United States securities and exchange commission logo





                             July 19, 2022

       Joseph Richard Moran
       Chief Executive Officer
       Blue Chip Capital Group Inc.
       269 South Beverly Drive     Suite 373
       Beverly Hills, CA 90212

                                                        Re: Blue Chip Capital
Group Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted June 22,
2022
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted July 1,
2022
                                                            CIK No. 0001932213

       Dear Mr. Moran:

              We have reviewed your draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

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

       Cover page

   1.                                                   We note your disclosure
regarding the possible quotation of your securities on the OTC
                                                        Market. Please revise
this disclosure prior to effectiveness to provide more details
                                                        regarding the potential
quotation or listing, such as the status of any applications for
                                                        listing that you have
made. Please also reconcile your disclosure with the last risk factor
                                                        on page 12 referencing
the possible listing of your securities on the "Nasdaq Stock Market
                                                        or on another national
securities exchange."
 Joseph Richard Moran
FirstName  LastNameJoseph
Blue Chip Capital Group Inc.Richard Moran
Comapany
July       NameBlue Chip Capital Group Inc.
     19, 2022
July 19,
Page  2 2022 Page 2
FirstName LastName
2.       Please disclose on the cover page that following the offering you will
be a "controlled
         company." Include a cross-reference where you describe the definition
and ramifications
         of being a "controlled company" in a new risk factor as well.
Prospectus Summary, page 2

3.       We note your disclosure at the top of page 2 referencing the company's
name
         as "Investview, Inc.," which appears to be a clerical error. Please
revise or advise.
4.       Please prominently disclose here that you have incurred net losses in
each fiscal quarter
         since inception and that your auditors have expressed substantial
doubt about your ability
         to continue as a going concern, as disclosed elsewhere.
Our Business, page 2

5.       Please provide support for your assertions and descriptions of Lending
Club, Funding
         Circle Holdings PLC and SeedInvest. If these statements are solely
your opinions, please
         clearly state as such.
6.       We note your disclosures in this section and in the Business section
regarding your named
         competitors. Please provide more details regarding how you are
currently competing with
         these companies when it does not appear that you have begun
operations.
7.       Please provide more details regarding what your intellectual
properties center upon and
         how that can be monetized. Include a discussion of the term "White
Labeling," as
         referenced on page 6.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
25

8.       Please revise your next amendment to discuss interim period results as
required by Item
         303 of Regulation S-K.
9.       We note your disclosure on page 25 that you have, "ongoing and pending
contracts that
         are expected to generate operating cash to support operations well
into 2022" despite the
         fact that you do not appear to have any revenues from operations. We
further note your
         liquidity disclosure that you, "have cash reserves and cash
commitments available to fund
         operations through the end of the year or longer." Please revise your
next amendment to
         address the disclosure requirements in Item 303 of Regulation S-K
regarding liquidity.
         Specifically, address your ability to meet requirements in the
short-term (the next 12
         months from the most recent fiscal period end) and in the long-term
(beyond the next 12
         months).
Plan of Distribution, page 34

10.      We note your disclosure regarding the potential use of placement
agents and that you
         intend to utilize multiple closings of your offering. Please revise
your disclosure to clarify
 Joseph Richard Moran
FirstName  LastNameJoseph
Blue Chip Capital Group Inc.Richard Moran
Comapany
July       NameBlue Chip Capital Group Inc.
     19, 2022
July 19,
Page  3 2022 Page 3
FirstName LastName
         the mechanics of your offering. Please also reconcile your disclosure
in this section that
         the Units "are" being offered by your officers and directors with your
cover page
         disclosure that your management "may" participate in the offering of
the Units. We may
         have further comments based upon your revised disclosure.
Placement Agent Agreement, page 34

11.      Please define the term "Qualified Investors," as your disclosure
references on page 34.
Audited Financial Statements for the Years Ended May 31, 2021 and 2020
Note 4 - Related Parties, page F-9

12.      Please tell us the accounting guidance you relied upon for the
forgiveness of payables by a
         related party. Further, tell us how you determined that the
forgiveness resulted in an
         expense of $56,900 in 2021.
Note 5 - Stockholders Equity, page F-9

