October 4, 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. 4 to Registration Statement on Form 10
           Filed September 4, 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. 4 to Registration Statement on Form 10
General

1.     We note your response to prior comment 1. Please revise your
registration statement to
       include a description of the processes you have in place for determining
whether your
       products are "securities" within the meaning of Section 2(a)(1) of the
Securities Act. For
       instance, disclose who makes that determination, whether legal counsel
is consulted and
       whether you plan to re-evaluate your products on a periodic basis. Based
on
       these processes, please expand your related risk factor to have a more
fulsome discussion
       of the risks and limitations of your review process.
2.     We note your response to prior comments 3 and 13. Please revise your
registration
       statement to make the disclosures we previously requested, including:
           the details and development status of the platforms and services
that you plan to offer
 October 4, 2024
Page 2

           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;
             the material terms of your material contracts in El Salvador and
any other
           jurisdictions and identify the parties to those contracts;
             a clarification as to the term "back end programming" that you use
on page 4; and
             for each jurisdiction in which you plan to operate, a description
of the licensing
           application process, 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 tell us why
           you believe that your operations in other countries will make your
ability to operate in
           Indonesia and Guatemala more likely.
3.     We note your response to prior comment 4. 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. For example, we note your revised
disclosure on page 13
       that "Guatemala is more established with their policies than many other
countries in
       regards to how they treat crypto asset markets but is still evolving and
regulations are
       being changed often" but you have not added a section that describes the
regulations or
       pending regulations in Guatemala that will impact your business
operations.
Prior Operations
Organizational History, page 2

4.     We note your response to prior comment 7. Your disclosure on page 2 that
the Universa
       Blockchain is a public blockchain that is available to the public
appears to be inconsistent
       with your disclosure that the Universa Blockchain is owned by Universa
Hub Africa
       and that is permissioned by Universa Hub Africa to the Tunisian
Government and your
       statement in your September 4, 2024 correspondence that Universa
Blockchain is the . . .
       blockchain that you have used as a private blockchain for Tunisia as
well as your
       description of your business throughout in which it appears that you
offer blockchain-as-
       a-service to corporations and governments. Please revise for clarity and
consistency. In
       addition, please revise to disclose the material terms of your agreement
with the Tunisian
       Government for the private blockchain.
5.     We note your revised disclosure on pages 2 and 3 regarding your
agreement with the
       Internet Agency of Tunisia for the National Tunisian Blockchain Network.
Please
       describe the material terms of the agreement, including your obligations
in connection
       with the agreement, how you earn revenues pursuant to the agreement and
the termination
       provisions of the agreement. Expand your description of National
Blockchain Network to
       describe the platform, your role in the platform, including the
blockchain services you
       provide, the mechanics of how a user gains access to the platform and
utilizes the
       platform to develop its business such as the certified digital signature
service provider you
       describe in your registration statement, the "latest technological
developments of Universa
       Blockchain" and your role regarding "future integrations." In addition,
we note your
       disclosure on page 3 that "[t]he next key points of the project are
planned to be the launch
       of a national DNS service on top of blockchain, a decentrali[z]ed
identity system,
 October 4, 2024
Page 3

       blockchain web services and several other services    and that    this
is expected sometime
       between September 2020 and January 2021." Please update your disclosure
to state
       whether these services were "launched" and describe the decentralized
identity system and
       any other services that have launched or that you plan to develop.
Finally, you state that
       the "[f]uture planned developments are oriented towards Smart Cities,
e-government and
       citizen-oriented services." Please briefly describe each of these
planned developments and
       disclose whether you have signed agreements with any parties in relation
to these planned
       developments.
6.     We note your disclosure that in December 2023 you completed a reverse
merger with
       Universa Hub Africa, a Tunisian Corporation. However, we have seen media
reports,
       including the one you cite in your registration statement on page 2,
that describes the
       Universa Hub Africa's platform as a "Russian platform." Please revise to
clarify the
       jurisdictions in which your subsidiaries are located and the
jurisdictions in which you
       operate.
7.     Please tell us the basis for your statement on page 2 that your
blockchain is one of the
       fastest and most secure blockchains in the world. Alternatively, please
remove this
       statement.
Present Operations, page 3

