November 22, 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. 5 to Registration Statement on Form 10
           Filed October 21, 2024
           File No. 000-56658
Dear George Athanasiadis:

       We have reviewed your amended 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. 5 to Registration Statement on Form 10
General

1.     Please revise your disclosure throughout to clarify:
           your ability to earn revenue prior to obtaining the necessary
licenses and highlight
           your revenue and net losses along with the risk to your business if
the licenses to
           operate are not approved in El Salvador, Thailand, Indonesia,
Guatemala, the
           UAE, Tunisia and any other jurisdictions material to your current
business plans
           or if you are unable to obtain the necessary capital to begin
operations;
           the status of the licenses needed to begin operations, including the
status of the
           digital license agreement with the bank in Thailand along with a
description of the
           material terms of the licensing agreement and the identity of the
bank;
           the wallets that you intend to offer to users of your platform; and
 November 22, 2024
Page 2

             when the national DNS service will be launched, as you disclose on
page 3 that it
           is expected to be launched sometime between September 2020 and
January 2021.
2.     We note your response to prior comment 1. Please revise to include
disclosure related
       to your processes and procedures for monitoring your products'
compliance with
       Section 2(a)(1) of the Securities Act. For example, please include
disclosure
       explaining who conducts your Howey test analysis when the need arises,
whether your
       process involves consulting legal counsel and whether your process
includes any other
       steps.
Prior Operations
Organizational History, page 2

3.     We note your response to prior comment 5. Your disclosure that you do
not have
       ongoing agreements with Tunisia other than your contracting service is
inconsistent
       your disclosure on page 2 that states that "[c]urrently, The Internet
Agency of Tunisia
       (ATI) has partnered with Universa Hub Africa" and that "ATI sign[ed a]
10 year
       partnership with 'Universa Hub Africa.'" Please revise for clarity and
consistency, and
       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.
Present Operations, page 7

4.     We note your disclosure on page 3 that you have an agreement with a
Digital Asset
       Service Provider in El Salvador that will allow you to tokenize certain
assets and
       commodities. Please disclose the material terms of the Digital Asset
Service Provider
       agreement and include this contract as an exhibit to your registration
statement or tell
       us why this is not necessary.
5.     We note your response to prior comment 9. Please describe the material
terms of the
       partnership agreement with Al Khaleej Sugar, including your role in the
partnership
       and how you earn revenue or will earn revenue pursuant to the
partnership agreement.
       In addition, revise to disclose the following:
           the mechanics of how tokens are exchanged on the Digital Sugar
           Exchange platform;
           a description of the tokenized Sugar Warrants that addresses the
risks and
           characteristics of the Sugar Warrants and the rights of the Sugar
Warrant holders;
           how your platform and the DMCC work together to prevent issues like
double
           spending;
           to the extent that the sugar exchange is operational, quantitative
information
           regarding the number of transactions recorded and the value of the
tokenized
           Sugar Warrants as compared to the underlying asset; and
           provide consistent disclosure throughout regarding whether or not
you have
           obtained the necessary licenses to offer your products and services
in the UAE.
           For example purposes only, please see your disclosure on page 5 as
compared to
           your disclosure regarding your partnership with Al Khaleej Sugar and
the DMCC.
 November 22, 2024
Page 3
6.     We note your revised disclosure on page 4 that "[t]he custody will be
with the
       government or business providing the token or will be held by the end
user in their
       wallet or stored locally on their personal device." Please revise to
clarify what you
       mean by "end user" and explain whether and how tokens will be restored
in the case
       of a lost device. In this regard, we note your disclosure that "[i]n
case of loss of device
       there is a record that the end user can access by verifying their
identity."
7.     We note your response to prior comment 11. Please disclose the material
terms of
       your agreement with the Bank of Abu Dhabi and the DMCC related to gold
       tokenization. In addition, disclose how an end-user will be able to
prove ownership
       without the token and how discrepancies between the blockchain and other
proofs of
       ownership will be resolved. Also please revise to clarify what you mean
by your
       disclosure on page 9 that "Network is stored the full history of
transactions, including
       hash of both receiver and sender, which would allow [you] to find all
information
       needed for KYT . . . procedures."
8.     We note your response to prior comment 12 and your added risk factor
related to
       failures of your KYC/AML program. 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    with an
explanation
       specifically focused on the open-source nature of your blockchain and
the difficulties
       inherent to that characteristic when it comes to restricting use.
Management's Discussion and Analysis of Financial Condition and Results of
Operation,
page 17

9.     We acknowledge your response to prior comment 19 and your revised
disclosure of
       your present operations on pages 7-9. In your response and disclosure,
you disclose a
       partnership with Al Khaleej Sugar and DMCC to launch the digital sugar
exchange -
       Universa Digital Sugar Trading DMCC - and disclose similar plans
regarding your
       agreement for gold tokenization with NewCo Gold Trading DMCC. Please
respond
       to the following:
           Clarify for us whether Universa Sugar Trading DMCC and Universa Gold
           Trading DMCC are distinct legal entities.
           Describe for us the ownership structure of Universa Sugar Trading
DMCC
           and Universa Gold Trading DMCC and tell us who controls and
consolidates the
           entities. Also, tell us if NewCo Gold Trading DMCC and Universa Gold
Trading
           DMCC are the same entity.
           Confirm our understanding that the DMCC Tradeflow warrant conveys
ownership
           of the underlying commodities.
           You disclose in response to prior comment 11 and in your disclosure
on page 7
           that title of the warrant for sugar and gold is transferred to
Universa Sugar
           Trading DMCC and Universa Gold Trading DMCC, respectively. Clarify
for us
           if you take title of the warrant indirectly through control of
Universa Sugar
           Trading DMCC and Universa Gold Trading DMCC. Additionally, to the
           extent Universa Sugar Trading DMCC and Universa Gold Trading DMCC
are not
           legal entities, explain to us how those entities are able to take
title to warrants.
 November 22, 2024
Page 4

             Clarify for us whether any consideration was exchanged at the time
title to the
           warrant was conveyed to Universa Digital Sugar Trading DMCC or will
be
           exchanged at the time the warrant will be conveyed to Universa Gold
Trading
           DMCC.
             Confirm for us whether the digital token represents legal
ownership of the
           warrant.
             Clarify for us the legal rights and obligations associated with
the warrants and
           related digital tokens.
             Tell us which entity sells the tokens to the end user.
             Explain to us your involvement, if any, with secondary
transactions on the digital
           gold trading platform, and tell us if there is a similar platform
for the sugar
           exchange.
10.    We acknowledge your response to prior comment 20. In your response, you
state that,
       in the future, you will recognize blockchain activities on a
consolidated basis. Please
       clarify what you mean by    blockchain activities    in your response.
In addition, given
       you have previously tokenized sugar and have plans to tokenize gold,
explain to us
       why you do not currently recognize blockchain activities on a
consolidated basis.
        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