August 29, 2019

Harry Simeonidis
President
Glucose Biosensor Systems (Greater China) Holdings, Inc.
708 Third Avenue, 6th Floor
New York, New York 10017

       Re: Glucose Biosensor Systems (Greater China) Holdings, Inc.
           Amendment No. 2 to Registration Statement on Form S-1
           Filed August 21, 2019
           File No. 333-232557

Dear Mr. Simeonidis:

       We have reviewed your amended registration 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 registration 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 registration 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 August 16,
2019 letter.

Amendment No. 2 to Registration Statement on Form S-1 filed August 21, 2019

Exclusive Forum Selection, page 84

1.     We note your disclosure that "[o]ur stockholders investors will not be
deemed to have
       waived compliance with the federal securities laws and the rules and
regulations
       thereunder." We note your similar disclosure in the last risk factor on
page 32. As
       requested by our prior comment 2 in our letter dated August 16, 2019,
please revise your
       prospectus to disclose that investors cannot waive compliance with the
federal securities
       laws and the rules and regulations promulgated thereunder. Please also
expand your
       related risk factor on page 32 to address the increased costs for
investors to bring a claim
       to which your exclusive forum provision applies in the Court of Chancery
or the federal
       district court for the District of Delaware.
 Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
August 29, 2019
Page 2

        You may contact Michael Fay at (202) 551-3812 or Brian Cascio,
Accounting Branch
Chief, at (202) 551-3676 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
August 29, 2019 Page 2
cc:       Eric T. Schwartz, Esq.
FirstName LastName