June 7, 2019

Harry Simeonidis
President
Glucose Biosensor Systems (Greater China) Holdings, Inc.
733 Third Avenue, Floor 15
New York, New York 10017

       Re: Glucose Biosensor Systems (Greater China) Holdings, Inc.
           Draft Registration Statement on Form S-1
           Submitted May 13, 2019
           CIK No. 0001725430

Dear Mr. Simeonidis:

       We have reviewed your draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1 submitted May 13, 2019

Prospectus Summary, page 1

1.     If true, please disclose that to date you have not generated any
revenues from sales of your
       intended products and that to date you have incurred net losses and
negative cash flows
       from operations.
2.     Please balance your disclosure that the SGB produces a signal directly
correlated to the
       amount of glucose present in saliva with disclosure of whether you have
any third-party
       clinical validation that supports a meaningful correlation between
glucose present in saliva
       and glucose present in blood. If you do not have clinical evidence of a
       meaningful correlation at this time, please disclose in an appropriate
location in your
       prospectus the basis for your belief that the measurement of salivary
glucose is a
 Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
June 7, 2019
Page 2
         meaningful proxy for blood glucose levels and include appropriate risk
factor disclosure
         regarding your beliefs.
3.       We note your disclosure that the biosensor technology has been
"extensively referenced in
         scientific literature." It is unclear what this disclosure is intended
to convey since you also
         appear to disclose that you have not generated clinical evidence to
support regulatory
         clearance. If you elect to reference scientific literature please
briefly indicate the nature of
         the references and provide balanced disclosure, including information
regarding any
         reference with results that may not support that salivary glucose
biosensors provide
         meaningful information for blood glucose monitoring.
4.       Given your disclosure that the Licensor owns all of the intellectual
property related to the
         biosensor technology, including any improvements made to the
technology by you, and all
         data and any derivations related to the foregoing, briefly disclose
how you intend to
         conduct business after your license agreement expires and include
appropriate risk factor
         disclosure.
5.       We note the intended launch of other diagnostics tests. Briefly
explain the status of
         development of those products. Also compare that status with the
status of your SGB
         product.
License Agreement, page 3

6.       Revise the second paragraph to clarify whether you, your affiliates,
the Licensor or its
         affiliates currently are capable of manufacturing your product.
7.       Please briefly explain the reason for the geographic scope limitation
of the License
         Agreement. If the Licensor has granted other licenses with different
or overlapping
         scopes, please also disclose that fact and explain the extent of that
scope. Please also
         explain the purpose and intended use of the demographic information
and personally
         identifiable information, including health information, you are
required to assemble.
Risks We Face, page 5

8.       Revise your ninth bullet point to disclose, if true, that the Licensor
may choose not to
         protect the intellectual property and proprietary rights.
Implications of being an Emerging Growth Company, page 6

9.     Please supplementally provide us with copies of all written
communications, as defined in
FirstName LastNameHarry Simeonidis that you, or anyone authorized to do so on
your behalf,
       Rule 405 under the Securities Act,
Comapany NameGlucose Biosensor in reliance on Section 5(d) of the Securities
Act, whether or
       present to potential investors Systems (Greater China) Holdings, Inc.
June 7,not they retain copies of the communications.
        2019 Page 2
FirstName LastName
 Harry Simeonidis
FirstName LastNameHarry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
Comapany NameGlucose Biosensor Systems (Greater China) Holdings, Inc.
June 7, 2019
June 7, 2019 Page 3
Page 3
FirstName LastName
Common Stock to be Outstanding after this Offering, page 7

10.      Please tell us how the 1,861,706 outstanding shares of your Series A
Convertible
         Preferred Stock is reconcilable to the information in your balance
sheet as of December
         31, 2018 and the information on pages F-15 and F-16.
Our parent company may exert significant influence..., page 30

11.      If true, please disclose that your decision not to seek exemption as a
"controlled company"
         could change. If your decision could change with respect to relying on
the exemptions,
         please include appropriate risk factor disclosure. Please also revise
your disclosure in an
         appropriate section, such as pages 63-66, to specify the nature of the
"controlled
         company" exemptions that would be available to you.
Use of Proceeds, page 34

12.      Please clarify the extent to which the proceeds to be received will
enable you to achieve
         the items specified in the first two bullet points.
Liquidity and Capital Resources, page 40

