November 5, 2020

Via E-mail
Terence Kelly, Esq.
Dorsey & Whitney LLP
305 Lytton Avenue
Palo Alto, CA 94301

       Re:    Kyto Technology and Life Science, Inc.
              Amendment No. 1 to Schedule TO-I
              Filed November 3, 2020
              File No. 5-80125

Dear Mr. Kelly:

         We have reviewed the filing above and have the following comment.
Please respond to
this letter by providing the requested information. If you do not believe our
comment applies to
the company   s facts and circumstances or do not believe an amendment is
appropriate, please tell
us why in your response. After reviewing any amendment to the filing and the
information you
provide in response to this comment, we may have additional comments.

1.     We note that the offer was set to expire on October 31, 2020. The
amendment to the
       Schedule TO filed on Tuesday, November 3 announced that the Company has
elected to
       extend the offer to Tuesday, November 9. Given that the announcement
does not appear
       to have been made by 9:00 am Eastern time, on Monday, November 2, the
next business
       day after the scheduled expiration date of the offer and otherwise does
not disclose the
       approximate number of securities deposited to date, please advise how
the company has
       complied with the requirements of Exchange Act Rule 14e-1(d). Please
also provide
       your legal analysis of the consequences of such failure to comply,
including the effect of
       such failure on the tender offer. Please also advise what consideration
has been given to
       disclosing such non-compliance to holders, including the consequences of
such non-
       compliance.

                                           *    *   *

        We remind you that the registrant 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 me at (202) 551-3444 with any questions.
 Terence Kelly, Esq.
Dorsey & Whitney LLP
November 5, 2020
Page 2


                       Sincerely,

                       /s/ Perry Hindin

                       Perry Hindin
                       Special Counsel
                       Office of Mergers and Acquisitions