September 25, 2019

Pedro C. Gonzalez
Chief Financial Officer
Stratus Capital Corporation
8480 East Orchard Road, Suite 1100
Greenwood Village, Colorado 80111

       Re: Stratus Capital Corporation
           Form 10-12G
           Filed September 9, 2019
           File No. 000-56093

Dear Mr. Gonzalez:

        We have undertaken a preliminary review of the registration statement,
and have the
following comment. We are deferring any further review of your filing until you
respond to this
letter by amending your registration statement to comply with our comment. If
you do not
believe our comment applies 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 this
comment, we will
likely have additional comments.

Form 10

General

1.    Please revise the registration statement to include the required interim
financial
      information for the six months ended June 30, 2019. Reference is made to
Rule 8-08 of
      Regulation S-X. Please note that the Form 10 goes effective by lapse of
time 60 days
      after the original filing date, pursuant to Section 12(g)(1) of the
Securities Exchange Act
      of 1934. To the extent you are unable to update your financial statements
prior to
      effectiveness, please withdraw the Form 10 and re-file a new Form 10 that
is in
      compliance with this comment.
 Pedro C. Gonzalez
FirstName LastNamePedro C. Gonzalez
Stratus Capital Corporation
Comapany 25, 2019
September NameStratus Capital Corporation
Page 2
September 25, 2019 Page 2
FirstName LastName
        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. Please contact Paul Cline, Staff Accountant, at
202-551-3851 or Wilson Lee,
Staff Accountant, at 202-551-3468 with any questions.




                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Real
Estate and
                                                           Commodities