July 29, 2024

George Athanasiadis
Chief Executive Officer
Eco Bright Future, Inc.
World Trade Center El Salvador
Calle El Mirador, 87 Ave Norte
San Salvador, El Salvador

       Re: Eco Bright Future, Inc.
           Amendment No. 1 to Registration Statement on Form 10
           Filed July 11, 2024
           File No. 000-56658
Dear George Athanasiadis:

       We have reviewed your filing and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

      After reviewing your response and any amendment you may file in response
to this letter,
we may have additional comments.

Amendment No. 1 to Registration Statement on Form 10
General

1.     Refer to your response to prior comments 2 and 3. We note that you
updated your
       "Present Operations" section to explain that your crypto assets do not
meet the Howey test
       and are therefore not "securities" within the meaning of Section 2(a)(1)
of the Securities
       Act. Please revise this section to describe the policies and procedures
that you followed to
       lead to that conclusion and the policies and procedures you will be
using moving forward.
       Additionally, please expand your risk factor on page 6 to have a more
fulsome discussion
       of the risks and limitations of your internal policies and procedures to
determine whether
       the crypto assets and crypto-asset related services and products you
offer or intend to offer
       are    securities    within the meaning of Section 2(a)(1). Also, please
provide us with a
       more detailed analysis regarding whether the crypto assets, and
crypto-asset related
       services and products you offer or intend to offer are "securities"
within the meaning of
       Section 2(a)(1) of the Securities Act. In this regard, we note your
response that you
 July 29, 2024
Page 2

       believe that "[y]our Tokenization process and current plans for
exchanging digital assets
       do not currently meet the Howey Test as the current items planned to be
tokenized are
       commodities." Please be advised that because an underlying asset is a
commodity does
       not mean that the crypto asset itself is not part of an investment
contract.
2.     Refer to your response to comment 4. Please provide us with a summary of
your analysis
       that led to your conclusion that you are not an investment company under
the Investment
       Company Act of 1940.
3.     Please revise to provide a definition of the term "tokenization" as used
in your registration
       statement, and provide a materially complete description of the
tokenization process, and,
       if applicable, your tokenization platform(s). Clarify which of your
existing projects
       involve tokenization as defined in the registration statement, and, to
the extent your
       projects differ, please describe the differences.
4.     Please revise throughout to clarify which products and services have
been developed,
       which are currently under development and which your are planning to
develop but have
       not yet begun development. For example, please disclose the phase of
development of
       each of your products and services in the UAE, Tunisia, El Salvador,
Thailand, Indonesia
       and Guatemala.
Business
Present Operations, page 1

5.     Please revise your disclosure on page 2 to clarify what mean by your
statement that you
       are "building an open source platform and developer infrastructure which
enables
       everyone to access and participate in the global economy and Real-World
Assets(RWA)
       tokenization."
6.     Refer to your response to prior comments 8 and 11. We note your revised
disclosure on
       page 2 that you "built a digital sugar exchange that has been tested and
used in Dubai
       (UAE)." Please revise to include disclosure that describes the digital
sugar exchange that
       you have developed, including, for example, disclosure regarding (i)
whether the digital
       sugar exchange is still operating in Dubai, as we note your disclosure
on page 4 that you
       plan to apply for licensing in the UAE, (ii) the mechanics of how you
mint the tokens and
       how the tokens are exchanged on your blockchain and platform, (iii) a
description of the
       information provided on your platform, (iv) a detailed description of
the tokenized Sugar
       Warrants that addresses the risks and characteristics of the Sugar
Warrants and the rights
       of the Sugar Warrant holders, (v) a description of the TradeFlow UAE
auditing software
       that is discussed in your June 18, 2024 letter, (v) a discussion of how
you earn revenues
       from your sugar exchange platform and the minting of the Sugar Warrants
and (vi) and
       your ongoing role in the operation of the sugar exchange platform. In
addition, your June
       18, 2024 letter states that you "issued a Digital Sugar Warrant for the
same volume
       secured by a paper warrant." In addition, disclose how the tokenized
Sugar Warrant is
       secured by the paper warrant, disclose whether you or Al Khaleej Sugar
has insurance for
       the underlying assets of the Sugar Warrants and, if so, describe the
degree to which such
       insurance protects the underlying assets.
7.     Refer to your response to prior comment 8. We note that you have
developed a
       proprietary blockchain, and it appears that this "blockchain assists the
[Tunisian]
       government in interfacing with a top telecom operator in Tunsia
(TOPNET)." Please
 July 29, 2024
Page 3

