2855 Sanford Ave SW #30666
Grandville, MI, 49418
+44 01455-290363
April 24, 2018
VIA EMAIL AND EDGAR
Beverly Singleton
Melissa Raminpour
Sonia Bednarowski
John Dana Brown - Attorney Advisor
U.S. Securities & Exchange Commission
Division of Corporate Finance
100 F. Street, N.E.
Washington, D.C. 20549
BednarowskiS@SEC.GOV
Re: Arazu Incorporated
Amendment No. 3 to Registration Statement on Form S-1
Filed March 23, 2018
File No. 333-221327
Dear Sirs/Mesdames:
This letter is written in response to the submission of an amended registration statement with the U.S. Securities and Exchange Commission (hereafter, the “Commission”) on Form S-1 (“Registration Statement”), and filed on March 23, 2018, by Arazu Incorporated, a Florida corporation (the “Company”), and its further receipt of your email to the Company, dated April 6, 2018. We have reproduced your 2 comments below, highlighted in bold, with our responses following immediately thereafter.
General
| 1. | COMMENT. We note your response to our prior comment 3 and reissue. Please revise your prospectus summary section and your risk factors section to disclose the date by which your current cash will fund Arazu if you are unable to obtain loans. In this regard, we note your disclosure on page 2 that your current cash in combination with related party loans will be able to fund Arazu until June 30, 2018. |
RESPONSE: We have further revised the prospectus Summary and Risk Factors as requested.
| 2. | COMMENT. Please update your financial statements for your interim period ended January 31, 2018 pursuant to Rule 8-08 of Regulation S-X. The related financial information, such as MD&A should also be updated. |
RESPONSE:The Company has updated its financial statements to include the period ended January 31, 2018 as requested.
U.S. Securities & Exchange Commission
Division of Corporate Finance
April 24, 2018
Page 2
We will file this letter as correspondence via EDGAR contemporaneous with its dispatch to you via email. In the meantime, please feel free to call John D. Thomas at (801) 816-2536 or respond via email or facsimile if you have any further comments or questions.
Very truly yours,
ARAZU INCORPORATED
/s/ Paul Clewlow
Paul Clewlow
Chief Executive Officer