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                             May 12, 2021

       Kim Boyce
       Chief Executive Officer
       Reflect Scientific Inc.
       1266 South 1380 West
       Orem, UT 84058

                                                        Re: Reflect Scientific
Inc.
                                                            Amendment No. 1 to
Registration Statement on Form 10
                                                            Filed April 29,
2021
                                                            File No. 000-31377

       Dear Mr. Boyce:

              We have reviewed your filing 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

            After reviewing your response and any amendment you may file in
response to these
       comments, we may have additional comments.

       Amendment No. 1 to Registration Statement on Form 10

       Cryometrix Freezers, page 5

   1.                                                   We note your revised
disclosure in response to prior comment 3. Please remove
                                                        statements that you
have been able to develop products that you believe offer a superior
                                                        value proposition to
the customer "over any other competing and existing products in the
                                                        market" and statements
that your freezers "will be the desired technology to which the
                                                        industry will move,
providing [you] the opportunity to gain a significant market share in
                                                        this large market," as
such statements appear premature and speculative. Additionally,
                                                        please clarify how your
technology is different than other ultra-low temperature freezers,
                                                        including those
developed by Thermo Fisher Scientific and Sanyo Corporation.
 Kim Boyce
FirstName  LastNameKim  Boyce
Reflect Scientific Inc.
Comapany
May        NameReflect Scientific Inc.
     12, 2021
May 12,
Page 2 2021 Page 2
FirstName LastName
Competition, page 6

2.       We note your revised disclosure in response to prior comment 4,
         including your competitive position with respect to products other
than the Cryometrix
         freezer. Please expand your disclosure to also discuss your
competitive position with
         respect to the Cryometrix freezers. Please also disclose the Company's
methods of
         competition.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

        You may contact Jeanne Bennett at 202-551-3606 or Vanessa Robertson at
202-551-3649
if you have questions regarding comments on the financial statements and
related
matters. Please contact Deanna Virginio at 202-551-4530 or Laura Crotty at
202-551-7614 with
any other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Life
Sciences
cc:      Branden T. Burningham, Esq.