Mail Stop 3030

                                                                 July 13, 2018

     Harry Simeonidis
     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.
                    Amendment No. 1 to Draft Offering Statement on Form 1-A
                    Submitted June 19, 2018
                    CIK No. 0001725430

     Dear Mr. Simeonidis:

           We have reviewed your amended draft offering statement and have the
     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 offering statement or publicly filing your offering
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 any amendment
     to your draft offering statement or filed offering statement and the
information you provide in
     response to these comments, we may have additional comments.

     Offering Circular

     Offering Procedure, page 55

     1.     Please reconcile the duration of your offering disclosed in the
first paragraph of this
            section with the information on your offering circular cover. Also
reconcile your
            disclosure regarding the definition of change in control disclosed
on pages 12 and 62, and
            your anti-takeover disclosures at the top of page 45 and in the
second and third
            subsections on page 91 with exhibit 2.4.

     2.     We note your disclosure that subscribers have no right to a return
of their funds during
            the Minimum Offering Period. Please clarify whether subscribers
after the Minimum
            Offering Period can revoke their subscriptions and have their funds
 Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
July 13, 2018
Page 2

3.     We note your disclosure on your offering circular cover that you will
effect a reverse split
       immediately prior to completion of the offering and that your disclosure
gives effect to
       the reverse split. Given the potential for multiple closings that you
mention on page 46, it
       is unclear whether investors who receive shares before the final closing
will receive more
       than one share for each $12.00 investment. If investors could receive
pre-split shares, it
       is unclear how you will handle fractional shares resulting from the
split. Please revise to
       clarify. Likewise, where your disclosure refers to action you will take
prior to the closing
       or consummation of the offering like on pages 78 and 79, please clarify
which closing
       you mean.

Description of Business, page 58

4.     Please revise your analysis in response to the second sentence of prior
comment 4 to
       address where your officers currently direct, control and coordinate
your activities. Also,
       ensure that your disclosure appropriately addresses your plans for
operations in the
       United States and Dr. Caminis' role.

Certain Steps to Commercialization, page 64

5.     Please expand your revisions in response to prior comment 1 to clarify
the status of
       development of the GBS System. For example, it is unclear what you mean
by "at the
       prototype stage." Have you developed a functioning product with the
capabilities you
       disclose? Also revise to clarify the "significant work" in relation to
product development
       that remains, as referenced on page 65.

Security Ownership . . ., page 87

6.     Please address that part of prior comment 5 seeking disclosure of the
natural persons who
       have or share voting and/or dispositive power over the shares held by
Life Science
       Biosensor Diagnostics.

Interim Financial Statements

7.     Please report comprehensive income as required by ASC 220-10-45. In that
regard, it
       does not appear that you have provided all of the required financial

Consolidated Statements of Cash Flows, page F-7

8.     Please revise to measure and present the impact of changes in foreign
currency exchange
       rates on cash and equivalents pursuant to ASC 830-230-45-1 and the
       implementation guidance at ASC 830-230-55-1. In that regard, the foreign
       translation adjustment should not appear as a reconciling item in the
body of the
       statement of cash flows. Also, note that the impact of changes in
exchange rates on cash
 Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
July 13, 2018
Page 3

       and cash equivalents and the foreign currency transaction adjustment are
       interchangeable measurements.


9.     We note your response to prior comment 9. Please identify in your
exhibit index the
       agreements mentioned on pages 51 and 52. Also file your agreement with
Dr. Caminis
       mentioned on page 77.

        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 Geoff Kruczek at (202) 551-3641 or me at (202)
551-3617 with
any other questions.


                                                           /s/ Russell Mancuso

                                                           Russell Mancuso
                                                           Branch Chief
                                                           Office of
Electronics and Machinery

cc: Gary J. Simon--Hughes Hubbard & Reed LLP