13.      Please tell us how you considered the guidance in Rule 5-02-27 of
Regulation S-X
         concerning the classification of Preferred Stock within Stockholders'
Equity.
Note 6 - Software Application, page F-9

14.      Please provide us with your basis in authoritative accounting
literature for capitalizing
         costs incurred related to the ongoing production of your development
stage software
         application. Refer to ASC 985-20-25.
Unaudited Financial Statements for the Period Ended February 28, 2022 and 2021,
page F-11

15.      Please revise your next amendment to reflect the correct period for
the comparable income
         statement and cash flows of February 28, 2021 in the Table of
Contents.
Note 3 - Summary of Significant Accounting Policies
Warrants, page F-18

16.      We note your sale of shares of 3,040,000 shares for $95,000 during
June and July 2021.
         As part of the agreement, you issued warrants with escalating strike
prices. Please tell us
         how you considered the guidance in ASC 815-40-25 related to the sale
and the potential
         allocation of the proceeds to warrants.
Note 4 - Joint Venture, page F-20

17.      Please tell us the following concerning Raisewise Sweden referenced in
Note 4:
             Do you account for Raisewise Sweden as a consolidated,
wholly-owned subsidiary or
             an equity method joint venture;
             How are you accounting for the investment in the development of
the web platform
             that is valued at $250,000 given that there is no intellectual
property on the Balance
 Joseph Richard Moran
Blue Chip Capital Group Inc.
July 19, 2022
Page 4
              Sheet in the periods presented;
                Has the transaction been cash settled with Medcap LTD? If so,
how was it accounted
              for in the financial statements.
Exhibits
Exhibit 5.1, page II-2

18.      Please have counsel revise the legality opinion to opine on the Units
and each security
         component thereof. In particular, please revise to address the
following points:
             Please provide a binding obligation opinion with respect to the
legality of the Units.
             Clearly opine that the common stock included in the Units will be,
when sold, legally
             (or validly) issued, fully paid and non-assessable.
             Clearly opine that the common stock underlying the warrants will
be, when sold,
             legally (or validly) issued, fully paid and non-assessable.
             Since the warrants are contractual obligations issued pursuant to
agreements,
             please file a revised legality opinion that opines on whether the
warrants will be a
             binding obligation of the registrant under the law of the
jurisdiction governing the
             common stock purchase warrant. In that regard, we note that the
opinion does not
             indicate that the warrants will be the binding obligation of the
registrant, and the
             opinion is limited to the laws of Nevada. However, the form of
common stock
             purchase warrant filed as Exhibit 4.1 indicates that the warrant
will be governed by
             the laws of the State of Delaware.

         For guidance, please refer to Staff Legal Bulletin 19.
General

19.    Please provide us with supplemental copies of all written
communications, as defined in
       Rule 405 under the Securities Act, that you, or anyone authorized to do
so on your behalf,
       have presented or expect to present to potential investors in reliance
on Section 5(d)of the
       Securities Act, whether or not you retained, or intend to retain, copies
of those
       communications. Please contact the staff member associated with the
review of this
       submission to discuss how to submit the materials, if any, to us for our
review.
FirstName LastNameJoseph Richard Moran
20.    We note that in Amendment No. 1 you removed your previous disclosure in
the section
Comapany   NameBlue
       headed          Chip of
               "Description  Capital Group Securities."
                               the Offered Inc.          Please restore this
disclosure or explain to
       us why  it was
July 19, 2022 Page 4  deleted.
FirstName LastName
 Joseph Richard Moran
FirstName  LastNameJoseph
Blue Chip Capital Group Inc.Richard Moran
Comapany
July       NameBlue Chip Capital Group Inc.
     19, 2022
July 19,
Page  5 2022 Page 5
FirstName LastName
        You may contact Jacob Luxenburg at (202) 551-2339 or David Irving at
(202) 551-3321
if you have questions regarding comments on the financial statements and
related matters.
Please contact Eric Envall at (202) 551-3234 or David Lin at (202) 551-3552
with any other
questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Finance