April 3, 2020

Anthony Snow
President and Corporate Secretary
CBA Florida, Inc.
3753 Howard Hughes Parkway, Suite 200, Office #258
Las Vegas, NV 89169

       Re: CBA Florida, Inc.
           Preliminary Proxy Statement on Schedule 14A
           Filed March 25, 2020
           File No. 000-50746

Dear Mr. Snow:

       We have reviewed your filing 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 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.

Preliminary Proxy Statement on Schedule 14A

Proposal 2: Approval of Plan of Dissolution
Background of the Proposed Dissolution, page 27

1.    Please revise the background section to discuss in greater detail the
process for identifying
      potential strategic transactions. Please describe all discussions,
meetings, contacts and
      reports among specific members of the board and/or management of the
Company, and
      representatives of potential counterparties as well as financial,
economic and legal
      advisors regarding the various options considered.
2.    Please identify the independent economic consulting firm engaged by the
Company to
      make an assessment of potential unknown liabilities and provide the
information required
      by Item 1015(b) of Regulation M-A.
 Anthony Snow
FirstName LastNameAnthony Snow
CBA Florida, Inc.
Comapany NameCBA Florida, Inc.
April 3, 2020
Page 3,
April 2 2020 Page 2
FirstName LastName
Amount and Timing of Estimated Liquidating Distributions to Shareholders, page
30

3.       Please quantify the amounts that make up the Potential Additional
Proceeds and the
         amount of Transaction purchase price proceeds expected to be released
from escrow in
         May 2020. Please also identify and quantify the amounts that make up
the $3.0 million to
         $3.5 million intended for known, ongoing expenses and the $2.2 million
for unknown,
         contingent and/or conditional liabilities.
Interests of Certain Persons in the Dissolution, page 32

4.       Please disclose the expected amount of compensation to be received by
the Company's
         officers and directors above their regular compensation with respect
to their services
         related to the implementation of the plan of dissolution.
General

5.       Please tell us how you considered the financial statement requirements
in Item 14(b)(8)
         through (b)(11) and 14(c)(1) of Schedule 14A.
        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.

       Please contact Chris Edwards at (202) 551-6761 or Celeste Murphy at
(202) 551-3257
with any other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Life
Sciences
cc:      Kenneth A. Schlesinger