8.     We note your response to prior comment 5 and that you expect to earn
revenue from users
       of your open-source platform because "there will also be blockchain
transaction fees that
       will be paid to the Universa Blockchain for verification of
transactions." If your platform
       is open source, will entities that use a version of your technology be
able to remove or
       change this transaction fee requirement such that Universa Blockchain
does not receive
       any revenue? If so, please disclose this and if not, please explain how
this is possible with
       an open-source platform.
9.     We note your response to prior comment 6, your description of DMCC
Tradeflow and
       your statement that your sugar exchange tokenizes DMCC paper warrants.
Please revise
       your disclosure to describe the testing of your digital sugar exchange
with DMCC
       Tradeflow and the results of the test. Please also clarify what you mean
by the
       tokenization of the DMCC    paper warrants    as you disclose that the
DMCC creates
       electronic negotiable instruments (the    DMCC Tradeflow Warrants   )
and that the DMCC
       Tradeflow Warrants are electronically transferred between users using a
web-based
       interface. In addition, please expand your disclosure to explain how
your platform and the
       DMCC work together to prevent issues like double spending, and 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, and (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. 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. Also, we note your disclosure that you have not yet
applied for
       licensing in the UAE and that you do not have any contracts in place
with the UAE.
       Please clarify whether to operate the sugar exchange in the UAE you will
need to obtain a
       license and execute agreements with DMCC Tradeflow.
 October 4, 2024
Page 4

10.    We note your response to prior comment 7. Please revise your disclosure
to include a
       description of the Universa Blockchain, including, but not necessarily
limited to, whether
       it is public or permissioned, the consensus mechanism used by the
blockchain, the number
       of transactions that the blockchain can accommodate per minute, the
types of crypto
       assets that can be created and transferred on the blockchain and how
changes are made to
       the blockchain.
11.    We note your response to prior comment 10. Please revise to disclose the
material terms
       of your agreement with the Bank of Abu Dhabi and the DMCC related to the
gold
       tokenization, describe the wallets you will offer and whether you will
hold the private
       keys for such wallets. If you will hold the private keys for such
wallets, disclose whether
       you will use a third-party custodian for the private keys and whether
these will be stored
       in cold or hot storage, disclose how an end-user could prove ownership
without the token
       and how discrepancies between the blockchain and other proofs of
ownership are
       resolved. Additionally, please explain whether the gold bar tokens will
be able to be split
       by users and traded in a manner such that less than one gold bar is
changing hands at a
       time. If so, please explain how redemption of the underlying gold bar
would function.
12.    We note your response to prior comment 11 and the role that SumSub plays
in your KYC
       and AML process. Please revise your registration statement to include a
risk factor that
       discusses the material risks you face from unauthorized or impermissible
customer access
       to your products and services by those who circumvent your KYC and AML
process. In
       addition, we note your disclosures on page 4, 14 and 50 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, clarify whether
       you are you referring to the "large corporate and government customers"
for whom you
       intend to create infrastructure solutions or if you are referring to
individuals who may
       wish to utilize your platform or purchase crypto assets using the
blockchain services you
       provide. 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.    We note your response to prior comment 12. Your disclosure on page 3
that you are
       involved in "digital asset trading" is inconsistent with your revised
disclosure on page 3
       that "[t]he company is does not engage in crypto asset trading." Please
revise for clarity
       and consistency.
14.    We note your response to prior comment 15. Please revise your
registration statement to
       include the information you provided in your September 4, 2024 response,
including the
       status of your plans for the AI service. In this regard, we note you
state that a substantial
       amount of the code is written for your AI platform. If known, please
describe how the AI
       platform will operate, 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, the mechanics of how users can make hotel and restaurant
reservations
       "directly from their wallet" and how you intend to earn revenues from
this product. To the
 October 4, 2024
Page 5

       extent that you have not yet finalized your plans for how the AI
platform will function,
       please disclose.
Risk Factors, page 8

