May 24, 2019

Wayne Anderson
President
Sylios Corp
501 1st Ave N., Suite 901
St. Petersburg, FL 33701

       Re: Sylios Corp
           Amendment No. 1 to Registration Statement on Form S-1
           Filed May 15, 2019
           File No. 333-230824

Dear Mr. Anderson:

      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 May 7, 2019
letter.

Registration Statement on Form S-1 filed May 15, 2019

Cover Page

1.     We note that you have added disclosure indicating that the registration
statement covers
       the resale by future shareholders of up to 6,750,000 shares of common
stock "to be issued
       to future shareholders." Please revise your prospectus to clarify that
you are registering
       the resale by your selling shareholders of 6,750,000 shares of common
stock comprised of
       750,000 shares issuable upon conversion of your Series D Preferred
Stock, 1,000,000
       issuable upon the exercise of a warrant and 5,000,000 issuable upon
conversion of
       convertible notes.
 Wayne Anderson
FirstName LastNameWayne Anderson
Sylios Corp
Comapany NameSylios Corp
May 24, 2019
May 24, 2019 Page 2
Page 2
FirstName LastName
Description of Business , page 4

2.       We note your revised disclosure in response to prior comments 2 and 4
regarding the
         number of shares you hold in The Greater Cannabis Company, Inc. and
AMDAQ Crop
         and reissue them in part. Please disclose the percentage interest of
your equity investment
         in each of these entities and revise to eliminate disclosure regarding
investments in which
         you are engaged to only a limited extent or tell us why you have
included such disclosure
         despite your limited ownership. Please also disclose how you intend to
provide funds to
         AMDAQ to be used to assist it in completing its "going public" event.
For example,
         please disclose whether such funds will be provided as a loan or
otherwise.
Risk Factors
Because directors and officers currently and for the foreseeable future will
continue to control
Sylios Corp..., page 38

3.       We note your revised disclosure stating that your President has
"considerable control over
         the outcome of any matter brought before shareholders for a vote."
Please further revise
         this risk factor to quantify the percentage of voting power held by
your President, giving
         effect to his ownership of the Series D Preferred Stock.
Financial Statements, page F-1

4.       Update your financial statements to comply with Rule 8-08 of
Regulation S-X and provide
         corresponding updated disclosures throughout your filing.
Exhibits

5.       Please file your unsecured convertible promissory notes that are in
technical default and
         referred to in Note H to your consolidated financial statements or
tell us why you believe
         you are not required to do so. Refer to Item 601(b)(10) of Regulation
S-K.
6.       Please have counsel revise its opinion to accurately describe and
quantify the shares of
         common stock offered by the selling shareholders. For example, please
have
         counsel clarify that the 637,500 shares that are currently issued and
outstanding "are"
         legally issued, fully paid and non-assessable and that the 6,750,000
shares of common
         stock comprised of 750,000 shares issuable upon conversion of your
Series D Preferred
         Stock, 1,000,000 issuable upon the exercise of a warrant and 5,000,000
issuable upon
         conversion of convertible notes "will be" legally issued, fully paid
and non-assessable.
General

7.       We note you revised disclosure in response to prior comment 1. Please
revise your
         registration fee table and your Selling Shareholders disclosure to
make corresponding
         changes.

         You may contact Joseph Klinko, Staff Accountant, at (202) 551-3824 or
Ethan Horowitz,
 Wayne Anderson
Sylios Corp
May 24, 2019
Page 3

Accounting Branch Chief, at (202) 551-3311 if you have questions regarding
comments on the
financial statements and related matters. Please contact Anuja A. Majmudar,
Attorney-Advisor,
at (202) 551-3844 or, in her absence, Karina Dorin, Attorney-Advisor, at (202)
551-3763, with
any other questions.



                                                          Sincerely,
FirstName LastNameWayne Anderson
                                                          Division of
Corporation Finance
Comapany NameSylios Corp
                                                          Office of Natural
Resources
May 24, 2019 Page 3
cc:       John E. Lux, Esq.
FirstName LastName