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                            April 27, 2022

       Robert Bohorad
       Chief Executive Officer
       Yuenglings Ice Cream Corporation
       One Glenlake Parkway #650
       Atlanta, GA 30328

                                                        Re: Yuenglings Ice
Cream Corp
                                                            Post-effective
amendment to Offering Statement on Form 1-A
                                                            Filed April 19,
2022
                                                            File No. 024-11517

       Dear Mr. Bohorad:

             We have reviewed your amended 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.
Unless we note
       otherwise, our references to prior comments are to comments in our March
30, 2022 letter.

       Offering Statement on Form 1-A filed April 19, 2022

       General

   1.                                                   We note your responses
of April 8, 2022 and April 18, 2022 to comment one of our letter
                                                        dated March 30, 2022.
While your initial response indicated that you determined financial
                                                        statements and pro
forma information for your pending acquisition of Revolution
                                                        Desserts, LLC were
required, you now believe the information is not required because a
                                                        recently signed letter
of intent between the parties is non-binding. To help us better
                                                        understand your
conclusions, we reissue our comment. Please provide us with a clear and
                                                        full analysis of
whether financial statements and pro forma information for each of your
                                                        planned acquisitions of
Revolution Desserts LLC and the production facility are required
                                                        pursuant to Part F/S of
Form 1-A and Rules 8-04 and 8-05 of Regulation S-X. Tell us (i)
 Robert Bohorad
Yuenglings Ice Cream Corporation
April 27, 2022
Page 2
         whether each of these acquisitions were of businesses as described in
Rule 11-01(d) of
         Regulation S-X; (ii) whether the acquisitions are probable and support
any conclusions to
         the contrary; and (iii) provide your supporting calculations of each
of the significance tests
         outlined Rule 1-02(w) of Regulation S-X. Tell us the amount and nature
of the planned
         consideration for each merger.
2.       In addition, please refer to your response dated April 18, 2022 and
clarify for us whether it
         is your determination that the acquisition of Revolution Desserts now
is no longer
         probable. Please address the following:
             Provide us with a robust discussion of the factors you considered
in initially
              concluding that the acquisition was probable and how, if any,
those factors have
              changed. In this regard, please note that an assessment of
probability requires
              consideration of all available facts and that having a    binding
   versus    non-binding
              letter of intent would only be one of several factors considered
in determining
              whether consummation of the transaction is probable.
             Tell us how you considered the expected May 2022 closing date of
the transaction in
              your determination of probability.
             Explain to us how your determination considered that the assets of
Revolution
              Desserts appear to be more than 50% of your own total assets
based on the balance
              sheet amounts previously included in Exhibit 7.9. In this regard,
as explained in FRC
              506.02(c)(ii), note that an acquisition is deemed probable where
the registrant   s
              financial statements alone would not provide adequate financial
information to make
              an investment decision.
             Identify for us the material terms of, and highlight all changes
between, your
                 binding    letter of intent and your new    non-binding
letter of intent with Revolution
              Desserts, and tell us whether Board of Director approval was
required and, if so,
              obtained, on either side.
             Describe to us the overall status of negotiations and provide us
with an expected
              chronological timeline of pending events that must be
accomplished before the
              expected closing date in May 2022. Discuss all open contingencies
and explain why
              you believe they will be resolved by the expected closing date.

       You may contact Bradley Ecker, Staff Attorney, at (202) 551-4985 or
Sherry Haywood,
Staff Attorney, at (202) 551-3345 with any questions.



FirstName LastNameRobert Bohorad                                Sincerely,
Comapany NameYuenglings Ice Cream Corporation
                                                                Division of
Corporation Finance
April 27, 2022 Page 2                                           Office of
Manufacturing
FirstName LastName