March 13, 2020

Panagiotis Tolis
Chief Investor Relations Officer
Elvictor Group, Inc.
30 Wall Street (8th floor)
New York, NY 10005

       Re: Elvictor Group, Inc.
           Post-effective Amendment No. 4 to Registration Statement on Form S-1
           Filed February 27, 2020
           File No. 333-225239

Dear Mr. Tolis:

       We have reviewed your post-effective amendment 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.

Post-effective Amendment No. 4 to Registration Statement on Form S-1

Prospectus Cover Page, page i

1.     We note that the Form S-1 registration statement that went effective on
October 12, 2018
       registered the offer and sale of 656,700 shares of common stock, but
this post-effective
       amendment is seeking to register the offer and sale of an additional
1,668,605 shares.
       Please provide us with your analysis as to how you may register the
offer and sale of these
       securities by means of a post-effective amendment, or revise your
registration statement to
       remove the additional shares. Please refer to Securities Act Rule 413(a)
and Securities
       Act Rules Compliance and Disclosure Interpretation 210.01.
2.     Your prospectus makes inconsistent references to the fact that you are
conducting a best
       efforts offering and may receive proceeds from this offering. For
example, you state on
       page 1 that you "anticipate raising sufficient capital from this
offering to market and grow
 Panagiotis Tolis
Elvictor Group, Inc.
March 13, 2020
Page 2
         [y]our Company." You make similar statements in your risk factors and
plan of
         operations, among other places. Please revise your prospectus to
consistently describe
         this offering as a resale transaction and state you will receive no
proceeds from this
         offering.
Where You can Find More Information, page 37

3.       You have included language incorporating by reference reports filed
pursuant to Section
         13(a) and 15(d) of the Exchange Act since December 31, 2019. It
appears you are not
         permitted to incorporate by reference because you have not filed an
annual report required
         under Section 13(a) or Section 15(d) of the Exchange Act for your most
recently
         completed fiscal year, and your stock is a penny stock. See Form S-1
General Instruction
         VII(C) and (D)(1)(c). See also Securities Act Forms Compliance and
Disclosure
         Interpretation 113.08. Please revise your disclosure accordingly.
Signatures, page II-5

4.       Please provide the signatures for your principal financial officer or
CFO, and your
         principal accounting officer or controller, as required by the
Instructions to the Signatures
         on Form S-1. If a person is acting in more than one capacity, please
indicate each
         capacity in which the person signs.
General

5.       Please be advised that pursuant to Rule 8-08 of Regulation S-X, you
were required to
         include audited financial statements for the year ended December 31,
2019 in this Post-
         effective Amendment. In this regard, you do not report income from
continuing
         operations attributable to the registrant before taxes in either
fiscal year 2018 or 2017
         (page F-16), and therefore, you do not satisfy the requirement of Rule
8-08(b)(3) of
         Regulation S-X. As such, you are required to update your financial
statements in
         registration statements filed after 45 days but within 90 days of the
year ended December
         31, 2019. Please revise your registration statement to update the
financial statements.
        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 Jacqueline Kaufman at 202-551-3797 or Mara Ransom at
202-551-3264
with any other questions.



FirstName LastNamePanagiotis Tolis                              Sincerely,
Comapany NameElvictor Group, Inc.
March 13, 2020 Page 2                                           Division of
Corporation Finance
FirstName LastName                                              Office of Trade
& Services