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                           February 15, 2022

       William Sanchez
       President and Chief Executive Officer
       Telco Cuba, Inc.
       454 South Yonge Street
       Suite 7C
       Ormond Beach, Florida 32174

                                                        Re: Telco Cuba, Inc.
                                                            Amendment No. 2 to
Offering Statement on Form 1-A
                                                            Filed February 1,
2022
                                                            File No. 024-11611

       Dear Mr. Sanchez:

              We have reviewed your amended offering statement and have the
following comment. In
       our comment, we may ask you to provide us with information so we may
better understand your
       disclosure.

              Please respond to this letter by amending your offering statement
and providing the
       requested information. If you do not believe our comment applies 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 offering statement and the
information you
       provide in response to our comment, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
January 10, 2022 letter.

       Amendment 1 to Form 1-A

       Risk Factors
       A large part of our revenues are dependent on our limited number of
clients..., page 4

   1.                                                   You state that during
the 9 months ended August 31, 2021 and 2020, you had one and no
                                                        certain customers whose
revenue individually represented 90% or more of the Company   s
                                                        total revenue,
respectively. On page 25, however, you state that during the 9 months
                                                        ended August 31, 2021
and 2020, the Company had one and no certain customers whose
                                                        revenue individually
represented 9% or more of the Company   s total revenue,
                                                        respectively, and on
page F-7 you disclose that "During the 9 months ended on August 31,
                                                        2021 and 2020, 9% and
10% respectively of our revenue was concentrated in one
 William Sanchez
Telco Cuba, Inc.
February 15, 2022
Page 2
      customer. Please resolve these discrepancies. Also, clarify in your
disclosure if the
      customer from which you generated the most revenue through the nine
months ended
      August 31. 2020 and 2021 was Jace Inc.

        You may contact Claire DeLabar, Senior Staff Accountant, at (202)
551-3349 or
Robert Littlepage, Accounting Branch Chief, at if you have questions regarding
comments on
the financial statements and related matters. Please contact Matthew Crispino,
Staff Attorney,
at (202) 551-3456 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any
other questions.



                                                           Sincerely,
FirstName LastNameWilliam Sanchez
                                                           Division of
Corporation Finance
Comapany NameTelco Cuba, Inc.
                                                           Office of Technology
February 15, 2022 Page 2
cc:       Brett Alan Verona
FirstName LastName