September 24, 2018

Reymund Guillermo
President
Cocoluv Inc.
1390 Main Street, Suite 200
San Francisco, CA 97204

       Re: Cocoluv Inc.
           Registration Statement on Form S-1
           Filed August 28, 2018
           File No. 333-227066

Dear Mr. Guillermo:

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

Form S-1 filed August 28, 2018

General, page 1

1.     Your filing indicates that you are a development stage company with
limited operating
       activities, no revenues, no products, no arrangements for additional
financing and nominal
       assets consisting only of cash. These and other facts suggest that your
proposed business
       is commensurate in scope with the uncertainty ordinarily associated with
a blank check
       company and that you should comply with Rule 419 of Regulation C under
the Securities
       Act. Please revise the registration statement to comply with Rule 419,
or provide us a
       detailed legal analysis which explains why Rule 419 does not apply to
this offering, and
       state prominently on the cover page of the prospectus that you are not a
blank check
 Reymund Guillermo
FirstName LastNameReymund Guillermo
Cocoluv Inc.
Comapany 24, 2018
September NameCocoluv Inc.
September 24, 2018 Page 2
Page 2
FirstName LastName
         company and have no plans or intentions to engage in a business
combination following
         this offering.
Prospectus Cover Page, page 3

2.       We note disclosure here that your shares will be offered for one
hundred forty (140) days
         from the prospectus effective date. We also note disclosure on page
six in the
         Termination of the Offering section that your shares may be offered
for one hundred
         twenty (120) days from the prospectus effective date and in your
discretion you may
         extend the offering for an additional 60 days. Please make your
disclosure consistent on
         whether your shares will be offered 140 days or 120 days from the
prospectus effective
         date, and disclose on the prospectus cover page that in your
discretion you may extend the
         offering for an additional 60 days.
Prospectus, page 3

3.       You state you are offering for sale a total of 3,000,000 shares of
common stock at a fixed
         price of $0.05 per share. Later in the same paragraph, you disclose
the shares will be
         offered at a fixed price of $0.03 per share. Please correct this
amount to $0.05, if
         appropriate. Please also revise your statement under the Use of
Proceeds section on page
         12 that the offering price per share is $0.03.
Prospectus Summary, page 5

4.       Please disclose your anticipated expenditures over the next twelve
months in this section.
5.       We note your disclosure on page 10 that after this offering, Mr.
Guillermo will own
         57.14% of your common shares. Please disclose in this section, the
percent of outstanding
         stock Mr. Guillermo will own upon the closing of the offering. Please
also disclose that
         as a result, Mr. Guillermo is able to control all matters submitted to
the shareholders for
         approval, as well as your management and affairs.
6.       We note disclosure that you do not anticipate earnings revenues until
such time as you
         enter into "commercial operation". Please revise to describe the
meaning of "commercial
         operation" and discuss the time frame in which you plan to enter into
such commercial
         operation.
7.       We note disclosure here that your principal offices are on "Market
Street"in California and
         on the facing page and page 23 that your offices are located on "Main
Street". Please
         revise to make your disclosure consistent. We also note that Article I
of your bylaws state
         that your principal office and place of business is located in
Chesapeake, Virginia and
         your registered office is to be maintained in Nevada. Please clearly
disclose here and in
         the Business section where your business is located and explain why
your offices are not
         consistent with your bylaws, if applicable.
8.       We note disclosure that you intend to use the net proceeds from this
offering to operate
 Reymund Guillermo
FirstName LastNameReymund Guillermo
Cocoluv Inc.
Comapany 24, 2018
September NameCocoluv Inc.
September 24, 2018 Page 3
Page 3
FirstName LastName
         your business only until Phase I of your operation. Please briefly
explain the meaning of
         your Phases I-II here including the time frames and amounts needed in
each Phase I and
         II, provide a cross reference to your Plan of Operations section, and
discuss that the
         amount in this offering is not sufficient for you to begin operations
and may not cover the
         costs of the offering. Please also clearly disclose the time frames of
Phase I and Phase II
         in the Plan of Operations section.
Risk Factors, page 7

9.       Please remove the references to "beverage" as your business on pages 8
and 9.
Our Ability to sustain . . ., page 7

10.      We note disclosure that Mr. Gullermo has verbally agreed to loan the
company funds and
         page 26 discloses that as of May 31, 2018 Mr. Guillermo has loaned you
$1,719. Please
         file a written agreement description of this verbal agreement as an
exhibit to the
         registration statement. See Compliance and Disclosure Interpretations,
Regulation S-K,
         Question 146.04.
We intend to source our products . . . , page 8

11.      We note disclosure that your products are intended to be sourced from
the Philippines and
         you expect to rely on one manufacturer/supplier. We also note
disclosure in the risk
         factor "Because of the specific . . ." on page 8 regarding "possible
issues with our intended
         manufacturer and supplier of our proposed line of hair care products".
Please disclose
         whether or not you have entered into discussions or agreements with a
potential
         manufacturer or supplier.
Description of Business
Industry Overview, page 18

12.      We note the link to the website containing industry information here.
Please clarify
         whether you intend to incorporate this website and its contents into
your prospectus. If
         this is not your intention, please state that the information that can
be assessed through
         this website is not part of the prospectus.
Marketing, page 19

13.      Please revise your disclosure throughout this section to describe your
"intended" website,
         social media, e-commerce store and Twitter community.
Products, page 21

14.      We note disclosure here of your intended four women's products and two
men's hair care
         products. However, elsewhere throughout your filing you disclose that
you intend to have
         three women's products and two men's products for a total of five
products. Please make
 Reymund Guillermo
Cocoluv Inc.
September 24, 2018
Page 4
         your disclosure consistent throughout the filing.
Plan of Distribution, page 27

15.      We note disclosure that Mr. Guillermo will offer the shares of common
stock on your
         behalf to friends, family members and business acquaintances. Please
include such
         disclosure in this section and elaborate how investors will learn
about the offering. For
         example, will Mr. Guillermo solicit investors through direct mailings
and/or personal
         contacts? How would Mr. Guillermo identify those who might have an
interest in
         purchasing shares of common stock?
Common Stock, page 28

16.      We note disclosure that your bylaws provide that all meetings of the
stockholders for the
         election of directors, a plurality of the votes cast shall be
sufficient to elect. Please tell us
         the Article and section of your bylaws that contains such provision.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Jenn Do, Staff Accountant at (202) 551-3743 or Al Pavot,
Staff
Accountant at (202) 551-3738 if you have questions regarding comments on the
financial
statements and related matters. Please contact Sherry Haywood, Staff Attorney
at (202) 551-
3345 or Jay Ingram, Legal Branch Chief at (202) 551-3397 with any other
questions.



                                                                  Sincerely,
FirstName LastNameReymund Guillermo
                                                                  Division of
Corporation Finance
Comapany NameCocoluv Inc.
                                                                  Office of
Manufacturing and
September 24, 2018 Page 4                                         Construction
FirstName LastName