August 16, 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. 1 to Registration Statement on Form S-1
           Filed August 2, 2019
           File No. 333-232557

Dear Mr. Simeonidis:

      We have reviewed your amended 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 amending your registration 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 registration 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 July 11,
2019 letter.

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

Management, page 64

1.     Exhibits 10.5 and 10.7 indicates that Mr. Syrmalis is your chief
executive officer and that
       your President and Chief Financial Officer report to him, contrary to
your disclosure in
       this section. Please revise or advise. Please also reconcile your
disclosure on page 71
       regarding the terms of the referenced employment agreements with
Exhibits 10.5 and
       10.7.
Exclusive Forum Selection, page 84

2.     We note that your forum selection provision in exhibit 3.1 identifies
the Court of
       Chancery of the State of Delaware as the exclusive forum for certain
litigation, including
 Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
August 16, 2019
Page 2
      any "derivative action." Please disclose whether this provision applies
to actions arising
      under the Securities Act or Exchange Act. In that regard, we note that
Section 27 of the
      Exchange Act creates exclusive federal jurisdiction over all suits
brought to enforce any
      duty or liability created by the Exchange Act or the rules and
regulations thereunder, and
      Section 22 of the Securities Act creates concurrent jurisdiction for
federal and state courts
      over all suits brought to enforce any duty or liability created by the
Securities Act or the
      rules and regulations thereunder. If the provision applies to Securities
Act claims, please
      also revise your prospectus to state that there is uncertainty as to
whether a court would
      enforce such provision and that investors cannot waive compliance with
the federal
      securities laws and the rules and regulations thereunder. If this
provision does not apply
      to actions arising under the Securities Act or Exchange Act, please also
ensure that the
      exclusive forum provision in the governing documents states this clearly.
        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 16, 2019 Page 2
cc:       Eric T. Schwartz, Esq.
FirstName LastName