April 24, 2019

Max Rockwell
Chief Executive Officer
Gulf Chronic Care Inc.
12465 South Fort St.
Draper, Utah 84020

       Re: Gulf Chronic Care Inc.
           Amendment No. 2 to Offering Statement On Form 1-A
           Filed April 18, 2019
           File No. 024-10975

Dear Mr. Rockwell:

      We have reviewed your amended offering statement 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 this letter by amending your offering statement and
providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our [month, day,
year] letter.

Amendment No. 2 to Form 1-A

Exhibits

1.     We reissue prior comment 2. Please file as exhibits to the offering
statement all exhibits
       required by Paragraph 12 of Item 17 of Form 1-A, including, as examples,
the legal
       opinion required as Exhibit 12 and the correspondence required as
Exhibit 15(a). We
       note that you included a form of legal opinion in your correspondence
but did not file it as
       an exhibit or revise your exhibit index. It also is unclear how you
determined that the
       correspondence submitted on March 19, 2019, and April 1, 2019 does not
need to be filed
       as exhibits as each of those letters reference the draft offering
statement. Please advise or
       file the correspondence as previously requested.
 Max Rockwell
Gulf Chronic Care Inc.
April 24, 2019
Page 2




       You may contact Suying Li at 202-551-3335 or Joel Parker, Senior
Assistant Chief
Accountant at 202-551-3651 if you have questions regarding comments on the
financial
statements and related matters. Please contact Ruairi Regan at 202-551-3269 or
Pamela Howell,
Special Counsel, at 202-551-3357 with any other questions.



                                                         Sincerely,

FirstName LastNameMax Rockwell                           Division of
Corporation Finance
                                                         Office of Beverages,
Apparel and
Comapany NameGulf Chronic Care Inc.
                                                         Mining
April 24, 2019 Page 2
cc:       Jack Brannelly, Esq.
FirstName LastName