July 9, 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 issued comments on the above captioned filing on April 15, 2019. On
June 18, 2019,
we issued a follow-up letter informing you that those comments remained
outstanding and
unresolved, and absent a substantive response, we would act consistent with our
obligations
under the federal securities laws.

         As you have not provided a substantive response, we are terminating
our review and will
take further steps as we deem appropriate. These steps include releasing
publicly, through the
agency s EDGAR system, all correspondence, including this letter, relating to
the review of your
filing, consistent with the staff s decision to publicly release comment and
response letters
relating to disclosure filings it has reviewed.

       Please contact Paul Fischer, Staff Attorney, at 202-551-3415, or Larry
Spirgel, Assistant
Director, at 202-551-3815, with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Telecommunications
cc:    Elaine Dowling