March 6, 2020

Robert Bubeck
President and Principal Executive Officer
Allure Worldwide, Inc.
18731 SE River Ridge
Tequesta, FL 33469

       Re: Allure Worldwide, Inc.
           Registration Statement on Form S-1
           Filed February 21, 2020
           File No. 333-234815

Dear Mr. Bubeck:

      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 January 17,
2020 letter.

Form S-1/A filed February 21, 2020

Facing page

1.     We note your response to comment 6. Please revise your facing page to
indicate that you
       are a Florida corporation. Additionally, please file a revised legality
opinion which opines
       upon Florida law.
Cover page

2.     Please revise to define "Minimum Offering".
The Offering , page 7

3.     We note your deletion of language in The Offering section on page 7
regarding when the
 Robert Bubeck
FirstName LastNameRobert Bubeck
Allure Worldwide, Inc.
Comapany NameAllure Worldwide, Inc.
March 6, 2020
March 6, 2020 Page 2
Page 2
FirstName LastName
         funds may be released from escrow when you filed the amended Form
S-1/A1 on January
         2, 2020. Please revise The Offering section to include the deleted
paragraph.
Directors, Executive Officers, Promoters and Control Persons, page 29

4.       Refer to prior comment 4. It remains unclear when Ms. McLaughlin was
also an officer
         and director of Atlantic Acquisition II, Inc., and Atlantic
Acquisition I, Inc. It is also
         unclear what were her and Mr. Bubeck's responsibilities at those
companies. Please
         clarify.
Certain Relationships and Related Transactions, page 33

5.       We reissue prior comment 5 in part. Please revise to indicate the
amount of consideration
         given for the shares in each of the noted transactions.
Financial Statements, page F-1

6.       Please include updated financial statements in your next amendment.
Please refer to Rule
         8-08 of Regulation S-X.
Report of Independent Registered Public Accounting Firm, page F-2

7.       We note your response to prior comment 7 from our letter dated
December 19, 2019. It
         does not appear that your filing has been revised to address this
comment; as such, it will
         be reissued. It appears that your auditor has included an explanatory
paragraph with
         respect to substantial doubt about the company's ability to continue
as a going concern.
         Please have your auditor revise the report to include this explanatory
paragraph
         immediately following the opinion paragraph, or tell us how this
placement is consistent
         with AS 2415.
General

8.       We note your response to prior comment 2; however, it is unclear how
any acquisition
         whether for stock or cash would have a fair value of at least $336,000
or 80 percent of the
         maximum offering proceeds, given your available assets, following the
proposed
         offering. Please provide an analysis of how you would fund such
acquisition that
         addresses the value of any stock you may use in such an acquisition
and explain how the
         value of such stock will be determined.




        You may contact William Demarest at 202-551-3432 or Jennifer Monick at
202-551-
3295 if you have questions regarding comments on the financial statements and
related
 Robert Bubeck
Allure Worldwide, Inc.
March 6, 2020
Page 3

matters. Please contact Ruairi Regan at 202-551-3269 or David Link at
202-551-3356 with any
other questions.



                                                         Sincerely,
FirstName LastNameRobert Bubeck
                                                         Division of
Corporation Finance
Comapany NameAllure Worldwide, Inc.
                                                         Office of Real Estate
& Construction
March 6, 2020 Page 3
cc:       Elaine A. Dowling, Esq.
FirstName LastName