November 30, 2020


Paul Moody
President and Director
Turnkey Solutions, Inc.
780 Reservoir Avenue, #123
Cranston, RI 02910

       Re:    Turnkey Solutions, Inc.
              Schedule 14F-1
              Filed November 25, 2020
              File No. 005-91859

Dear Mr. Moody:

       We have reviewed the above-captioned filing and have the following
comment.

       Please respond to this letter by amending the filing, by providing the
requested
information, or by advising us when you will provide the requested response. If
you do not
believe our comment applies to the Company   s facts and circumstances or do
not believe an
amendment is appropriate, please tell us why in your response.

       After reviewing any amendment to the filing and any information you
provide in
response to this comment, we may have additional comments.

General

1.     Your disclosure indicates that Mr. Shirai, Mr. Sasaki, and Mr. Ishizuka
were appointed as
       directors on November 18, 2020. Please advise us whether or not the
Company timely
       fulfilled its disclosure obligations under Rule 14f-1 to transmit the
information statement
       not less than 10 days prior to the date that any such new director take
office.

        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.
 Paul Moody
Turnkey Solutions, Inc.
November 30, 2020
Page 2

        Please direct any questions to me at (202) 551-7951.


                                                           Sincerely,

                                                           /s/ Joshua Shainess

                                                           Joshua Shainess
                                                           Special Counsel
                                                           Office of Mergers
and Acquisitions