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                               April 30, 2020

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

                                                        Re: Allure Worldwide,
Inc.
                                                            Amendment to
Registration Statement on Form S-1
                                                            Filed April 15,
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 April
3, 2020 letter.

       Amendment to Form S-1 filed April 15, 2020

       The Offering, page 7

   1.                                                   We note no revisions
have been made in response to prior comment 4; therefore, we
                                                        reissue the comment.
Please revise to add the following two sentences which were
                                                        deleted to the bottom
of the third paragraph on page 8 in The Offering section "Unless
                                                        80% of investors elect
to remain investors, all investors will be entitled to the return of a
                                                        pro rata portion of the
Deposited Funds (without interest) and none of the Deposited
                                                        Securities will be
issued to investors. In the event an acquisition is not consummated
                                                        within 18 months of the
effective date of this prospectus, the net Deposited Funds will be
                                                        returned on a pro rata
basis to all investors."
 Robert Bubeck
Allure Worldwide, Inc.
April 30, 2020
Page 2


Part II
Exhibits and Financial Statement Schedules, page II-2

2.     Please file a copy of the executed escrow agreement as an exhibit to the
registration
       statement. We may have further comment.
Exhibit 23, page II-2

3.     Please obtain and file as Exhibit 23 an updated consent from your
independent
       auditors. To the extent the consent references a specific amendment,
please ensure that it
       references the current amendment.
Signatures, page II-5

4.     Please revise to add the following statement, in the appropriate
location, on your
       signatures page "Pursuant to the requirements of the Securities Act of
1933, this
       registration statement has been signed by the following persons in the
capacities and on
       the dates indicated."
        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
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
April 30, 2020 Page 2
cc:       Elaine A. Dowling, Esq.
FirstName LastName