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                              November 15, 2021

       Marina Konstantinova
       Chief Executive Officer
       Orion Bliss Corp.
       Ashdod
       Kalonite 9-57
       Israel
       7724233

                                                        Re: Orion Bliss Corp.
                                                            Amendment No. 3 to
Registration Statement on Form S-1
                                                            Filed November 4,
2021
                                                            File No. 333-257326

       Dear Ms. Konstantinova:

             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
September 21, 2021 letter.

       Amendment No. 3 to Registration Statement on Form S-1

       Cover Page

   1.                                                   We note your response
to comment one, which includes cover page disclosure that you
                                                        will be placing
proceeds from the offering in an escrow, trust or similar account. Please
                                                        indicate the specific
type of account you intend to use to deposit the funds, an escrow
                                                        account, a trust
account or a similar type of account. Your filing should clarify your
                                                        ability to access the
funds prior to and following the completion of the offering, by
                                                        clarifying applicable
escrow or trust provisions. Similarly, revise the two risk factors on
                                                        page 9 to clarify the
type of account and ensure that the consequences relating to the type
 Marina Konstantinova
FirstName
Orion BlissLastNameMarina    Konstantinova
            Corp.
Comapany 15,
November   NameOrion
               2021    Bliss Corp.
November
Page 2     15, 2021 Page 2
FirstName LastName
         of account are clear. Please also update the "Plan of Distribution" on
page 17 to describe
         the circumstances under which the proceeds will be released from the
escrow account
         and/or the terms of the trust agreement, if applicable.
Description of Our Business, page 19

2.       We note your revisions in response to prior comment 3 and reissue in
part. Please
         revise to provide a summary in this section of the material terms of
the contract with your
         supplier, Red Hot Products Ltd. It is not clear from the terms of the
agreement that you
         have filed as Exhibit 10.3 that you have agreed to buy any Milk_shake
products from the
         supplier and the supplier has committed to sell any Milk_shake
products to you. To the
         extent that there are no specific commitments for you to purchase
products or for Red Hot
         Products to sell products to you, please clarify the absence of such
commitments in your
         disclosure. Additionally, disclose in this section whether you are
able to sell the products
         you purchase from the supplier anywhere or whether you are limited to
a particular
         geographic region under the contract. We note your disclosure that you
will be purchasing
         products directly from the developer on page 4 yet it appears that Red
Hot Products Ltd is
         a distributor. Please revise or advise.
Unaudited Interim Financial Statements
Balance Sheet, page F-12

3.       Please revise to clearly label the periods as audited and unaudited
for all of your interim
         financial statements, including the index at F-11.
Statement of Operations (Unaudited), page F-13

4.       Please revise your statements of operations and cash flows to only
present the current
         period rather than from inception, i.e. only the three months ended
July 31, 2021, in
         accordance with Rule 10.01(a)(7) under Regulation S-X. Please make the
corresponding
         change to the title of your notes as well. Please note that ASC 915
Development Stage
         Entities was superseded by ASU No. 2014-10, which removed the
definition of a
         development stage entity from Topic 915, thereby removing the
distinction between
         development stage entities and other reporting entities from U.S.
GAAP. As such, please
         also remove your references of a development stage company at F-8 and
F-17.
Note 3. Summary of Significant Accounting Policies
Basis of Presentation, page F-16

5.       In accordance with Rule 10.01(b)(8) of Regulation S-X, please include
a statement to the
         effect that the unaudited interim financial statements reflect all
adjustments which are, in
         the opinion of management, necessary to a fair statement of the
results for the interim
         periods presented. Address whether all adjustments are of a normal
recurring nature.
       You may contact Li Xiao at 202-551-4391 or Al Pavot at 202-551-3738 if
you have
questions regarding comments on the financial statements and related matters.
Please contact
 Marina Konstantinova
Orion Bliss Corp.
November 15, 2021
Page 3

Ada Sarmento at 202-551-3798 or Suzanne Hayes at 202-551-3678 with any other
questions.



                                                        Sincerely,
FirstName LastNameMarina Konstantinova
                                                        Division of Corporation
Finance
Comapany NameOrion Bliss Corp.
                                                        Office of Life Sciences
November 15, 2021 Page 3
cc:       Mont E. Tanner, Esq.
FirstName LastName