April 6, 2020

Lisa Averbuch
President, CEO and CFO
Celexus, Inc
8275 S. Eastern Ave, Suite 200
Las Vegas, Nevada 89123

       Re: Celexus, Inc
           Amendment No. 2 to the Form 10-K for the Fiscal Year Ended March 31,
2019
           Filed March 12, 2020
           Form 10-Q for the Fiscal Quarter Ended December 31, 2019
           Filed March 12, 2020
           File No. 000-52069

Dear Ms. Averbuch:

       We have reviewed your March 12, 2020 response to our comment letter and
your Form
10-Q filing for the quarter ended December 31, 2019, 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 these comments within ten business days by amending
your filing,
providing the requested information, or advise us as soon as possible when you
will respond. If
you do not believe our comments apply to your facts and circumstances, please
tell us why in
your response.

      After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
October 10, 2019 letter.

Form 10-Q for the Fiscal Quarter Ended December 31, 2019

Statement of Changes in Stockholders' Deficit, page 6

1.    We note your response to our prior comment 12. However, it appears that
both your par
      value and authorized number of shares on pages 4 and 12 were not
retroactively adjusted
      to account for the 1-90 reverse stock split. Furthermore, it is unclear
why you adjusted the
      historical balance of your additional paid-in capital as of March 31,
2018 and March 31,
      2019 as a result of the stock split. Please revise your filing
accordingly.
 Lisa Averbuch
FirstName LastNameLisa Averbuch
Celexus, Inc
Comapany NameCelexus, Inc
April 6, 2020
Page 6,
April 2 2020 Page 2
FirstName LastName
Notes to Condensed Financial Statements
Note 1. Organization and Going Concern, page 8

2.       Please revise to correct inconsistencies in your disclosures about
HempWave. Please
         clarify how the May 13, 2019 agreement is different than the February
2019 agreement
         which was later amended in July 2019. Furthermore, we note that on
December 30, 2019,
         HempWave announced an intention to purchase a controlling interest in
the Company.
         The press release included a quote from Ms. Averbuch in her role as
President of Celexus
         regarding a "partnership" with HempWave. Please revise your
disclosures here and in
         your MD&A on page 16 to address the current status of your planned
acquisition of or by
         HempWave. Refer to ASC 805-10-50 and ASC 855-10-50-2.
3.       We note inconsistencies in your disclosure related to Mr. Soto and Ms.
Averbuch's current
         status as officers and directors of the Company. Please revise your
disclosures
         accordingly.
        You may contact Robert Shapiro, Senior Staff Accountant, at
202-551-3273 or Lisa
Etheredge, Senior Staff Acountant, at 202-551-3424, if you have questions
regarding comments
on the financial statements and related matters. Please contact Kathleen Krebs,
Special Counsel,
at 202-551-3350, or Celeste Murphy, Legal Branch Chief, at 202-551-3257 with
any other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services