August 29, 2018


Harry Simeonidis
President
Glucose Biosensor Systems (Greater China) Holdings, Inc.
733 Third Avenue, Floor 15
New York, NY 10017

       Re:     Glucose Biosensor Systems (Greater China) Holdings, Inc.
               Amendment No. 2 to Draft Offering Statement on Form 1-A
               Submitted August 15, 2018
               CIK No. 0001725430

Dear Mr. Simeonidis:

      We have reviewed your amended draft 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 providing the requested information
and either submitting
an amended draft offering statement or publicly filing your offering statement
on EDGAR. 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 draft offering statement or filed offering statement and the
information you provide in
response to these comments, we may have additional comments.

Lock-up Agreements, page 53

1.     We note your response to prior comment 9. Please reconcile your
disclosure in this
       section and on page 94 regarding the duration of the lock-up period with
Exhibit 6.6.
       Please also reconcile the disclosure on page 78 regarding Dr. Caminis
serving as
       Executive Vice President with your response that he will not serve on
the executive team.

License Agreement, page 62

2.     We note your response to prior comment 1; however, the first bullet
point of this section
       discloses that a change in control includes a change of 30% ownership or
voting rights.
       Page 12 refers to a 50% change. Please reconcile. Also, tell us which
exhibit provides
       for the payment to avoid the change of control termination consequences
mentioned in
       the second clauses (i) and (ii) of the penultimate bullet point on page
63.
 Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
August 29, 2018
Page 2

Principal Place of Business, page 78

3.      Please expand your response to prior comment 4 to address from where
the other
        members of your management perform their roles for the issuer; tell us
the nature of
        those roles, and tell us about any role that your current sole
shareholder and its affiliates
        have in directing, controlling and coordinating your activities.
Disclose when Dr. Becker
        will begin the activities that you disclose on page 77 and 78 that he
will undertake, and
        tell us whether his position is full-time and when he began receiving
the disclosed
        compensation. Also, disclose in an appropriate section of your offering
circular the
        general character of your principal properties. In this regard, tell us
about your
        relationships with iqbiosensor whose website indicates a Sydney
address.

Security Ownership . . ., page 87

4.      Please expand your response to prior comment 6 to clarify how the 21%
owner of Life
        Science Biosensor Diagnostics would have sole voting and dispositive
power over the
        shares given your disclosure on page 88 that IQnovate Limited is the
majority owner of
        Life Science Biosensor Diagnostics. It is unclear whether other natural
persons have or
        share voting and/or dispositive power over the shares held by Life
Science Biosensor
        Diagnostics.

Description of Our Securities, page 89

5.      Please tell us how the "No. of Ordinary Shares in GBSGC Pty Ltd"
mentioned on page
        F-6 is reflected in this section.

Anti-takeover Effects, page 90

6.      Please address the last sentence of prior comment 1. It is unclear how
your disclosures at
        the top of page 45 and in the second and third subsections on page 91
are reconcilable
        with the second exhibit that you have numbered as exhibit 2.4.

Exhibits

7.      Please file the Annex and Purchaser Questionnaire mentioned in exhibit
1.1, and tell us
        which exhibit represents the agreement with FundAmerica mentioned on
page 51 and the
        engagement agreement mentioned on page 52. Also tell us the authority
on which you
        rely to omit schedule 3 to exhibit 6.7, and which exhibit represents
the orders mentioned
        on page 88.

Exhibit 4.1

8.      Please address in your offering statement the governing law,
indemnification, waiver of
        trial by jury and jurisdiction provisions of this exhibit. If any of
these provisions would
 Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
August 29, 2018
Page 3

        apply to claims under the federal securities laws and the rules and
regulations thereunder,
        revise to affirmatively state (in both your offering circular and the
appropriate exhibit)
        that, by agreeing to these provisions, investors will not be deemed to
have waived their
        rights under the federal securities laws and the rules and regulations
thereunder. In
        addition (1) address any question under applicable law as to the
enforceability of any of
        the provisions and whether these provisions would apply to transferees,
and (2) provide
        us your analysis of how the last sentence of section 4(f) is consistent
with the disclosure
        in the rest of your offering statement.

        You may contact Michael Fay at (202) 551-3812 or Gary Todd, Senior
Accountant, at
(202) 551-3605 if you have questions regarding comments on the financial
statements and
related matters. Please contact Geoff Kruczek at (202) 551-3641 or me at (202)
551-3617 with
any other questions.

                                                             Sincerely,

                                                             /s/ Russell
Mancuso

                                                             Russell Mancuso
                                                             Branch Chief

cc: Gary J. Simon--Hughes Hubbard & Reed LLP