HART & HART, LLC
                                ATTORNEYS AT LAW
                             1624 Washington Street
                                Denver, CO 80203
William T. Hart, P.C.              ________                   harttrinen@aol.com
Will Hart                                                         (303) 839-0061
Fax: (303) 839-5414

                                  July 11, 2017

John Stickel
Mail Stop 3561
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C.  20549

      RE:   The Diamond Cartel, Inc.
            Registration Statement on Form S-1
            File No. 333-215884

     This office  represents  The Diamond  Cartel,  Inc. (the  "Company").  This
letter provides the Company's  responses to the comments received from the staff
by letter dated June 30, 2017. The paragraph  numbers in this letter  correspond
with the numbered paragraphs in the staff's comment letter.

     1. As stated on our letter to you of June 14,  2017,  below is a listing of
four  companies  that filed  registration  statements  with the  Securities  and
Exchange  Commission and which indicated in their  registration  statements that
they were "blank check" companies.

      Name                                Registration Number
      ------                              -------------------

      M.I. Acquisition, Inc.                  333-212675
      KLR Energy Acquisition Corp.            333-209041
      Stellar Acquisition III. Inc.           333-212377
      Forum Merger Corporation                333-216842

     At the time the registration statements of these issuers were filed, and at
the time these registration  statements became effective,  none of these issuers
had net tangible assets above  $5,000,000.  As a result,  and in accordance with
Rule  3a51-1 of the  Commission,  the  shares  which  were  registered  by these
companies  were penny stocks.  However,  the Commission has adopted the position
that an issuer will not be deemed to issue penny stock if it has a minimum of $5
million of net tangible assets immediately following its IPO.

     We believe the same  principle  should  apply to the  Company.  The Company
plans to acquire another entity solely with shares of its common stock. When the
Company enters into  negotiations  with the target entity Section (a)(2)(i) will
not apply  since the  Company  no  longer  has the  intention  of  acquiring  an
unidentified company.






      Rule 419 was designed to prevent issuers from:

          o    selling  stock to the public and using the  offering  proceeds to
               acquire a company which the investors  most likely never heard of
               at the time they made their investment; and

          o    not  providing  the  investors  with  the  right to  approve  the
               acquisition of the target company.

      In the case of the Company's offering:

          o    the Company is not receiving money from any investors; and

          o    the persons  that acquire the  securities  offered by the Company
               will have approved the terms and conditions of the acquisition.

     Section  508 of the Penny  Stock  Reform Act was not  intended to deal with
offerings which:

          o    do not involve the sale of securities for cash; and

          o    allow  investors to approve the terms of the offering  before any
               consideration is exchanged.

     By way of  example,  Section  508(b)(1)(B)  of the Penny  Stock  Reform Act
provides as follows:

          o    (B)  place  limitations  on the  use of  such  proceeds  and  the
               distribution  of securities by such issuer until the  disclosures
               required under subparagraph (A) have been made.

     In the case of the Company's offering,  there will be no cash proceeds and,
as discussed  in our letter of June 14, 2017,  the Company will not issue any of
its securities until the disclosures  required under Section  508(b)(1)(A)  have
been made.

     Likewise,  Securities Act Release 33-6932, which adopted Rule 419, provides
extensive  discussion  of the  "proceeds  received  pursuant  to a  blank  check
offering". See, for example, Sections II.A.1 and II.C. of Release 33-6932.

     Finally,  in the  type  of  offering  which  the  Company  proposes,  it is
impossible to comply with Rule 419(e).

     Nevertheless,  we  are of the  opinion  that  the  Company's  offering,  as
outlined  in our June 14, 2017 letter and in  Amendment  No. 2 to the  Company's
Registration  Statement,  complies  with the  spirit of Rule 419 and  avoids the
abuses which Rule 419 was designed to prevent.


                                       2



     2. The Company will remove the  reference  to itself as a "special  purpose
acquisition company".

     3. The Company  cannot provide the  disclosures  required by Form S-4 since
the Company has not, at this time, identified a potential acquisition.  Once the
Company has identified a potential acquisition,  as discussed in Amendment No. 2
to  its  Registration  Statement,  the  Company  will  provide  Form  S-4  level
disclosures  by  means  of  a  post-effective   amendment  to  its  registration
statement.

     4. Between 2005 and 2008, the Company:

          o    had  numerous  discussions  with  jewelers in New York's  diamond
               district concerning purchasing gems at wholesale prices;

          o    hired a consultant  to assist the Company in the  development  of
               its Business Plan;

          o    hired  a  consultant  to  develop  a  compensation  plan  for the
               Company's distributors; and

          o    developed a website;

          o    spent  approximately  $400,000  in an  effort  to  establish  the
               Company's business.

     See also the last  sentence  of the first  paragraph  of Section  II.A.  of
Release 33-6932:

        "Likewise,  start-up  companies with specific  business plans are
        not subject to Rule 419, even if operations have not commenced at
        the time of the offering."

     For these reasons, we believe the Company was not a "shell  company" when
it sold its 256,000 shares.

     If you should have any questions  concerning the  foregoing,  please do not
hesitate to contact the undersigned.

                                          Very Truly Yours,

                                          HART & HART, LLC

                                          /s/ William T. Hart

                                          William T. Hart



                                       3