July 10, 2019

Muneeb Ali
Chief Executive Officer
Blockstack PBC
101 W. 23rd Street, Suite 23
New York, NY 10011

       Re: Blockstack PBC
           Offering Statement on Form 1-A
           Filed July 8, 2019
           File No. 024-11033

Dear Mr. Ali:

       We have reviewed your 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.

Form 1-A filed July 8, 2019

General

1.    We understand that you intend to request qualification in the near
future. Please be
      advised that, as is the case with all Regulation A qualification
determinations, any
      determination we make with respect to your request does not mean that we
have passed
      upon the merits of, or given our approval to, the positions you have
taken in response to
      our comments or any determinations you have made in connection with the
offering.
2.    Please update your disclosure in the offering statement, such as your
Government
      Regulation section, to discuss the applicability of the FinCEN guidance
on the
      "Application of FinCEN's Regulations to Certain Business Models Involving
Convertible
      Virtual Securities" on your business. In this respect, please also
address whether you have
      engaged with FinCEN or state regulators on the subject.
 Muneeb Ali
FirstName LastNameMuneeb Ali
Blockstack PBC
Comapany NameBlockstack PBC
July 10, 2019
Page 2
July 10, 2019 Page 2
FirstName LastName
Where You Can Find Additional Information, page 141

3.       The disclosure in the third paragraph indicating that you will become
an Exchange Act
         reporting company as a result of the offering is inconsistent with
your disclosure
         elsewhere. Please revise your filing to eliminate this inconsistency.
        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. We also remind you that, following qualification of your
Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a
Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered
by the report.

        You may contact Michael Henderson, Staff Accountant, at (202) 551-3364
or Robert
Klein, Staff Accountant, at (202) 551-3847 if you have questions regarding
comments on the
financial statements and related matters. Please contact David Gessert, Staff
Attorney, at (202)
551-2326 or Erin E. Martin, Legal Branch Chief, at (202) 551-3391 with any
other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Financial Services