you
have not generated
         any revenues to date from your planned business and your business is
very early stage.
         Please also revise to clarify that your platform is not currently
operational, as your
         disclosure suggests that you currently provide this platform. Please
also clarify the status
         of the platform and indicate who is developing the platform and
whether you have entered
         into any contracts or made any payments to date for the development.
Please also tell us
         whether this is your own platform, or a platform operated by
EndlessOne.
3.       Please revise to clearly explain your duties under the agreement with
EndlessOne, which
         appear to be limited to providing the first introduction of EndlessOne
products to
         customers, qualifying customers for the products, making sales
presentations, and
         distributing EndlessOne's materials. Please clearly state that you are
acting as an
         independent sales representative for EndlessOne and remove any
reference that you are a
         partner with EndlessOne. Please also specify that you will not receive
revenue from
         customer contracts, which will be executed with EndlessOne.
4.       Please clearly explain the fees and payments that you will receive
from EndlessOne,
         including how you earn such payments. Please also file the Fee
Processing Schedule that
         is included with your Authorized Reseller Agreement, or tell us why
you do not believe
         you are required to do so. Please disclose whether you have made any
payments to
         EndlessOne to date.
5.       Please provide a general description of the business and operations of
EndlessOne,
         including the number of cardholders and the size of the company.
Please disclose the
         number of independent sales representatives of EndlessOne, and whether
such sales
         representatives operate in the same territory as you.
Our Market Strategy, page 6

6.       Please tell us why you believe that you have a market opportunity of
34,000 liquor stores
         throughout the United States, as suggested by your disclosure on page
6.
Distribution of Our Products and Services, page 7

7.       Please tell us why you believe that the GPR BlueOne prepaid card is
"the most
         revolutionary card to card transfer." Please tell us specifically how
it is different from any
         other cards on the market today.
Our President, CEO, CFO and Chairman, page 33

8.       It appears that Mr. Koh served as an executive officer and director of
Golden Rush, Inc.
         and Monetiva, Inc., which were both SEC reporting companies. Please
disclose
         all directorships held by Mr. James Koh during the past five years in
any company with a
         class of securities registered pursuant to Section 12 of the Exchange
Act or subject to the
         requirements of Section 15(d) of the Exchange Act. Please discuss Mr.
Koh's roles at
         both companies, and disclose that the registration of Golden Rush was
revoked in 2019.
 James Koh
BlueOne Card, Inc.
January 25, 2021
Page 3
         With respect to Monetiva, Inc, we note that Mr. Koh sold the company
to Pierre Sawaya
         in 2017, who is the founder of EndlessOne Global. We further note that
Monetiva has a
         similar business plan to that of your company, including a contract
with EndlessOne, but
         it has not generated any revenue to date. Please disclose any
relationship or affiliation
         between Monetiva and BlueOne Card, Inc.
Item 13. Financial Statements and Supplementary Data
Audited Financial Statements, page F-1

9.       Please revise all share and per share numbers to reflect the June 30,
2020 1-for-100
         reverse stock split. Please also add disclosure describing the split
and the impact on the
         share and per share numbers.
Note 7 - Stockholders' Equity, page F-13

10.      Please disclose the pertinent rights and privileges of the preferred
stock to include
         liquidation preference, rights to dividends, conversion rights and
voting rights. Refer to
         ASC 505-10-50-3. In addition, we note that on September 30, 2020 your
Chief Executive
         Officer converted 8,000 share of preferred stock into 8,000,000 common
shares. Please
         confirm that the post splits exchange ratio is 1,000 for 1.
        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 Nasreen Mohammed at 202-551-3773 or Adam Phippen at
202-551-
3336 if you have questions regarding comments on the financial statements and
related
matters. Please contact Scott Anderegg at 202-551-3342 or Erin Jaskot at
202-551-3442 with
any other questions.



FirstName LastNameJames Koh                                    Sincerely,
Comapany NameBlueOne Card, Inc.
                                                               Division of
Corporation Finance
January 25, 2021 Page 3                                        Office of Trade
& Services
FirstName LastName