December 23, 2019 Roger May Chief Executive Officer Graphene & Solar Technologies Limited 433 N. Camden Dr., Ste. 600 Beverly Hills, CA 90210 Re: Graphene & Solar Technologies Limited Form 10-K for the fiscal year ended September 30, 2018 Filed January 23, 2019 File No. 333-174194 Dear Mr. May: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: David Fickson