13.      We note the references to financial support from the shareholders of
your parent entity in
         the third paragraph of Note 1 to your financial statements on page
F-8. Please tell us why
         you have not included disclosure regarding those arrangements in this
section or revise
         your disclosure as appropriate. In this regard, we also note your
disclosure on page 10
         that you do not currently have any arrangements or credit facilities
in place as a source of
         funds. Please ensure that your disclosure is consistent throughout
your prospectus. Please
         also file as exhibits the letters relating to the financial support
those entities intend to
         provide.
Description of Business, page 41

14.      We note your disclosure in the second risk factor on page 13. Please
tell us the basis for
         your statement above figure 5 on page 44 that the pictured technology
allows mass
         volume printing at low cost or revise your disclosure as appropriate.
Since you have not
         entered the mass production stage, please tell us why it is
appropriate to depict this
         technology in your prospectus summary.
15.      Please provide us your analysis of whether you are a "foreign private
issuer," as defined in
         Rule 405 of Regulation C. In this regard, we note that you state your
principal executive
         offices are in New York, but that such offices are limited in size. It
is also unclear what
         functions are performed there, given the geographic scope of the
license, location of your
         sole stockholder and its affiliates and location of your other
management team members.
 Harry Simeonidis
FirstName LastNameHarry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
Comapany NameGlucose Biosensor Systems (Greater China) Holdings, Inc.
June 7, 2019
June 7, 2019 Page 4
Page 4
FirstName LastName
The Saliva Glucose Biosensor, page 46

16.      Please briefly describe the technological claims protected by your
patent. Clarify whether
         the China patent relates to similar or identical technological claims
as your U.S. patent.
17.      Briefly indicate how the biosensor communicates with the smart device
and indicate how
         the incorporation of the communication technology in the biosensor may
impact cost.
         Also, your disclosure indicates that you have successfully developed a
product that
         communicates with a smart device. If that is not correct, please
revise to eliminate that
         implication.
Competition, page 62

18.      Clarify the basis for the statements in the second paragraph given the
status of your
         product's development.
Management, page 63

19.      We note your disclosure that Mr. Simeonidis has been with Farmaforce
since March
         2017. It also appears that Mr. Becker and Mr. Sakiris are also
currently employed by
         entities other than the registrant. If Messrs. Simeonidis, Becker and
Sakiris will not be
         full-time employees, please clarify and include any appropriate risk
factor disclosure,
         including any conflicts of interest, and reconcile with your
disclosure on page 62 that you
         have no part-time employees. Also disclose Mr. Simeonidis' business
experience between
         April 2015 and March 2017.
20.      Disclose Dr. Hei's business experience between February 2015 and
August 2018.
Principal Stockholders, page 74

21.      Please revise footnote 2 to disclose all natural person or persons who
exercise the sole or
         shared voting and/or dispositive powers with respect to your shares
held by Life Science
         Biosensor Diagnostics Pty Ltd.
22.      Please expand the information in the table to account for the
transactions referenced in the
         second paragraph on page 84, as applicable.
Certain Transactions, page 75

23.      Please tell us how you determined that any agreements relating to the
employee sharing
         arrangements discussed here are not required to be filed as exhibits
in accordance with
         Regulation S-K Item 601(b)(10) or file the agreements as appropriate.
Related Party Policy, page 76

24.      Please disclose the standards to be applied in deciding whether to
approve or ratify any
         related party transaction. Refer to Regulation S-K Item 404(b)(1)(ii).
 Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
June 7, 2019
Page 5
Consolidated Financial Statements
Consolidated Balance Sheets, page F-3

25.   Please revise to provide the correct date above each of the balance
sheets. The headings
      appear to be reversed. Also, delete the label "audited" above the balance
sheet derived
      from your audited financial statements. The audit report expresses an
opinion on the
      financial statements taken as a whole rather than on individual
components of those
      financial statements.
Consolidated Statements of Operations, page F-4

26.   Please revise to round loss per share to two decimal places to avoid
giving the impression
      of more precision than exists, here and Note 13.
        You may contact Michael Fay at (202) 551-3812 or Gary Todd, Senior
Accountant, at
(202) 551-3605 if you have questions regarding comments on the financial
statements and
related matters. Please contact Tim Buchmiller at (202) 551-3635 or Geoff
Kruczek, Special
Counsel, at (202) 551-3641 with any other questions.



                                                           Sincerely,
FirstName LastNameHarry Simeonidis
                                                     Division of Corporation
Finance
Comapany NameGlucose Biosensor Systems (Greater China) Holdings, Inc.
                                                     Office of Electronics and
Machinery
June 7, 2019 Page 5
cc:       Eric T. Schwartz, Esq.
FirstName LastName