March 1, 2019

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

       Re: Hash Labs Inc.
           Amendment No. 1 to Registration Statement on Form S-1
           Filed December 31, 2018
           File No. 333-228042

Dear Mr. Goode:

       We have reviewed your amended registration statement and have the
following
comment. In our comment, we ask you to provide us with information so we may
better
understand your disclosure.

       Please respond to this letter by providing the requested information. If
you do not believe
our comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to this comment, we may have additional comments. Our
reference to prior
comments is to comments in our November 28, 2018 letter.

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

General

1.     We note your response to prior comment 1 in which you provide your
analysis of why the
       digital token is not a security. We are unable to agree with your
analysis and believe that
       your tokenized gold program may involve the offer and sale of securities
under the
       Securities Act of 1933. While we acknowledge that your CXAU token and
platform are
       currently under development, it appears that these products will involve
the offer and sale
       of interests in a tokenized gold program. Please tell us how you intend
to register the
       offering of the interests in the tokenized gold program, or explain the
exemption from the
       registration requirements of the Securities Act of 1933 you will rely on
to conduct the
       offering.
 J. Mark Goode
Hash Labs Inc.
March 1, 2019
Page 2

      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 questions.



                                                            Sincerely,

FirstName LastNameJ. Mark Goode                             Division of
Corporation Finance
                                                            Office of
Information Technologies
Comapany NameHash Labs Inc.
                                                            and Services
March 1, 2019 Page 2
cc:       Thomas A. Rose, Esq.
FirstName LastName