February 4, 2020

Brian S. John
Chief Executive Officer
CBD Brands, Inc.
725 N. Hwy A1A, Suite C-106
Jupiter, FL 33477

       Re: CBD Brands, Inc.
           Amendment No. 2 to Draft Registration Statement on Form S-1
           Submitted January 21, 2020
           CIK No. 0001760903

Dear Mr. John:

      We have reviewed your amended draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1 submitted January 21, 2020

Prospectus Summary
Business Operations, page 1

1.     We note your response to prior comment 1. Please revise your summary to
disclose the
       current status of the four additional sun care products that are in
"various stages of FDA
       required testing." To the extent that you have not started FDA testing,
as indicated by
       your disclosure that you plan to "commence" testing, please revise to
make this clear.
       Please also revise your business section to discuss each of these
products. In your revised
       business section disclosure, please provide a description of these
products and the current
       status of development.
 Brian S. John
FirstName LastNameBrian S. John
CBD Brands, Inc.
Comapany NameCBD Brands, Inc.
February 4, 2020
Page 2
February 4, 2020 Page 2
FirstName LastName
Use of Proceeds, page 22

2.       We note your response to prior comment 5. Please revise your filing to
provide consistent
         disclosure regarding your use of proceeds for your product
candidate(s), including the
         amounts to be allocated to each candidate, and how far in the
development of the
         candidate you expect to reach with the offering proceeds. In this
regard, we note that your
         use of proceeds disclosure currently indicates that you will be
allocating proceeds to
         multiple products and the disclosure on page 32 indicates your plan to
initiate the
         development of other products in parallel with your CaniDermRX topical
solution.
         However, your breakout of "CaniDerm RX Products" here on page 22
appears limited to
         eczema.
       You may contact Kristin Lochhead at 202-551-3664 or Kate Tillan at
202-551-3604 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jeffrey Gabor at 202-551-2544 or Mary Beth Breslin at 202-551-3625 with
any other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Life
Sciences
cc:      Arthur Marcus