Bell Rose Capital, Inc.
2920 Inland Empire Boulevard, Suite 103
Ontario, California 91764
June 14, 2023
VIA EDGAR
Austin Pattan
Staff Attorney
Office of Technology
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Bell Rose Capital, Inc. |
| | Offering Statement on Form 1-A |
| | Commission File No. 024-12270 |
Dear Mr. Pattan:
On behalf of the Company, I respectfully request that the qualification date of the Offering Statement on Form 1-A be accelerated and that the Offering Statement be declared qualified Thursday, June 15, 2023, at 3:00 p.m. EDT, or as soon thereafter as is reasonably practicable.
In making this request, the Company represents that the Offering Statement on Form 1-A will be approved in the State of Colorado, upon qualification by the Securities and Exchange Commission (the “Commission”), and acknowledges the following:
| · | should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the filing qualified, it does not foreclose the Commission from taking any action with respect to the filing; |
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| · | the action of the Commission or the staff, acting pursuant to delegated authority, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy of disclosure in the filing; and |
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| · | the Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States. |
Very truly yours,
/s/ Carlos Salgado
Carlos Salgado
Chief Executive Officer
Bell Rose Capital, Inc.