August 13, 2019

Douglas Chloupek
Chief Executive Officer
JUVA LIFE INC./Canada
1500 - 885 West Georgia Street
Vancouver, British Columbia V6C 3E8
Canada

       Re: JUVA LIFE INC./Canada
           Amendment No. 2 to Offering Statement on Form 1-A
           Filed July 29, 2019
           File No. 024-11014

Dear Mr. Chloupek:

      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 July 9, 2019
letter.

Amendment No. 2 to Form 1-A filed July 29, 2019

Summary
Our Business, page 5

1.    We note your response to prior comment 3 and your revised disclosure on
page
      6 indicating that if your business transitions into interstate commerce
in the future, your
      business may eventually involve development and sale of cannabis based
products that
      will require FDA and/or DEA drug approval(s) and/or registration(s) and
that in such
      case, you research, development and marketing of nutraceuticals, or
dietary supplements,
      would be permitted without FDA prior approval under the Dietary
Supplement and Health
      Education Act of 1994. Please provide the basis for your belief that your
products would
 Douglas Chloupek
JUVA LIFE INC./Canada
August 13, 2019
Page 2
      be permitted without FDA prior approval under the Dietary Supplement and
Health
      Education Act of 1994. In this regard, we note Question 9 of the FDA's
Regulation of
      Cannabis and Cannabis-Derived Products: Questions and Answers which
indicates that
      the FDA has concluded that THC and CBD products are excluded from the
dietary
      supplement definition under section 201(ff)(3)(B) of the Federal Food,
Drug, and
      Cosmetic Act.
Securities Being Offered, page 55

2.    We note your response to prior comment 8 and your revised disclosure on
page 56
      indicating that claims or actions arising out of the Subscription
Agreement and asserted
      under the Securities Act will be subject to exclusive federal
jurisdiction. Please revise
      to state that there is uncertainty as to whether a court would enforce
such provision. If the
      provision applies to Securities Act claims, please also state that
investors cannot waive
      compliance with the federal securities laws and the rules and regulations
thereunder. In
      that regard, we note that Section 22 of the Securities Act creates
concurrent jurisdiction
      for federal and state courts over all suits brought to enforce any duty
or liability created by
      the Securities Act or the rules and regulations thereunder. Please also
consider including
      appropriate risk factor disclosure.
       You may contact Mary Mast at 202-551-3613 or Kevin Vaughn at
202-551-3494 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jeffrey Gabor at 202-551-2544 or Mary Beth Breslin at 202-551-3625 with
any other
questions.



                                                             Sincerely,
FirstName LastNameDouglas Chloupek
                                                             Division of
Corporation Finance
Comapany NameJUVA LIFE INC./Canada
                                                             Office of
Healthcare & Insurance
August 13, 2019 Page 2
cc:       Rebecca G. DiStefano, Esq.
FirstName LastName