February 7, 2019

Melvin Pereira
Chief Executive Officer
MESO NUMISMATICS, INC.
3265 Johnson Avenue
Suite 213
Riverdale, NY 10463

       Re: MESO NUMISMATICS, INC.
           Form 10-12G
           Filed December 12, 2018
           File No. 000-56010

Dear Mr. Pereira:

       We have reviewed your filing 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

     After reviewing your response and any amendment you may file in response
to these
comments, we may have additional comments.

Form 10 Filed December 12, 2018

Business
General Information, page 1

1.    We note your disclosure regarding the merger between Pure Hospitality
Solutions and
      Meso Numismatics Corp. Please revise here to clarify that your CEO,
Melvin Pereira,
      controlled both companies at the time of the merger. In this regard, we
note your
      disclosure on page F-11.
Risk Factors, page 6

2.    Please add a risk factor regarding the fact that your auditor has
expressed substantial
      doubt about your ability to continue as a going concern, and the risks
related to the same.
 Melvin Pereira
FirstName LastNameMelvin Pereira
MESO NUMISMATICS, INC.
Comapany NameMESO NUMISMATICS, INC.
February 7, 2019
February 7, 2019 Page 2
Page 2
FirstName LastName
We have a significant number of shares of our common stock . . . ., page 11

3.       Please disclose in this or a separate risk factor the number of shares
issuable upon
         conversion of the outstanding Series BB Preferred Stock.
Our Executive Officers and Directors . . . ., page 12

4.       Please revise this risk factor to quantify the percentage of voting
power held by your
         executive officers and directors, giving effect to their ownership of
the Series AA
         Preferred.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Results of Operations for the Nine Months Ended September 30, 2018 Compared to
the Nine
Months Ended September 30, 2018, page 14

5.       Please disclose management's insight into the sources and changes in
your revenue for
         the interim and annual periods. Refer to Item 303(a)(3)(ii) and (iii)
and Item 303(b)(2) of
         Regulation S-K.
6.       Please revise your analysis of the change in gross profit to also
analyze your gross profit
         as a percentage of revenue. In doing so, please disclose management's
insight into why
         your sales were less profitable during the nine months ended September
30, 2018.
Directors, Executive Officers, page 21

7.       We note disclosure throughout your registration statement regarding
the benefit of Mr.
         Pereira's experience in the numismatics industry. To support these
statements, please
         revise this section to describe this experience in more detail.
Certain Relationships and Related Transactions, page 23

8.       Please identify by name the related party referenced in this section.
Refer to Item 404 of
         Regulation S-K.
Financial Statements
Financial Statements for the Nine Months Ended September 30, 2018 and 2017
Note 2 - Summary of Significant Accounting Policies
Revenue Recognition, page F-8

9.       We note your disclosure regarding the adoption of ASC 606 here and in
your Critical
         Accounting Policy for revenue recognition on page 19. In both
locations, you indicate
         that you recognize revenue from the sale of goods, licensing
agreements and contracts to
         perform pilot studies. If you generate revenue from licensing
agreements and/or contracts
         to perform pilot studies please revise the description of your
business and the analysis of
         your results within MD&A to describe these lines of business and the
resulting revenue.
 Melvin Pereira
FirstName LastNameMelvin Pereira
MESO NUMISMATICS, INC.
Comapany NameMESO NUMISMATICS, INC.
February 7, 2019
February 7, 2019 Page 3
Page 3
FirstName LastName
         Otherwise, please remove the reference to these lines of business from
this footnote and
         page 19. Additionally, we note your statements here and on page 19
that you accrue for
         warranty costs. Please tell us and disclose to your readers more
detailed information
         about the warranties you offer; or if you do not provide warranties,
remove your reference
         to warranties from your revenue recognition policies.
Going Concern, page F-11

10.      You state here that you will need $750,000 to fund basic operations
for the next twelve
         months. In your liquidity and capital resources discussions on pages
14 and 17, you state
         that you will need an aggregate of $645,000 for your three-stage
approach to build your
         application technology. Please clarify your disclosures here and
within liquidity and
         capital resources to state, if true, that the $645,000 required to
build your application
         technology is in addition to the $750,000 needed for basic operations.
If this is not the
         case, please revise your disclosures accordingly. Finally, please
revise your liquidity and
         capital resources discussions to disclose, if known, the time frame in
which you expect to
         execute each stage of your three-stage approach.
Financial Statements for the Years Ended December 30, 2017 and 2016
Report of Independent Registered Public Accounting Firm, page F-25

11.      Please have your auditors revise their audit report to include their
audit tenure.
         Specifically, a statement disclosing the year in which they began
serving consecutively as
         your auditor should be presented. Refer to PCAOB Release No. 2017-001.
Additionally,
         if you continue to believe that reference to the restatement of your
financial statements is
         appropriate, please have your auditors revise the paragraph of their
audit report describing
         the restatement of the 2017 financial statements to remove the
reference to 2018.
Note 2 - Summary of Significant Accounting Policies
Business Combinations, page F-35

12.      We note that you accounted for the acquisition of Meso Numismatics as
a merger of
         entities under common control. We have the following comments:

             Please tell us the date that you and Meso Numismatics first came
under common
             control and clearly disclose this to your investors.

             Please confirm our assumption, if true, that your audited and
interim financial
             statements have combined your financial statements and the
financial statements of
             Meso Numismatics for the period between the date you first came
under common
             control and the acquisition date. Refer to ASC 805-50-45-2 through
45-5.

             If the above assumption is correct, please revise your analysis of
results within MD&A
             to better explain to your investors the changes that occurred at
Meso Numismatics in
 Melvin Pereira
MESO NUMISMATICS, INC.
February 7, 2019
Page 4
             2017 that allowed it to begin generating revenue and the further
changes that occurred
             at Meso Numismatics in 2018 that resulted in a significant
increase in revenue.
Note 8 - Restatements, page F-47

13.      We note the discussion of the restatement of your financial
statements, including your
         presentation of previously filed financial statement amounts. Please
tell us and revise
         your footnote to more clearly disclose to your investors the meaning
of your references to
         "previously filed" or "as filed" financial statements. We note that
this Form 10 is the first
         filing you have made with us, so your references to previously filed
financial statements
         do not appear to have the common meaning of financial statements
previously filed with
         the SEC.
        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.

        You may contact Yong Kim, Staff Accountant, at (202) 551-3323 or
Jennifer Thompson,
Accounting Branch Chief, at (202) 551-3737 if you have questions regarding
comments on the
financial statements and related matters. Please contact Lisa Kohl, Legal
Branch Chief, at (202)
551-3252 with any other questions.



FirstName LastNameMelvin Pereira                                Sincerely,
Comapany NameMESO NUMISMATICS, INC.
                                                                Division of
Corporation Finance
February 7, 2019 Page 4                                         Office of
Consumer Products
FirstName LastName