May 16, 2019 Lisa Averbuch Chief Executive Officer Celexus, Inc 8275 S. Eastern Ave. Suite 200 Las Vegas, Nevada 89123 Re: Celexus, Inc Registration Statement on Form 10-12G Filed February 5, 2019 Form 10-Q for the Quarter Ended December 31, 2018 Filed April 3, 2019 Form 8-K Filed February 25, 2019 File No. 000-52069 Dear Ms. Averbuch: We issued comments to you on the above captioned filing on April 12, 2019. As of the date of this letter, these comments remain outstanding and unresolved. We expect you to provide a complete, substantive response to these comments by May 31, 2019 If you do not respond, we will, consistent with our obligations under the federal securities laws, decide how we will seek to resolve material outstanding comments and complete our review of your filing and your disclosure. Among other things, we may decide to release publicly, through the agency's EDGAR system, all correspondence, including this letter, relating to the review of your filings, consistent with the staff's decision to publicly release comment and response letters relating to disclosure filings it has reviewed. Please contact Gregory Dundas, Attorney Advisor, at (202) 551-3436 or Celeste Murphy, Legal Branch Chief, at (202) 551-3257 with any questions. Sincerely, Division of Corporation Finance Office of Telecommunications cc: Elaine Dowling