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                            April 30, 2021

       Peter Klamka
       Chief Executive Officer
       Cordia Corporation
       401 Ryland St.
       Reno, NV, 89502

                                                        Re: Cordia Corporation
                                                            Registration
Statement on Form 10-12G
                                                            Filed April 5, 2021
                                                            File No. 000-51202

       Dear Mr. Klamka:

              We have reviewed your filing 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 these comments 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 our
       comments apply 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 these
       comments, we may have additional comments.

       Registration Statement on Form 10-12G

       Financial Information, page 8

   1.                                                   We note your disclosure
that you generated $74,207 in revenue in 2020. Please revise to
                                                        provide a discussion of
the sources of revenue and reconcile that with your
                                                        disclosure elsewhere
that you have generated no revenues.
       Liquidity and Capital Resources, page 9

   2.                                                   We note the disclosure
in Note 3 of your financial statements indicating you have a note
                                                        payable to Lyons
Capital, Inc that is due on April 27, 2021. Please revise to clarify
                                                        whether you have
satisfied this loan or whether you have reached an agreement to change
                                                        the payment date, and
include a discussion of the note payable in this section.
 Peter Klamka
FirstName   LastNamePeter Klamka
Cordia Corporation
Comapany
April       NameCordia Corporation
       30, 2021
April 230, 2021 Page 2
Page
FirstName LastName
3.       We note your disclosure that you will be dependent on management
and/or an affiliated
         party for your financing needs for the next 12 months. Please tell us
whether you have
         entered into an agreement with your sole officer and director or any
other related party for
         the funding necessary to implement your business plan, and file any
such agreement as an
         exhibit.
Description of Property, page 10

4.       We note your disclosure that you do not currently lease any property.
Please revise to
         explain the manner in which the Company holds its office space or
headquarters and the
         terms of any agreement for the use of such space.
Directors, Executive Officers, Promoters, and Control Persons, page 10

5.       Please revise to disclose more detail about Pater Klamka's principal
occupation
         or position of employment in the past five years by providing dates
and places of
         employment. Clarify whether your sole officer and director is serving
as an officer or
         director of any other entities. Finally, revise to disclose whether
your sole officer and
         director has been involved in certain legal proceedings in the last
ten years. In this regard,
         we note that you only represent that Mr. Klamka has not been involved
in any legal
         proceedings within the last five years. See Item 401(f) of Regulation
S-K.

Security Ownership of Certain Beneficial Owners and Management, page 10

6.       Please disclose the natural person or persons who directly or
indirectly exercise sole or
         shared voting or investment control over the shares held by Geils & Co
1866 and Geils
         Ventures LLC. Refer to Item 403 of Regulation S-K and Exchange Act
Rule 13d-3.
Certain Relationships and Related Transactions and Director Independence, page
11

7.       Please revise to provide the information required by Item 404(d) of
Regulation S-K,
         which requires disclosure of all transactions with related persons
since 2018. We note, for
         example, that you entered into a related party transaction with
Rideshare, an entity owned
         by your Chief Executive Officer.
Recent Sales of Unregistered Securities, page 12

8.       We note that Mr. Klamka holds 61,000 shares of common stock. Please
tell us whether
         these shares were issued after Churchill Schwartz, LLC became
custodian of the
         Company. To the extent there were any share issuances in the past 3
years, please revise
         to provide the information required by Item 701 of Regulation S-K.
 Peter Klamka
FirstName   LastNamePeter Klamka
Cordia Corporation
Comapany
April       NameCordia Corporation
       30, 2021
April 330, 2021 Page 3
Page
FirstName LastName
General

9.       Given your lack of revenues, nominal assets and operations, it appears
you are a shell
         company, as defined by Rule 405 of Regulation C of the Securities Act.
Please revise your
         registration statement accordingly, including the Form 10 facing page
and description of
         your business, and discuss the restrictions on resales of your shares
under Rule 144(i) as it
         applies to shell companies. Otherwise, please provide us with a
detailed analysis
         explaining why you are not a shell company.
        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.

       You may contact Joyce Sweeney, Senior Staff Accountant, at (202)
551-3449 or
Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have
questions regarding
comments on the financial statements and related matters. Please contact
Matthew Derby, Staff
Attorney, at (202) 551-3334 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Technology