June 27, 2025

Ryan Schadel
Chief Executive Officer
Metavesco, Inc.
410 Peachtree Pkwy, Suite 4245
Cumming, GA 30041

       Re: Metavesco, Inc.
           Amendment No. 1 to
           Offering Statement on Form 1-A
           Filed June 10, 2025
           File No. 024-12608
Dear Ryan Schadel:

     We have reviewed your amended offering statement and have the following
comments.

       Please respond to this letter by amending your offering statement and
providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we
note
otherwise, any references to prior comments are to comments in our May 16, 2025
letter.

Amendment No. 1 to Offering Statement on Form 1-A
General

1.     We note your response to prior comment 1, your revised disclosure and
your
       disclosure on the cover page that "[r]eferences herein to the 'Offered
Shares' include
       the Selling Shareholder Offered Shares, unless the context requires
otherwise. (See
       'Use of Proceeds,' 'Plan of Distribution' and 'Selling Shareholders')."
Please consider
       whether the context of each use of "Offered Shares" is sufficiently
clear or whether
       further revision would be appropriate.
2.     We note your response to prior comment 2, your revised disclosure and
continued use
       of the midpoint of your price range in certain portions of your offering
statement, and
       we reissue. Please revise Part II of your offering statement to
consistently use the
 June 27, 2025
Page 2

       upper end of your price range. Please further note that there is a
discrepancy on your
       cover page with respect to the upper end of your price range, and revise
as
       appropriate. Finally, please ensure that the midpoint used in your Part
1, Item 4
       disclosure is accurate.
3.     We note your Part I, Item 4 disclosure only includes the Company Offered
Shares in
       the    number of securities offered.    Please revise to include the
total number of shares
       being qualified under your offering statement.
4.     We note your response to prior comment 4 and revised disclosure. Please
further
       revise the table on the cover page to include the amount of interest
being qualified
       when referencing the principal amount of the Subject Convertible Notes
being
       qualified. Additionally, please consider whether you should clarify
throughout your
       offering statement.
5.     We note your response to prior comment 7 and revised disclosure, and we
reissue in
       part. Please add Puerto Rico to your Item 5, Part I disclosure or delete
the same from
       page 21 of your offering statement.
6.     We note your response to prior comment 8 and revised disclosure. Please
note that
       Rule 506(b) is not listed as an exemption relied upon for the disclosed
issuances of
       unregistered securities. Please reconcile this discrepancy. We further
note the
       common stock issuances disclosed on page F-31. Please confirm that such
issuances
       are included in your Part I disclosure, or revise as appropriate.
Similarly, please
       ensure that all sales of unregistered securities listed in your Part I
disclosure are
       disclosed in your offering statement, as applicable.
7.     We note your response to prior comment 10 and revised disclosure, and we
reissue.
       We note your disclosure on the cover page and elsewhere that the Subject
Convertible
       Notes will convert "at the election of their respective holders." Please
revise to ensure
       that your offering statement is consistent throughout and that any
discrepancies in
       your disclosures are reconciled.

Plan of Distribution
Procedures for Subscribing, page 21

8.     We note your response to prior comment 11 and reissue in part.
Specifically, we note
       your disclosure that in connection with determining whether to accept or
reject a
       subscription you intend to consider, among other things, your
then-current need for a
       cash investment    and    the state of the securities markets, in
general, and the market
       for [your] common stock, in particular.    Please confirm your
understanding that Rule
       251(d)(3)(i)(F) is limited to offerings that commence within two
calendar days after
       qualification and are made on a continuous basis during the offering
period. Relatedly,
       please also confirm your understanding that in a continuous offering, an
issuer must
       be ready and willing to sell the aggregate amount of securities
qualified at all times.
 June 27, 2025
Page 3
Notes to Unaudited Financial Statements
Note 2 - Significant Accounting Policies
Principles of Consolidation, page F-6

9.     Please reconcile your description of Epic Labor, Inc. here as a Wyoming
       corporation with your descriptions elsewhere of Epic Labor, Inc. as a
Georgia
       corporation.

       Please contact Lulu Cheng at 202-551-3811 or David Lin at 202-551-3552
with any
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Crypto
Assets
cc:   Eric Newlan