15.    We note your response to prior comment 16 and your updated risk factors.
For each
       jurisdiction you plan to operate in, please identify the regulations and
material pending
       regulations that will impact your business and describe the material
effects each such
       regulation and pending regulation may have on your business and business
plans. In this
       regard, we note that you refer generally to the existence of rules and
regulations
       in each jurisdiction but do not address specific regulations or pending
regulations. In
       addition, please revise your "Blockchain Technology carries with is
certain risks and
       compliance issues" risk factor on page 13 to expand your description of
the "[f]raudulent
       activities and 'hacking wallets'" by providing specific examples of such
fraudulent
       activities and an explanation of what 'hacking wallets' means.
We have a potential requirement to register, page 11

16.    We note your response to prior comment 17. Please be advised that the
Howey test is
       not the determinative test as it relates to whether you meet the
definition of an
       "investment company" for purposes of the Investment Company Act of 1940.
As such,
       please provide to us an analysis of why you believe you may meet the
definition of an
       "investment company" in the future, and revise this risk factor to
include a summary of
       the reasons you identify in the analysis.
Financial Information
Management's Discussion and Analysis of Financial Condition and Results of
Operation, page 14

17.    Please revise your next amendment to include a discussion of the results
of operations for
       the three and six month periods ended June 30, 2024. Refer to Item 303
of Regulation S-
       K.
18.    You disclose on page 15 that the insurance on the gold in your agreement
with the Bank
       of Abu Dhabi is held by the bank and the government of the UAE, and we
note your
       response to prior comment 10 stating that the insurance would not be
liable if an end user
       could not prove ownership of a token. Please describe for us your
liability in the event of
       a security breach on your blockchain or if an end user could not prove
ownership of a
       token.
19.    Please tell us the native token for your blockchain. Further, tell us
the value of the Real
       World Assets, such as under your sugar or gold tokenization agreements,
you have
       tokenized on your blockchain.
20.    Please tell us how you recognize the blockchain in your financial
statements, and whether
       you consolidate the blockchain and related activities.
Business Operations, page 14

21.    We note your response to prior comment 9. Your disclosure on page 14
that the tools you
       are developing will allow integration to other blockchains is
inconsistent with your
       revised disclosure that you have no plans to implement other blockchains
within your
       ecosystem. Please revise for clarity and consistency. Similarly, your
disclosure that you
 October 4, 2024
Page 6

       have not finalized the open-source options that will allow integration
into other wallets
       appears to be inconsistent with your disclosure that "[y]our blockchain
can be used with
       other developed wallets." Please revise for clarity and consistency. In
addition, please
       disclose the "open-source options" you have not yet completed and
describe the wallets
       that you offer and intend offer to users of the platform, including
whether you maintain
       the private keys, and, if so, whether you use a third-party custodian to
hold the private
       keys and whether the private keys are held in cold or hot storage.
Footnotes to Consolidated Financial Statements
Note 1 - Organization and Significant Accounting Policies, page 31

22.    We acknowledge your response to our comment 18. Please respond to the
following:
           Provide to us your accounting analysis supporting your
representation that less than
          50% of outstanding voting rights transferred control in the merger.
Refer to specific
          accounting guidance in your response; and
           Revise your disclosure in note 1 as indicated in your response.
Financial Statements For the Three Months Ended March 31, 2023, page 43

23.    Please remove old financial statements, footnotes, and management's
discussion and
       analysis of financial condition and results of operations (MD&A) from
future
       amendments. We note you included March 31, 2023 financial statements,
footnotes and
       MD&A on pages 43-52.
Form 10-Q for the Fiscal Quarter Ended June 30, 2024
Notes to Consolidated Financial Statements, page 5

24.    We acknowledge your response to prior comment 20, but do not note any
additional
       disclosure related to your intangible asset policies in the Form
10-12g/A or to the $4,800
       of intangible assets reported on your June 30, 2024 balance sheet.
Please provide draft
       disclosure to be included in future periodic filings, and revise your
next amendment to the
       Form 10 to include accounting policies and footnote disclosure, as
appropriate, for all
       material items in the financial statements, and in particular the
intangible assets reported
       on your balance sheet as of June 30, 2024.
Item 4. Controls and Procedures, page 11

25.    We acknowledge your response to prior comment 21. Please provide draft
disclosure to be
       included in future periodic reports describing in more detail the
significant deficiency in
       your internal controls, how you determined the significant deficiency
did not result in a
       material weakness, and your planned remediation of the deficiency in
your internal
       controls.
 October 4, 2024
Page 7

        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