       revise to describe how the blockchain operates, whether the universa
blockchain is
       permissioned and your role in its operation, the crypto assets that the
blockchain supports,
       how you earn revenues in connection with the proprietary blockchain, and
the specific
       blockchain application that you provide to the Tunsinian government. In
addition, we note
       your disclosure that the "Tunisian Government is also looking at other
implementations of
       the universa blockchain throughout the country as they experience the
efficiency and
       organization universa blockchain provides." Please revise to clarify
that there is no
       guarantee that the Tunsinian government will purchase additional
products or services
       from you. Also disclose whether this is the same blockchain that you use
for all of your
       planned projects, including those already developed or currently in
development.
8.     Refer to your response to prior comment 9. We note that your amendment
includes a
       discussion on how you plan to raise capital and what your plans are if
you raise
       $25,000,000. Please revise to disclose what your growth strategy will be
at different
       amounts if you raise an amount lower than $25,000,000.
9.     Refer to your response to prior comment 10 that your plan for the
creation of crypto asset
       wallets is "to create infrastructure solutions for large corporate and
government customers
       in which end-users can use [y]our digital infrastructure to securely
transfer their rights to
       digital assets from one wallet to another." Please revise to describe in
greater detail the
       "infrastructure solutions" you create and the "end-users" that can use
your "digital
       infrastructure." We note your response that "your platform allows end
customers to create
       and store private keys on their computer without transferring them to
the system" and
       "that the digital assets themselves are not stored within [y]our digital
infrastructure."
       Please clarify whether you intend to develop and offer crypto asset
wallets that can hold
       the tokens you mint and clarify what you mean by "wallet activities."
10.    Refer to your response to prior comments 8, 11 and 12. We note your
disclosure regarding
       "your involvement . . . in digital asset tokenization." Please revise
your registration
       statement to describe the characteristics of any tokens that you have
minted or plan to
       mint, including the rights of the token holders, how many tokens you
have minted to date,
       how you conduct your AML/KYC procedures, whether you provide wallets for
such
       tokens or whether the tokens may be stored in third-party wallets. In
addition, we note
       your response that you have a planned platform related to the
tokenization of customer
       assets in El Salvador, including gold, coffee and real estate and that
the physical assets
       will be stored in a vault. Please provide detailed information regarding
how these assets
       will be stored, including the location or locations of the vault, where
the vault is located,
       whether you will use a third-party vault and, if so, the material terms
the agreement, and
       whether you have insurance that covers the underlying assets.
Additionally, please
       provide an expected timeline for the development of this product and a
description of the
       licenses and approvals you will need to obtain in order to offer this
product in El
       Salvador.
11.    Refer to your response to prior comment 13. Please revise to describe
the laws and
       regulations that have or will have a material impact on your business in
El Salvador,
       Thailand, Indonesia, Guatemala, United Arab Emirates and any other
jurisdictions
       material to your business or business plans, including a description of
the approvals and
       licensing requirements, when you applied or plan apply for such
approvals and
 July 29, 2024
Page 4

       licenses, and an estimate of the length of time it will take to obtain
any necessary
       approvals and licenses.
12.    Please revise to describe the steps you have taken or intend to take to
prevent
       unauthorized or impermissible customer access to your products and
services outside of
       the jurisdictions in which you have obtained or will obtain the
necessary licenses and
       authorizations to operate. Also include a risk factor that discusses the
material risks you
       face from such unauthorized or impermissible customer access to your
products and
       services. In addition, we note your disclosure on page 8 that "[i]t is
currently planned to
       not accept clients from certain jurisdictions," that "[t]hese
jurisdictions include the United
       States of America and European Union countries" and that "[t]he KYC
process will not
       allow individuals with passports from these jurisdictions to use [y]our
services." Please
       revise your disclosure to clarify what you mean by "clients." For
example, are you
       referring to the "large corporate and government customers" for whom you
intend to
       create infrastructure solutions or are you referring to individuals who
may wish to utilize
       your platform or purchase your crypto assets. Finally, please expand
your disclosure to
       clarify how you will restrict U.S. persons given that you are "building
an open source
       platform and developer infrastructure which enables everyone to access
and participate in
       the global economy and Real-World Assets(RWA) tokenization.
13.    Refer to your response to prior comment 14. Your June 18, 2024 letter
states you do not
       engage in crypto asset trading activities for your own account and that
you do not own
       crypto assets. Please revise your disclosure in this section
accordingly.
14.    Refer to your response to prior comments 8 and 12. On page 21, you
disclose that you
       intend to enter into agreements in connection with blockchain products
in Thailand,
       Indonesia and Guatemala. Please revise to disclose any agreements you
have already
       entered into with respect to those countries or explain the types of
agreements you intend
       to enter into.
15.    Refer to your response to prior comment 15. Please revise your
disclosure to describe the
       consulting services you offer and plan to offer. In this regard, we note
that your June 18,
       2024 letter states that you plan to provide consulting services for
large industrial
       corporations and government agencies on the ways product tokenization
and digitalization
       of the trading process can be properly implemented and that your
disclosure on page
       8 states that for the year ended December 31, 2023 you recognized
$32,132 in consulting
       revenue.
16.    Refer to prior comments 12 and 16. You disclose on page 3 that you
intend to implement
       an AI platform that will allow users "to book hotels, make reservations
at restaurants and
       other services directly from their wallet." Please revise to describe in
detail your plan for
       developing an AI engine, including the mechanics of how users can make
hotel and
       restaurant reservations "directly from their wallet," the steps involved
in developing the
       AI engine, the estimated timeline and the cost of each step, the sources
of capital for the
       development of the AI engine and any challenges you may face in the
development of the
       AI platform.
Risk Factors, page 2

