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                            March 2, 2023

       Matthew Reid
       Chief Executive Officer
       APPlife Digital Solutions Inc.
       50 California St, #1500
       San Francisco, CA 94111

                                                        Re: APPlife Digital
Solutions Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed February 16,
2023
                                                            File No. 333-269389

       Dear Matthew Reid:

             We have reviewed your amended 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.
Unless we note
       otherwise, our references to prior comments are to comments in our
February 7, 2023 letter.

       Amendment No. 1 to Registration Statement on Form S-1

       Description of Business
       Products, page 20

   1.                                                   We note your response
to prior comment 4 and reissue it, in part. With respect to the
                                                        development of your
Valida "super wallet", please provide a description of the processes
                                                        and fees related to the
use of the Polygon blockchain.
 Matthew Reid
FirstName  LastNameMatthew
APPlife Digital Solutions Inc. Reid
Comapany
March      NameAPPlife Digital Solutions Inc.
       2, 2023
March2 2, 2023 Page 2
Page
FirstName LastName
2.       We note your response to prior comment 6. Please expand your
discussion of the security
         precautions you will take to keep your customers crypto assets secure
and highlight the
         risk that you may be liable for any cybersecurity breach resulting in
the loss of customer
         assets. Additionally, given that the wallets will be non-custodial,
please provide more
         detail on how the "cold storage" feature will work.
3.       With respect to the development of your Valida wallet, we note that
you will focus on
         storing and sharing NFTs that represent practical use. Please explain
how you intend to
         achieve this focus and whether you will prevent customers from storing
other types of
         NFTs. Additionally, please identify all of the services that you will
provide in connection
         with the super wallet. Lastly, we note that you "plan to add a
secondary round of
         features." Please expand your discussion to identify those planned
features.
General

4.       We note your response to prior comment 9 that your business management
and executive
         teams do not operate in China and that you generate no revenue in
China. However, you
         disclose in the risk factors that your "sole officer and director,
Matt Reid, resides in China
         and operates the Company from China." Your disclosure also indicates
that you work in
         partnership with a licensed law firm in Shanghai China and that you
anticipate working
         with other Chinese entities. Please revise your disclosure to address
this inconsistency or
         explain.
        Please contact Kyle Wiley, Staff Attorney, at 202-344-5791 or Jan Woo,
Legal Branch
Chief, at 202-551-3453 with any other questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Technology
cc:      Chase Chandler