April 15, 2020

Robert Brantl
Chairman, Chief Executive Officer, and Chief Financial Officer
HYB Holding Corp.
52 Mulligan Lane
Irvington, NY 10533

       Re: HYB Holding Corp.
           Registration Statement on Form 10
           Filed March 19, 2020
           File No. 0-51012

Dear Mr. Brantl:

       We have reviewed your filing and have the following comments. In some of
our
comments we may ask you to provide us information so that we may better
understand your
disclosure.

       Please respond to these comments within 10 business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe that
our comments apply to your facts and circumstances, please tell us why in your
response.

     After reviewing your response and any amendment you may file in response
to these
comments, we may have additional comments.

Registration Statement on Form 10 filed March 19, 2020

General

1.     Please note that the Form 10 goes effective by lapse of time 60 days
after the original
       filing date pursuant to Section 12(g)(1) of the Securities Exchange Act
of 1934. Upon
       effectiveness, you will be subject to the reporting requirements of the
Exchange Act of
       1934, including the requirements to file Forms 10-K, 10-Q, and 8-K even
if comments
       remain open on the Form 10. Please note that we will continue to review
your filing until
       all of our comments have been addressed. If you do not wish to become
subject to these
       reporting requirements before the completion of our review, you may wish
to consider
       withdrawing the Form 10 before it becomes effective automatically and
filing a new Form
       10 that includes changes responsive to our comments.
2.     Disclosure indicates that you are a shell company whose business plan is
to acquire or
       merge with a private operating company in exchange for the majority of
your common
 Robert Brantl
FirstName LastNameRobert Brantl
HYB Holding Corp.
Comapany NameHYB Holding Corp.
April 15, 2020
Page 15,
April 2 2020 Page 2
FirstName LastName
         stock and that you negotiated with potential acquisition targets in
fiscal year 2019.
         Elaborate on your negotiations with potential acquisition targets in
fiscal year 2019.
         Additionally, clarify whether you are continuing to negotiate with
potential acquisition or
         merger targets, and, if so, describe the negotiations. Finally,
clarify whether you have
         identified any debt or equity financing sources to finance a potential
acquisition or
         merger, and, if so, indicate the debt or equity financing sources.
3.       Since you are a shell company, please revise to disclose the
requirements that must be met
         under Rule 144(i) for your securityholders to be able to rely on Rule
144 for the resale of
         your shares and the effect that these restrictions may have on the
liquidity of a
         securityholder's shares.
4.       It appears that you may be a "blank check" company under Section
(a)(2) of Rule 419 of
         the Securities Act of 1933. We note your disclosure that the company
ceased operating its
         business in approximately 2013 and that the company intends to acquire
or merge with an
         operating business. Please revise to disclose your status as a blank
check company and, in
         an appropriate place in your filing, provide details regarding
compliance with Rule 419 in
         connection with any offering of your securities.
Item 2. Financial Information
Years Ended June 30, 2019 and 2018, page 4

5.       We note your disclosure that the increase in operating expenses period
over period are
         attributable to negotiations with potential acquisition targets.
Please tell us if the
         likelihood of one or more of these potential acquisitions occurring is
considered probable.
Item 7. Certain Relationships and Related Transactions, and Director
Independence , page 7

6.       We note disclosure on page 5 that since July 2017, your chief
executive officer has
         financed your operations by making advances of funds to cover your
expenses. Please
         disclose the terms of repayment for the expenses that your chief
executive officer has paid
         on behalf of the company.
Item 9. Market Price of and Dividends on the Registrant's Common Equity and
Related
Stockholder Matters , page 8

7.       We note disclosure that your common stock is quoted on OTC Pink.
Please caution
         investors on the highly illiquid nature of an investment in your
common stock.
        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.

        You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or
Jean C. Yu,
Assistant Chief Accountant, at (202) 551-3305 if you have questions regarding
comments on the
financial statements and related matters. Please contact Edward M. Kelly,
Senior Counsel, at
 Robert Brantl
HYB Holding Corp.
April 15, 2020
Page 3

(202) 551-3728 or Sherry Haywood, Senior Counsel, at (202) 551-3345 with any
other
questions.



FirstName LastNameRobert Brantl                         Sincerely,
Comapany NameHYB Holding Corp.
                                                        Division of Corporation
Finance
April 15, 2020 Page 3                                   Office of Manufacturing
FirstName LastName