United States securities and exchange commission logo October 4, 2023 Timothy Spell Chief Executive Officer Reagan Bosco International Company, Inc. 1800 2nd Street, Suite 603 Sarasota, FL 34236 Re: Reagan Bosco International Company, Inc. Registration Statement on Form S-1 Filed September 27, 2023 File No. 333-274718 Dear Timothy Spell: We have reviewed your registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a 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 registration statement and the information you provide in response to this letter, we may have additional comments. Registration Statement on Form S-1 filed September 27, 2023 Dilution, page 12 1. We note your response to prior comment 1. Please include a table comparing the public contribution under the proposed public offering and the effective cash cost to officers, directors, promoters and affiliated persons of common equity acquired by them in transactions since inception. Include columns for the number and percent of shares purchased; amount and percent of total consideration; and the average price per share for existing shareholders versus new investors. Refer to Item 506 of Regulation S-K. 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. Timothy Spell Reagan Bosco International Company, Inc. October 4, 2023 Page 2 Please contact William Demarest at 202-551-3432 or Isaac Esquivel at 202-551-3395 if you have questions regarding comments on the financial statements and related matters. Please contact Kibum Park at 202-551-6836 or Jeffrey Gabor at 202-551-2544 with any other questions. Sincerely, FirstName LastNameTimothy Spell Division of Corporation Finance Comapany NameReagan Bosco International Company, Inc. Office of Real Estate & Construction October 4, 2023 Page 2 cc: Stephen A. Weiss, Esq. FirstName LastName