TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo February 9, 2021 Joseph Francella Chief Executive Officer Limitless Venture Group Inc. 121 E. 36th Street Tulsa, OK 74106 Re: Limitless Venture Group Inc. Offering Statement on Form 1-A Post-qualification Amendment No. 4 Filed February 5, 2021 File No. 024-11128 Dear Mr. Francella: We have reviewed your amendment and have the following comment. In our comment, 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 comment applies 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 this comment, we may have additional comments. Post-qualification Amendment No. 4 to Form 1-A filed February 5, 2021 Item 7. Description of Business, page 15 1. We note your response to prior comment 1 and revised disclosure and reissue in part. We note that you filed your agreement to acquire KetoSports, Inc. but have not filed your agreement to acquire Rokin, Inc. Please file your material acquisition agreements as an exhibit to the offering circular or tell us why it is not material. Refer to Item 17 of Part III to Form 1-A. We will consider qualifying your offering statement at your request. If a participant in your offering is required to clear its compensation arrangements with FINRA, please have FINRA advise us that it has no objections to the compensation arrangements prior to qualification. We remind you that the company and its management are responsible for the accuracy Joseph Francella Limitless Venture Group Inc. February 9, 2021 Page 2 and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Jason L. Drory at 202-551-8342 or Celeste Murphy at 202-551-3257 with any questions. Sincerely, FirstName LastNameJoseph Francella Division of Corporation Finance Comapany NameLimitless Venture Group Inc. Office of Life Sciences February 9, 2021 Page 2 cc: Thomas C. Cook FirstName LastName