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                             October 20, 2021

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

                                                        Re: Cordia Corporation
                                                            Offering Statement
on Form 1-A
                                                            Filed September 23,
2021
                                                            File No. 024-11655

       Dear Mr. Klamka:

              We have reviewed your offering 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 amending your offering statement
and providing the
       requested information. 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 any amendment to your offering statement and
the information you
       provide in response to these comments, we may have additional comments.

       Offering Statement on Form 1-A

       Cover Page

   1.                                                   You indicate that the
Board of Directors used its business judgment in setting the price
                                                        range between $0.35 -
$0.50 but you set the offering price range to $0.30- $0.50 per
                                                        share. Please advise
why the price range is different from the Board's recommendation.
                                                        Further, explain your
statement that the "offering price will not remain fixed for the
                                                        duration of the
Offering" and tell us how this complies with Securities Act Rule
                                                        251(d)(3)(ii) which
prohibits at-the-market offerings under Regulation A.
       Liquidity and Capital Resources, page 27

   2.                                                   We note your disclosure
that you estimated costs will be five or six thousand dollars per
                                                        month. However, we
further note that your license agreements have a minimum annual
                                                        payment of $100,000 in
the aggregate, and you intend to pay your officers and directors a
                                                        salary in addition to
other expenses. Please revise to incorporate all expected
 Peter Klamka
Cordia Corporation
October 20, 2021
Page 2
         expenditures in your discussion of your liquidity and capital
resources needed for the next
         12 months.
3.       You disclose that your note with Lyons Capital LLC is currently in
default. However, you
         also indicate that the due date has been extended to December 31,
2021. Please reconcile
         or advise.
Description of Business, page 28

4.       You indicate that you intend to operate a subscription based business.
You also indicate
         that pursuant to your license agreements, a certain percentage of
gross receipts will be due
         to Denise Richards, Carmen Electra and Holly Sonders as a royalty for
usage of their
         image and likeness. Please revise to clarify how the company intends
to generate revenue,
         including from subscriptions and/or gross receipts, and clearly
disclose the fact that, in the
         aggregate, 80% of gross receipts for 36 months will be due under your
licensing
         agreements. File these license agreements as exhibits.

Directors, Executive Officers, and Significant Employees, page 30

5.       We note that your executive officers and significant employees are not
required to work
         full time for your company. Please disclose the number of hours per
week or month they
         are expected to work for the Company. See Item 10 of Form 1-A. Please
revise to clarify
         whether your officers and director serve as officers or directors of
any companies and not
         only publicly traded companies. Finally, you refer to Eric Rice as
your Chairman and
         Chief Executive Officer on page 31 which differs from your disclosure
elsewhere in the
         offering statement. Please advise.

Signatures, page 43

6.       Please revise to indicate whether Peter Klamka is also serving as the
company's principal
         accounting officer.
General
FirstName LastNamePeter Klamka
7.     We note that the consent from BF Borgers that references this offering
circular is dated
Comapany
       MayNameCordia     Corporation
            25, 2021, which is prior to the filing of this Form 1-A. Please
revise to provide an
       updated consent.
October 20, 2021 Page 2
FirstName LastName
 Peter Klamka
FirstName LastNamePeter Klamka
Cordia Corporation
Comapany
October 20,NameCordia
            2021        Corporation
October
Page  3 20, 2021 Page 3
FirstName LastName
        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        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. We also remind you that, following qualification of your
Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a
Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered
by the report.

      Please contact Matthew Derby, Staff Attorney, at (202) 551-3334 or Jan
Woo, Legal
Branch Chief, at (202) 551-3453 with any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Technology
cc:      Jonathan Leinwand