Exhibit 15d

GULF CHRONIC CARE INC.

12465 South Fort Street, Suite 240

PO Box 1382

Draper, Utah 84020

April 25, 2019

VIA EMAIL and EDGAR UPLOAD

Reganr@sec.gov

Mr. Ruairi Regan

Division of Corporation Finance

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Dear Mr. Regan:

This letter responds to comments of the staff of the United States Securities and Exchange Commission (the “Commission”), received by our legal counsel in response to your correspondence of April 24, 2019. Gulf Chronic Care, Inc (the “Company”) requests qualification of its above-referenced offering statement. In so doing, the Company acknowledges the following:

In response to the specific items set forth in your correspondence of March 13, 2019, the Company responds as follows:

Amendment No. 2 to Form 1-A

Exhibits

1. We reissue prior comment 2. Please file as exhibits to the offering statement all exhibits required by Paragraph 12 of Item 17 of Form 1-A, including, as examples, the legal opinion required as Exhibit 12 and the correspondence required as Exhibit 15(a). We note that you included a form of legal opinion in your correspondence but did not file it as an exhibit or revise your exhibit index. It also is unclear how you determined that the correspondence submitted on March 19, 2019, and April 1, 2019 does not need to be filed as exhibits as each of those letters reference the draft offering statement. Please advise or file the correspondence as previously requested.

Response:

An amended Form 1-A with the requested correspondence exhibits has been filed with EDGAR.

The Company hereby requests that the Commission provide final approval and qualification of the Form 1-A and related Offering Circular filed with the Commission in the form uploaded to EDGAR as soon as practicable.