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                             October 5, 2020

       David Koos
       Chief Executive Officer
       SYBLEU Inc.
       4700 Spring Street, Suite 304
       La Mesa, CA 91942

                                                        Re: SYBLEU Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed September 21,
2020
                                                            File No. 333-248059

       Dear Mr. Koos:

              We have reviewed your registration 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 registration
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 registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Amendment No. 1 to Registration Statement on Form S-1 filed September
21, 2020

       Prospectus Summary, page 6

   1.                                                   We note your response
to comment 6 and re-issue in part. Please update your disclosure to
                                                        describe what type of
patent protection you anticipate seeking (composition of matter, use
                                                        or process) and whether
you anticipate owning the patent application or licensing it from a
                                                        third party.
       Risk Factors
       No approval has been granted by the FDA for the marketing and sale of
the Cell Transplant IP,
       page 16

   2.                                                   We note your response
to comment 11 and updated disclosure and re-issue in part. Please
                                                        update your disclosure
to clarify that a product candidate must be identified and
 David Koos
SYBLEU Inc.
October 5, 2020
Page 2
      preclinical testing must be completed prior to submission of an
Investigational New
      Drug application (IND) to the FDA and that further, if the IND is
approved by the FDA,
      rigorous clinical testing must be successfully completed prior to
submission of a Biologic
      License Application to the FDA.
Business, page 27

3.    We note your response to prior comment 13 and updated disclosure and
re-issue in part.
      Please revise your initial statement that the Cell Transplant IP provides
means of
      "preactivating" a cellular graft and your initial description of the
benefits of
      preactivating a cellular graft with the Cell Transplant IP before
implantation to clarify that
      these statements are based on management's belief.
4.    We note your discussion beginning on page 29 of the studies that support
your belief that
      the Cell Transplant IP provides a means to preactivate a cellular graft
and that this
      preactivation would provide benefits to patients. Please update your
disclosure to clarify
      whether a Company affiliate conducted these studies or if they were
conducted by
      unaffiliated third parties.
Signatures, page 58

5.    Please ensure that your signature page is dated concurrently with the
date you file your
      amendment.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Tracey McKoy at 202-551-3772 or Lisa Vanjoske at
202-551-3614 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Alan Campbell at 202-551-4224 or Chris Edwards at 202-551-6761 with any
other
questions.



                                                             Sincerely,
FirstName LastNameDavid Koos
                                                             Division of
Corporation Finance
Comapany NameSYBLEU Inc.
                                                             Office of Life
Sciences
October 5, 2020 Page 2
cc:       William Aul
FirstName LastName