April 15, 2019

Anthony Iarocci
President
Apex11 Inc.
8217 East Spanish Boot Road
Carefree, AZ 85377

       Re: Apex 11 Inc.
           Registration Statement on Form 10-12G/A
           Amended on April 10, 2019
           File no. 000-54964

Dear Mr. Iarocci:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

     After reviewing your response and any amendment you may file in response
to these
comments, we may have additional comments.

Registration Statement on Form 10-12G/A, filed on April 10, 2019

Report of Independent Registered Public Accounting Firm, page F-20

1.    We note you indicate on page F-20 that the report of the independent
registered public
      accounting firm on your interim financial statements is "To Come." Please
confirm to us,
      if true, that your financial statements for the nine months ended
September 30, 2018 and
      2017 have been reviewed by your auditor and as indicated, provide the
auditor's report in
      your amended filing. Refer to Rule 8-03 of Regulation S-X.
General

2.    You were required to file an annual report for the fiscal year ended
12/31/18 no later than
      March 31, 2019. Please advise us when you intend to file your annual
report on Form 10-
      K. Refer to Rule 13a-1 of the Exchange Act, and the Instructions to Form
10-K.
 Anthony Iarocci
Apex11 Inc.
April 15, 2019
Page 2

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Kathryn Jacobson, Senior Staff Accountant, at
202-551-3365, or
Robert S. Littlepage, Accounting Branch Chief, at 202-551-3361, if you have
questions
regarding comments on the financial statements and related matters. Please
contact Paul Fischer,
Staff Attorney, at 202-551-3415, or Larry Spirgel, Assistant Director, at
202-551-3815, with
any other questions.



                                                           Sincerely,
FirstName LastNameAnthony Iarocci
                                                           Division of
Corporation Finance
Comapany NameApex11 Inc.
                                                           Office of
Telecommunications
April 15, 2019 Page 2
cc:       Elaine Dowling
FirstName LastName