August 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. 3 to Registration Statement on Form 10
           Filed August 9, 2024
           Form 10-Q for the Fiscal Quarter Ended June 30, 2024
           Filed August 13, 2024
           File No. 000-56658
Dear George Athanasiadis:

       We have reviewed your filings 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. 3 to Registration Statement on Form 10
General

1.     We note your revised disclosure in response to prior comment 1. Please
revise to include a
       more detailed description of your process for determining whether your
products are
       "securities" within the meaning of Section 2(a)(1) of the Securities
Act. Also, please
       expand your risk factor on page 7 to have a more fulsome discussion of
the risks and
       limitations of your review process to determine whether the crypto
assets and crypto
       asset-related services and products you intend to offer are
securities    within the meaning
       of Section 2(a)(1). In this regard, we note your response that you
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."
 August 29, 2024
Page 2

       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.     We note your revised disclosure in response to prior comment 3. Please
revise your
       registration statement to expressly define the term "tokenization" as it
is used in the
       registration statement.
3.     We note your response to prior comments 4 and 11. Please revise your
registration
       statement to disclose the details and development status of the
platforms and services that
       you plan to offer in the UAE, El Salvador, Thailand, Indonesia and
Guatemala, including
       a detailed timeline of the remaining steps in the development of the
platforms and
       services, the estimated costs of each step and the sources of funding
for each of these
       steps. In this regard, we note your disclosure on page 2 that "[t]here
are no current
       contracts in place other than El Salvador." Please revise to disclose
the material terms of
       your agreements in El Salvador and identify the parties to the
agreements. Also, please
       clarify what you mean on page 2 by "back end programming," and please
describe the
       "integrations" that you are currently programming or plan to program for
the products and
       services offered in each jurisdiction. In addition, please describe the
application for
       licensing in the UAE, Thailand and El Salvador, including an estimate of
the time it will
       take you to obtain the necessary licenses to operate in the UAE,
Thailand and El Salvador,
       and disclose when you plan to obtain licenses for operations in
Indonesia and Guatemala.
4.     Refer to your response to comment 11. Please add a section that
describes the laws and
       regulations that have or will have a material impact on your business in
El Salvador,
       Thailand, Indonesia, Guatemala, the UAE, Tunisia and any other
jurisdictions material to
       your business or business plans, including a detailed description of the
approvals and
       licensing requirements for each.
Business
Present Operations, page 2

5.     We note your response to prior comment 5. Please revise your disclosure
here or on page
       9 to describe the "open source platform and developer infrastructure"
that you plan to
       release and how you intend to earn revenues from the "open source
platform and
       developer infrastructure."
6.     We note your response to prior comment 6 and your description of the
status and
       mechanics of the sugar exchange in your August 9, 2024 correspondence.
Please revise
       your registration statement to include the details you provided to us
and explain how your
       sugar exchange integrates with the DMCC Tradeflow. Additionally, please
include
       disclosure regarding (i) the mechanics of how the tokens are exchanged
on your
       blockchain and platform, (ii) a description of the information provided
on your platform,
       (iii) 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, and (iv)
       your ongoing role in the operation of the sugar exchange platform. In
addition, your June
       18, 2024 correspondence states that you "issued a Digital Sugar Warrant
for the same
       volume secured by a paper warrant." Please tell us what you mean by this
statement.
7.     We note your response and revised disclosure related to prior comment 7.
Please revise
       your registration statement to include the information you provided to
us in your August
       9, 2024 correspondence and further disclose how the universa blockchain
operates,
 August 29, 2024
Page 3

       whether the universa blockchain is publicly accessible, and the specific
blockchain
       applications that you provide to the Tunisian government. Also disclose
whether this is
       the same blockchain that you intend to use for all of your planned
projects, including
       those already developed or currently in development. Further, please
disclose the material
       terms of your agreement with the Tunisian government.
8.     Refer to your response to prior comment 8. Please revise to describe in
detail your growth
       strategy for different amounts that you may raise in offerings of your
securities. For
       example, describe your growth strategy if you raise less than
$5,000,000, $5,000,000 or
       12,500,000.
9.     We note your response to prior comment 9. Please revise here or on page
9 to clarify what
       you mean by your disclosure that the tools include code that will allow
integration to
       "other" wallets and "other" blockchains by disclosing whether you are
referring to third-
       party wallets and third-party blockchains. In addition, (i) disclose
whether the tools you
       describe on page 9 are in development or are have already been
developed; (ii) include an
       overview of the functions of these tools; and (iii) identify the "end
users" that can use
       your "digital infrastructure" on page 3. Additionally, please clarify
whether you have
       developed or intend to develop crypto asset wallet software that enables
an "end user" to
       receive and exchange the crypto assets that you or your clients mint as
well as other types
       of crypto assets. Also clarify what you mean by "wallet activities."
10.    We note your response to prior comment 10 and your disclosure related to
your
       tokenization process. Please revise your registration statement to
include the information
       you provided to us in your August 9, 2024 correspondence regarding the
gold tokens you
       plan to create in the UAE. In addition, please disclose the material
terms of the custody
       agreement with the DMCC, disclose the mechanics of how the tokens
representing the
       gold will be transferred, the rights of the holders of the tokens, the
degree to which the
       insurance will protect the underlying assets of the tokens and the
AML/KYC procedures
       of SumSub and whether you intend to use SumSub for all of your AML/KYC
procedures.
       Additionally, please disclose (i) whether you provide wallets for such
tokens or whether
       the tokens may be stored in third-party wallets,(ii) an estimated
timeline for the
       development of this product, (iii) an estimate of the costs associated
with the development
       of this product, including the sources of capital, and (iv) a
description of the licenses and
       approvals you will need to obtain in order to offer this product in the
UAE. We also note
       your disclosure that you plan to offer similar "Real-World Assets"
tokenization in El
       Salvador, Thailand and other jurisdictions. Please disclose the assets
you currently intend
       to offer such services for in each of the jurisdictions you intend to
operate.
11.    We note your response to prior comment 12 and the revisions to your
registration
       statement related to your KYC and AML protocols. Please revise your
registration
       statement to provide greater detail on the systems and procedures that
your KYC service
       provider employs. Additionally, please 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 9 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
 August 29, 2024
Page 4

