October 10, 2019

I. Andrew Weeraratne
Chief Executive Officer
Acqusalut Inc.
7135 Collins Ave
No.624
Miami Beach, Florida 33141

       Re: Acqusalut Inc.
           Amendment No.1 to Offering Statement on Form 1-A
           Filed September 25, 2019
           File No. 024-10996

Dear Mr. Weeraratne:

      We have reviewed your amended 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 amending your offering 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 offering 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 June 3, 2019
letter.

Amendment No. 1 to Offering Statement on Form 1-A filed September 25, 2019

Risks Factors
Risks Related to Our Business , page 5

1.     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.
Risks Related to this Offering
"Our management has included an arbitration clause . . .", page 5

2.     We note your responses to comments two and three, and your amended risk
factor
       disclosure on page 5. Please amend your disclosure in the offering
circular to clearly state
 I. Andrew Weeraratne
FirstName Inc.
Acqusalut LastNameI. Andrew Weeraratne
Comapany NameAcqusalut Inc.
October 10, 2019
October 10, 2019 Page 2
Page 2
FirstName LastName
         that you have both an arbitration provision and an exclusive forum
provision in your
         subscription agreement. In this regard, we note that your amended
subscription agreement
         appears to contain an exclusive forum provision in Section IV(1), and
an arbitration
         provision in Section IV(2). You should clearly describe each
provision, the risks related
         to each provision, and any uncertainty about the enforceability of
each provision. For
         clarity, you should consider providing separate risk factors for each
provision.

         As a related matter, we note your responses to comments 2 and 3 that
the arbitration and
         exclusive forum provisions apply to all claims arising or relating to
state and federal
         securities laws and the rules and regulations promulgated thereunder.
Please amend
         your disclosure in the offering circular to state the same, and amend
Section IV(2) of your
         subscription agreement to include a statement that this clause also
applies to federal
         securities law claims. Further, because it appears that the
arbitration clause applies to
         federal securities law claims, please disclose that, by agreeing to
the subscription
         agreement, investors cannot waive the company's compliance with the
federal securities
         laws and the rules and regulations promulgated thereunder.
Use of Proceeds, page 9

3.       In light of your current development stage, please revise to clarify
the basis for your
         estimate of cash flow to be generated per music concert.
100% of the Shares of Common Stock Offered, page 11

4.       We note that you have amended your use of proceeds disclosure to
reflect that you now
         plan to use the proceeds of the offering to do live entertainment, and
that if you sell 75%
         or 100% of the shares of common stock that you are offering, you will
do a two-night
         music festival where you believe that you can make $10,000,000. The
difference in the
         use of net proceeds for 75% of the offering and 100% of the offering
appears to be an
         increase in annual and future administrative expenses. Please briefly
explain the
         difference between the use of proceeds for 75% of the offering and
100% of the offering,
         including why you estimate annual and future administrative expenses
to be higher if you
         sell 100% of the offering, even though it appears from your disclosure
that you intend to
         do the same two-day festival under each scenario.
Directors, Executive Officers, and Significant Employees, page 20

5.       Please include a table substantially similar to the one found in Item
10(a) of Form 1-A,
         including the name, position, age, term of office, and approximate
hours per week for
         part-time employees.
Compensation of Directors and Executive Officers, page 22

6.       Please provide the disclosure required by Item 10(a) and Item 11(a) of
Form 1-A to
         include Ms. Kazuko Kusunoki. In this regard, we note that your amended
disclosure
         describes Ms. Kazuko Kusonoki as the Vice President of Administration.
See the
 I. Andrew Weeraratne
Acqusalut Inc.
October 10, 2019
Page 3
         definition of "executive officer" in Instruction 2. to Item 10(a) of
Form 1-A.
General

7.       Please remove references throughout your offering statement that you
are "registering"
         shares in this offering, considering that you are filing on Form 1-A,
which applies to
         securities offerings made pursuant to Regulation A, and you are not
registering any shares
         under the Securities Act or Exchange Act. For example, we note that
your "Use of
         Proceeds" section states that you are "registering" shares of common
stock.
       You may contact Katherine Bagley, Staff Attorney, at 202-551-2545 or
Jennifer L pez,
Staff Attorney, at 202-551-3792 with any questions.



FirstName LastNameI. Andrew Weeraratne                         Sincerely,
Comapany NameAcqusalut Inc.
                                                               Division of
Corporation Finance
October 10, 2019 Page 3                                        Office of Trade
& Services
FirstName LastName