Ms. Maryse Mills-Apenteng
Special Counsel
Securities and Exchange Commission
Re: OptiLeaf, Incorporated
File No. 333-202003
Dear Ms. Mills-Apenteng,
Our client, OptiLeaf, Incorporated, received the Commission’s comment letter dated June 5, 2015 regarding the above. We hereby respond to said letter, on an item, by item basis, as follows:
| 1. | We have filed Amendment No. 3 to the S-1, and have included updated and current financial statements. |
| 2. | We have revised the document to include this disclosure in several places as requested. |
| 3. | We have revised the document accordingly. |
| 4. | We have corrected the errors regarding number of shares offered. We counted the shares being offered, and actually determined the correct number is 4,466,668. We have revised the document throughout accordingly. |
| 5. | We have revised the document accordingly. |
| 6. | We have revised the document accordingly. |
| 7. | We have revised the document accordingly. |
| 8. | We have revised the document to reflect that Mr. Tran is no longer CEO of Eman Technologies. |
| 9. | Trans Pacific was never a related party. This was an error, they are a third party landlord. |
| 10. | We have added the disclosure required by item 509. |
| 11. | We have revised the document accordingly. |
| 12. | We have amended the Form D. |
| 13. | We have revised the document accordingly. |
| 14. | We have revised the document accordingly. |
Thank you very much for your consideration in this matter.
| Sincerely, | |
| James S. Byrd, Jr. | |
| Counsel to OptiLeaf |