Waller Lansden Dortch & Davis, LLP 511 Union Street, Suite 2700 P.O. Box 198966 Nashville, TN 37219-8966

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May 8, 2018

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Attention: John Reynolds, Assistant Director, Office of Beverages, Apparel, and Mining

Dear Mr. Reynolds:

American Premium Water Corporation (the “Company”) is in receipt of the above-captioned Comment Letter (the “Comment Letter”) regarding the Company’s Offering Statement on Form 1-A filed with the Securities and Exchange Commission (the “Commission”) on March 26, 2017 (the “Offering Statement”). On behalf of the Company, we are responding to comments provided by the staff (the “Staff”) of the Commission.

For your convenience, this letter is formatted to reproduce your numbered comments in bold italicized text. In conjunction with these responses, the Company has filed today with the Commission Amendment No. 1 to its Offering Statement on Form 1-A (the “Amendment”).

Business, page 17

RESPONSE: In response to the Staff’s comment, in the Amendment, the Company inserted additional language regarding to clarify how it intends to utilize blockchain technology to support operations, specifically, that the Company seeks to acquire a blockchain solution that can be used as an exchange and platform for retailers and brands to launch their own utility token or tokens focused on rewards and loyalty, giving owners of such tokens the ability to purchase exclusive product from the brands as well as enjoy special discounts and promotions reserved for token holder. In addition, the Company added a risk factor that it believes addresses the material risks associated with operating in the blockchain and cryptocurrency sector. Please see pages 8,17 and 19 of the Amendment.

Plan of Operation, page 19

RESPONSE: In response to the Staff’s comment, in the Amendment, the Company, has inserted in to the Amendment the names of a number of the private companies that have expressed interest in entering into a transaction with you. In addition, the Company has added clarifying language in the Amendment discussing the steps it has taken to identify companies in the blockchain sector that the Company might acquire, specifically its retaining of International Money to assist the Company with the origination and evaluation of licensing and/or acquisition opportunities in the blockchain and cryptocurrency space. In addition, the Company has included its agreement with International Money, as amended, with the exhibits to the Amendment. Please see page 19 of the Amendment, as well as the related exhibits to the Amendment.

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We appreciate the opportunity to respond to your comments. If you have any questions during your review or I can assist in any way, please do not hesitate to contact me.

Sincerely,

/s/ Marc Adesso, Esq.

Waller Lansden Dortch & Davis, LLP