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                            August 17, 2022

       Robert Grinberg
       Chief Executive Officer
       Life Clips, Inc.
       2875 Northeast 191 Street, Suite 500 - #218
       Aventura, FL 33180

                                                        Re: Life Clips, Inc.
                                                            Offering Statement
on Form 1-A
                                                            Post Qualification
Amendment No. 2
                                                            Filed August 16,
2022
                                                            File No. 024-11514

       Dear Mr. Grinberg:

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

              Please respond to this letter by amending your offering statement
and providing the
       requested information. If you do not believe our comment applies 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 offering statement and
the information you
       provide in response to this comment, we may have additional comments.

       Post Qualification Amendment No. 2 to Offering Statement on Form 1-A
filed August 16, 2022

       General

   1.                                                   We note your response
to comment 3 and reissue in part. Your audit report on page F-2
                                                        appears to only cover
the period ending June 30, 2021. Please amend the filing to have
                                                        your auditor include an
audit report that covers both periods presented in the audited
                                                        financial statements.
Refer to Rule 2-02 of Regulation S-X.
               We will consider qualifying your offering statement at your
request. If a participant in
       your offering is required to clear its compensation arrangements with
FINRA, please have
       FINRA advise us that it has no objections to the compensation
arrangements prior to
       qualification.

              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
 Robert Grinberg
Life Clips, Inc.
August 17, 2022
Page 2

action by the staff.

       Please contact Jason Drory at 202-551-8342 or Celeste Murphy at
202-551-3257 with
any other questions.



                                                        Sincerely,
FirstName LastNameRobert Grinberg
                                                        Division of Corporation
Finance
Comapany NameLife Clips, Inc.
                                                        Office of Life Sciences
August 17, 2022 Page 2
cc:       Jonathan D. Leinwand, P.A.
FirstName LastName