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                             December 20, 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. 5 to
Offering Statement on Form 1-A
                                                            Filed November 25,
2022
                                                            File No. 024-11611

       Dear William Sanchez:

             We have reviewed your amended offering 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 offering 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 offering statement and the
information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our March
1, 2022 letter.

       Form 1-A/A filed November 25, 2022

       Description of Business and Plan of Operation, page 19

   1.                                                   We note that you have
included estimated amounts for revenue and operating profits for
                                                        fiscal year ended
November 30, 2022. Please revise to include actual amounts or include
                                                        all disclosures
required pursuant to Article 11 of Regulation S-X for forecasts and
                                                        projections.
       Dilution, page 23

   2.                                                   Please revise the
dollar amount and per share amounts to clarify that you had a net
                                                        tangible (deficit)
rather than book value, where applicable.
 William Sanchez
Telco Cuba, Inc.
December 20, 2022
Page 2
Executive Compensation, page 31

3.    Please disclose executive compensation for the company's last completed
fiscal year
      ended November 30, 2022.
Condensed Consolidated Statements of Operations, page F-3

4.    We note that you recognized "Total Other Income" of $1,347,040 in 2022.
Please expand
      the notes to the financial statements to describe the nature of the Other
Income and the
      reason for the amount and timing of the income recognized.
5.    We note that you included Operating expenses and Payroll, Salaries in
Operating
      Expenses and it does not appear that any of these expenses have been
allocated to Cost of
      Sales. Please revise to allocate expenses to Cost of sales and include an
accounting policy
      to describe the methodology used to allocate such expenses.
Financial Statements - Nine Months Ended August 31, 2022, 2021 and 2020
Note 12. Acquisition of Advanced Satellite Systems, page F-13

6.    Refer to the Unaudited Pro Forma Financial Information on page F-14. We
note that the
      pro forma revenues for fiscal 2019 of $388,586 equals the historical
revenue for fiscal
      2019 on page F-20. Please revise to correct the pro forma information or
the Fiscal 2019
      financial statements for all line items, as appropriate. Please revise
the disclosure on page
      F-31 accordingly. Please also ensure that the disclosure of revenue and
earnings of
      Advanced Satellite Systems, Inc. on page F-32 is consistent with the pro
forma
      disclosures.
        You may contact Claire DeLabar, Senior Staff Accountant, at (202)
551-3349 or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 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
December 20, 2022 Page 2
cc:       Brett Alan Verona
FirstName LastName