StemSation International, Inc.
7777 Glades Road, Suite 203
Boca Raton, FL 33434
Tel: (561) 245-7454 Fax: (561) 892-2444
rcarter@stemsationusa.com
www.stemsation.global
January 7, 2020
VIA EDGAR
Asia Timmons-Pierce
Staff Attorney
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
| Re: | Stemsation International, Inc. | |
| Offering Statement on Form 1-A | ||
| File No. 024-11111 |
Dear Ms. Timmons-Pierce,
Stemsation International, Inc. (the "Company") respectfully requests that the above- referenced Offering Statement on Form 1-A, as amended, be declared qualified by the Securities and Exchange Commission (the "Commission") on 12:00 p.m., Eastern Time on January 7, 2020, or as soon thereafter as is practicable.
The Company hereby confirms that the offering will take place in one or more states pursuant to an exemption from registration under, but otherwise in compliance with, any applicable state securities law.
The State of Wyoming exempts transactions of securities to institutional investors from registration pursuant to Section 17-4-202(a)(xiii)(A) of the Wyoming Uniform Securities Act. The Company is relying on this exemption in conducting the offering in Wyoming. We have spoken to the Office of the Secretary of State of Wyoming who advised us that such exemption is self-executing and no filings or fees are required in Wyoming to conduct the offering in their jurisdiction.
If you have any questions, please contact our counsel,Constantine Christakis, at (561) 227-4577.
Thank you in advance for your assistance.
Respectfully,
| /s/ Ray C. Carter | |
| Ray C. Carter | |
| President and Chief Executive Officer |