June 20, 2019

Everett Dickson
Chief Executive Officer
Aureus Inc.
1170 Peachtree Street, Suite 1200
Atlanta, GA 30309

       Re: Aureus Inc.
           Offering Statement on Form 1-A
           Filed May 29, 2019
           File No. 024-11008

Dear Mr. Dickson:

       We have reviewed your offering 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 offering 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 offering statement and the
information you
provide in response to these comments, we may have additional comments.

Offering Statement on Form 1-A

Risk Factors
Risks Relating to our Common Stock and Offering
Because directors and officers current and for the foreseeable future will
continue to control,
page 13

1.     Please expand your disclosure to discuss your Series A Preferred Stock.
In this regard, we
       note you disclose on page 35 that as along as at least one share of your
Series A Preferred
       Stock is outstanding, such Preferred Stock shall represent 66 2/3% of
all votes entitled to
       be voted at any annual or special meeting of shareholders and that all
such shares are held
       by Everett Dickson, the company's President. In addition, please file
all instruments
       defining rights of security holders, such as the notice of designation
of preferred stock.
 Everett Dickson
FirstName LastNameEverett Dickson
Aureus Inc.
Comapany NameAureus Inc.
June 20, 2019
June 20, 2019 Page 2
Page 2
FirstName LastName
Use of Proceeds, page 14

2.       We note you intend to apply a portion of your net proceeds to
discharge bank debt. Please
         describe the material terms of such bank debt. Refer to Instruction 6
to Item 6 of Form 1-
         A.
Distribution, page 17

3.       We note you state that all subscriptions are irrevocable and that the
purchase price is non-
         refundable. Please expand your disclosure to explain when you will
accept subscriptions
         and file the subscription agreement that will be used in this offering
as an exhibit to the
         Form 1-A. Refer to Item 17.4 of Form 1-A.
4.       Disclosure here indicates that you will use an online platform to
offer your common stock
         on a best efforts basis. Please describe the online platform on which
you will offer your
         common stock.
Business, page 21

5.       Please revise your disclosure to clarify the material terms and status
of your acquisition
         agreement with Yuengling's Ice Cream Corp. In this regard, we note you
have filed as
         Exhibit 6.9 a "letter of intent" to purchase all of the assets of
Yuengling's Ice Cream Corp.
         dated March 26, 2019, but your press release issued February 28, 2019
states you
         "formally closed" your merger with Yuengling's Ice Cream Online
Distributors, LLC,
         which is the exclusive online purveyor of the Yuengling Ice Cream
Brand. We further
         note you issued a press release on May 13, 2019 that indicates you
exclusively operate
         Yuengling's online sales, as well as select Yuengling retail
distribution. Please file any
         related material agreements, including any definitive acquisition
agreement, as exhibits to
         your filing.
        We will consider qualifying your offering statement at your request. In
connection with
your request, please confirm in writing that at least one state has advised you
that it is prepared
to qualify or register your offering. 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
action by the staff.
 Everett Dickson
Aureus Inc.
June 20, 2019
Page 3

       You may contact Jennifer O'Brien, Staff Accountant, at (202) 551-3721 or
Ethan
Horowitz, Accounting Branch Chief, at (202) 551-3311 if you have questions
regarding
comments on the financial statements and related matters. Please contact Karina
Dorin, Staff
Attorney, at (202) 551-3763 or Loan Lauren P. Nguyen, Legal Branch Chief, at
(202) 551-3642
with any other questions.



FirstName LastNameEverett Dickson                        Sincerely,
Comapany NameAureus Inc.
                                                         Division of
Corporation Finance
June 20, 2019 Page 3                                     Office of Natural
Resources
FirstName LastName