17.    Refer to your response to prior comment 17. Please add separate risk
factors that address
       the specific risks related to operating and offering your products and
services in El
 July 29, 2024
Page 5

       Salvador, Tunisia, United Arab Emirates, Thailand, Indonesia and
Guatemala, including
       whether and how the regulatory regimes in these countries will
materially impact your
       business and ability to operate.
18.    Please revise to include separate risk factors that address the risks
related to "real world
       asset" tokenization, including the risks related to the storage of the
"real world assets,"
       including storage costs and the risks of destruction of the    real
world    assets, market risks
       related to the value of the underlying assets, and liquidity risks
related to the tokens.
Blockchain Technology carries with is certain risks and compliance issues, page
8

19.    Refer to your response to comment 18. Please revise this risk factor to
describe the "risks
       associated with cyber criminals and fraud throughout the world" and, in
a separate risk
       factor, describe any material risks to your business from regulatory
developments related
       to crypto assets and crypto asset markets in the jurisdictions in which
you operate and
       intend to operate. Also identify the specific regulations and material
pending regulations
       in the jurisdictions in which you operate and intend to operate, and
describe the material
       effects this may have on your business and business plans. Also add a
risk factor that
       discusses the risks and consequences related to the impairment of the
infrastructure used
       by your blockchain technology.
Directors and Executive Officers, page 11

20.    Refer to your response to prior comment 23. Please revise to provide the
dates that
       Mr. Athanasiadis and Mr. Stragar held the positions listed in "Recent
Work History" on
       page 11.
Footnotes to Consolidated Financial Statements
Note 1 - Organization and Significant Accounting Policies, page 21

21.    We acknowledge your response to our comment 26 and your revised
disclosure under
       Note 1. You disclose that the preferred shares represent 99.90% of the
total votes
       available to be cast. Under Item 4 on page 11 you state that the
preferred shares represent
       49% of the voting power of the company. Please reconcile these
statements to us, and
       explain to us how 49% of the total voting power represented by the
preferred shares
       transferred control of the company in the merger.
Concentrations, page 21

22.    We acknowledge your response to our comment 28 and the revised
disclosure under Note
       1, Concentrations. Please revise your disclosure to include the
geographic location in
       which your revenues were derived. If the revenues attributed to any
individual foreign
       countries are immaterial, please include a statement to that effect in
your disclosure. Refer
       to ASC 280-10-50-41.
Revenue Recognition Policy, page 22

23.    We acknowledge your response to our comment 30 and your expanded MD&A
disclosure
       on page 8. Please respond to the following:
           Tell us whether you intend to operate, maintain or otherwise
participate in the digital
           exchange services you describe on page 2, and whether you anticipate
a continuing
 July 29, 2024
Page 6

           revenue stream;
             If so, please tell us your expected accounting policy for
recognizing this revenue; and
             Describe for us, and disclose, your revenue recognition policies
for any other digital
           asset tokenization, trading, exchange, or digital wallet products
you expect to
           introduce within the next year.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Please contact Rolf Sundwall at 202-551-3105 or David Irving at
202-551-3321 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Austin Stanton at 202-551-2197 or Sonia Bednarowski at 202-551-3666
with any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Crypto
Assets