       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.
12.    We note your response to prior comment 13 directing us to the "Present
Operations"
       section. There, you state that the company "is also involved in digital
asset tokenisation
       and digital asset trading." Please revise your registration statement to
clarify that you do
       not engage in crypto asset trading activities for your own account and
that you do not own
       crypto assets.
13.    We note your response to prior comment 14. Please revise your
registration statement to
       (i) disclose the material terms of your agreement with El Salvador,
Tunisia and any other
       material executed agreements and (ii) explain the types of agreements
you intend to
       execute with other governments or companies related to the services and
products you
       intend to provide.
14.    Refer to your response to prior comment 15. We note that you are
currently acting as
       a consultant to TOPNET in Tunisia and your statement in your June 18,
2024
       correspondence 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. Please revise your
disclosure to
       describe the consulting services you currently offer and plan to offer.
In this regard, we
       note your description in your August 9, 2024 correspondence.
15.    We note your response to prior comment 16 and your revised disclosure
regarding the
       status of your AI platform. Please revise to describe in detail the how
your AI platform
       operates and the estimated costs of advertising the platform and
integrating the reservation
       systems to your blockchain as well as any other costs associated with
offering this
       product. For example, please identify the jurisdictions in which you
plan to offer this
       product and whether you will need to obtain licenses or approvals to
offer this product in
       those jurisdictions. In addition, please describe in detail the
mechanics of how users can
       make hotel and restaurant reservations "directly from their wallet" and
disclose how you
       intend to earn revenues from this product.
Risk Factors, page 4

16.    We note your response to prior comments 17 and 19 and your revised
disclosure on pages
       7 and 8. Please add separate risk factors that describe the risks to
your business from the
       regulations and regulatory developments related to crypto assets, the
crypto asset markets
       and artificial intelligence products in the jurisdictions in which you
operate and intend to
       operate, identify the specific regulations and material pending
regulations, and describe
       the material effects each such regulation and pending regulation may
have on your
       business and business plans. In addition, please revise your "Blockchain
Technology
       carries with is certain risks and compliance issues" risk factor on page
7 to expand your
       description of the "risks associated with blockchain[s] due to cyber
criminals and fraud
       throughout the world" by providing specific examples of such risks.
 August 29, 2024
Page 5

We have a potential requirements to register as an investment company, page 7

17.    Refer to your response to comment 2. Please provide to us an analysis of
why you may
       be required to register as an investment company in the future, and
revise to include a
       summary of the reasons in your risk factor on page 7.
Footnotes to Consolidated Financial Statements
Note 1 - Organization and Significant Accounting Policies, page 22

18.    Your letter did not include a response to prior comment 21. We therefore
reissue the
       comment:
       We acknowledge your response to our comment 26 from our letter dated
June 11, 2024,
       and your revised disclosure under Note 1. You disclose that the
preferred shares represent
       99.9% of the total votes available to be cast. Under Item 4 on page 12
you disclose 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.
Revenue Recognition Policy, page 23

19.    Your letter did not include a response to prior comment 23. We therefore
reissue the
       comment:
       We acknowledge your response to our comment 30 from our letter dated
June 11, 2024,
       and your expanded MD&A disclosure on page 9. 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
           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.

Form 10-Q for the Fiscal Quarter Ended June 30, 2024
Notes to Consolidated Financial Statements, page 5

20.    Please revise future filings to include accounting policies for all
material items on the
       financial statements. Specifically, include accounting policies, and
separate footnote
       disclosure as necessary, for Intangible Assets in your next periodic
filing and in your
       Form 10-12G/A when updated to include financial information for the 3-
and 6-months
       ended June 30, 2024.
Item 4. Controls and Procedures, page 11

21.    We note you identified a significant deficiency in your internal
controls in the period
       ended June 30, 2024. Please provide us more information surrounding this
significant
       deficiency, including the nature of the significant deficiency, how you
determined this
       significant deficiency did not result in a material weakness over
internal controls, and the
       steps you have taken and put into place, to resolve the significant
deficiency. Refer to
       Item 308 of Regulation S-K.
 August 29, 2024
Page 6

        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