November 28, 2018

J. Mark Goode
Chief Executive Officer
Hash Labs Inc.
78 SW 7th Street
Miami, FL 33130

       Re: Hash Labs Inc.
           Registration Statement on Form S-1
           Filed October 29, 2018
           File No. 333-228042

Dear Mr. Goode:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 registration 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 registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-1 filed October 29, 2018

Prospectus Summary, page 1

1.     We note that your business plan contemplates the issuance of Crypto-Gold
(CXAU), a
       cryptocurrency asset that is backed by physical gold. As it appears CXAU
will be a
       security, please provide us with a detailed legal analysis of how you
intend to comply with
       the U.S. federal securities laws.
2.     You disclose that you are developing the CXAU Digital Vault and
Crypto-Gold and hope
       to launch both by March 4, 2019. Please balance your detailed disclosure
regarding your
       business plans to:

           clarify in the prospectus summary, if true, that these products are
not yet operational
 J. Mark Goode
FirstName LastNameJ. Mark Goode
Hash Labs Inc.
Comapany 28, 2018 Labs Inc.
November NameHash
November 28, 2018 Page 2
Page 2
FirstName LastName
             and have not yet generated any revenues;

             describe in the business or MD&A sections, the current stage and
anticipated stages of
             development of the CXAU Digital Vault and Crypto-Gold, including
             any developmental steps you have taken to date and the expected
developmental costs
             and sources of funding of the CXAU Digital Vault and Crypto-Gold;
and

             clarify whether whether you will be relying on your own employees
or third-party
             service providers to develop the CXAU Digital Vault and
Crypto-Gold.
Risk Factors, page 2

3.       Please add a risk factor that your executive officers, directors and
principal stockholders
         hold a majority of your securities and are able to exert significant
control over your
         corporate matters. Disclose the percentage of your common stock that
is currently held by
         your executive officers, directors and principal stockholders.
General

4.       Please provide a detailed legal and factual analysis of why this
offering is not a primary
         offering of your common stock and why the selling stockholders are not
explicitly
         identified as underwriters. In this regard, we note the size of this
offering relative to the
         number of shares of common stock held by non-affiliates, your
relationship with the
         selling stockholders, and the amount of time that the selling
stockholders have held their
         shares. In formulating your response, please consider Securities Act
Rule 415 and
         Interpretations 212.15, 612.09 and 612.12 of our Securities Act Rules
Compliance and
         Disclosure Interpretations.
        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.

        Refer to Rule 461 regarding requests for acceleration. Please allow
adequate time for us
to review any amendment prior to the requested effective date of the
registration statement.

      Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or, in
his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453 with any other questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Information Technologies
                                                                and Services
 J. Mark Goode
Hash Labs Inc.
November LastNameJ. Mark Goode
FirstName 28, 2018
Comapany NameHash Labs Inc.
Page 3
November 28, 2018 Page 3
cc:       Thomas A. Rose, Esq.
FirstName LastName