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                              May 16, 2024

       He-Siang Yang
       Chief Executive Officer and Chief Financial Officer
       EOS INC.
       5F-1, No.5, Qingdao E. Rd. Zhongzheng District
       Taipei City 100008, Taiwan

                                                        Re: EOS INC.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2023
                                                            File No. 000-55661

       Dear He-Siang Yang:

                                                        We have reviewed your
filing and have the following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K For the fiscal year ended December 31, 2023

       Item 1C. Cybersecurity, page 7

   1.                                                   We note you do not
include Item 1.C Cybersecurity. Please revise or advise us why you
                                                        do not provide
disclosure as applicable under Item 106 of Regulation S-K.
       Evaluation of Disclosure Controls and Procedures, page 18

   2.                                                   Please revise the
heading Evaluation of Disclosure Controls and Procedures
                                                        to Management   s
Report on Internal Control over Financial Reporting. In addition, you
                                                        set forth that
management assessed the effectiveness of our internal control over financial
                                                        reporting as of July
31, 2018. Please correct the date in an amended filing. Lastly, you set
                                                        forth that you used the
criteria set forth by the Committee of Sponsoring Organizations of
                                                        the Treadway Commission
(COSO) in Internal Control - Integrated Framework. Please
                                                        revise your disclosure
to refer to the specific framework used. Refer to Item 308 of
                                                        Regulation S-K.
 He-Siang Yang
FirstName
EOS INC. LastNameHe-Siang Yang
Comapany
May        NameEOS INC.
     16, 2024
May 16,
Page 2 2024 Page 2
FirstName LastName
Item 9A. Controls and Procedures
Definition and Limitations of Disclosure Controls and Procedures, page 18

3.       Please revise your heading to Evaluation of Disclosure Controls and
Procedures to
         provide more clarity. In addition, you refer to December 31, 2020 two
times in the
         paragraph, not December 31, 2023. Please correct your disclosure in an
amended filing.
         Refer to Item 307 of Regulation S-K.
Part IV, page 26

4.       We note that both sets of certifications are dated April 16, 2023 not
2024. Please filed an
         amended Form 10-K with corrected dates for your Exhibit 31 and Exhibit
32
         certifications.
Consolidated Financial Statements
Accounts Receivable, page F-8

5.       We note on page F-6 that you recorded $272,843 in bad debt expense in
2022 and
         $148,452 in bad debt recovery in 2023, and that your bad debt expense
in 2022 was
         approximately 42% of net sales. Your related disclosure on pages 13,
F-8 and in the
         results of operations discussion does not appear to provide any
information related to the
         reasons these amounts were recorded. Please revise your filing to
provide the disclosures
         required by ASC 326-20-50-10 and 50-11, and the rollforward required
by 50-13. As part
         of your revised disclosure, please provide company specific details
that describe the
         reasons the bad debt expense and subsequent recovery were recorded. In
addition, please
         tell us the amount of December 31, 2023 accounts receivable that were
subsequently
         collected in cash and the reasons for any significant amounts that
were not collected in
         cash.
Revenue Recognition , page F-9

6.       We note you attribute your revenue to the Asia Pacific region. Please
revise your
         disclosure to disclose revenues from customers attributed to your
country of domicile and
         attributed to all foreign countries in total from which you derive
revenues. If revenues
         from external customers attributed to an individual foreign country
are material, those
         revenues shall be disclosed separately. Refer to ASC 280-10-50-41(a).
General

7.       To the extent that one or more of your officers and/or directors are
located in China
         or Hong Kong, please create a separate Enforceability of Civil
Liabilities section for
         the discussion of the enforcement risks related to civil liabilities
due to your officers
         and directors being located in China or Hong Kong. Please identify
each officer
         and/or director located in China or Hong Kong and disclose that it
will be more difficult
         to enforce liabilities and enforce judgments on those individuals. For
example, revise
 He-Siang Yang
EOS INC.
May 16, 2024
Page 3
      to discuss more specifically the limitations on investors being able to
effect service
      of process and enforce civil liabilities in China, lack of reciprocity
and treaties, and cost
      and time constraints.
8.    Please revise to provide the disclosure require by Item 101(h) of
Regulation S-K,
      including for example, clarifying or disclosing your:
          principal products and services and their markets, your distribution
methods and the
           status of any expected new products or services;
          competitive conditions, your competitive position in the industry,
and in what way
           you compete;
          relationships and reliance on suppliers or distributors;
          source of materials and any material suppliers; and
          material patents or intellectual property rights that you own or to
which you have
           acquired the rights.
      In addition, please consider whether your disclosure of your number of
employees should
      be updated.
        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.

       Please contact Michael Fay at 202-551-3812 or Julie Sherman at
202-551-3640 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas O'Leary at 202-551-4451 or Abby Adams at 202-551-6902 with any
other
questions.



                                                              Sincerely,

FirstName LastNameHe-Siang Yang                               Division of
Corporation Finance
                                                              Office of
Industrial Applications and
Comapany NameEOS INC.
                                                              Services
May 16, 2024 Page 3
cc:       Brett Verona, Esq.
FirstName LastName