June 4, 2019

Steven Raack
Chief Executive Officer
Vitalibis, Inc.
3960 Howard Hughes Parkway, Suite 500
Las Vegas, NV 89169

       Re: Vitalibis, Inc.
           Registration Statement on Form S-1
           Filed May 16, 2019
           File No. 333-231550

Dear Mr. Raack:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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.

Form S-1 filed May 16, 2019

General

1.     We note your disclosure on the cover page and elsewhere that "[t]he
specific terms of any
       securities to be offered by [you] . . . and the specific manner in which
they may be
       offered, will be described in a supplement to [your] prospectus."
Accordingly, this
       appears to be a delayed offering under Rule 415 of the Securities Act.
Please provide us
       with your detailed legal analysis regarding why you believe you are
eligible to conduct a
       delayed offering under Rule 415 of the Securities Act. Alternatively,
please revise to
       provide all required disclosure regarding the primary offering and the
securities offered
       therein in this registration statement, or remove the references to a
primary offering from
       this registration statement.
 Steven Raack
Vitalibis, Inc.
June 4, 2019
Page 2


        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Joshua Lobert, Staff Attorney, at 202-551-7150 or Sara
von Althann, Staff
Attorney, at 202-551-3207 with any questions.



                                                           Sincerely,
FirstName LastNameSteven Raack
                                                           Division of
Corporation Finance
Comapany NameVitalibis, Inc.
                                                           Office of Real
Estate and
June 4, 2019 Page 2                                        Commodities
FirstName LastName