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                              January 20, 2022

       Panagiotis N. Lazaretos
       Chief Executive Officer
       brooqLy, Inc.
       10101 S. Roberts Road
       Suite 209
       Palos Hills, Illinois 60465

                                                        Re: brooqLy, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed December 22,
2021
                                                            File No. 333-261835

       Dear Mr. Lazaretos:

              We have reviewed your 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 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 December 22, 2021

       Registration Statement Cover Page, page 1

   1.                                                   Please check the box on
the cover page to indicate that you are a smaller reporting
                                                        company, or advise.
       Prospectus Cover Page, page 3

   2.                                                   Please disclose
prominently on the cover page that the Company is currently controlled by
                                                        its three officers.
Additionally, describe the voting power expected to be held by the three
                                                        officers following this
offering.
 Panagiotis N. Lazaretos
FirstName  LastNamePanagiotis N. Lazaretos
brooqLy, Inc.
Comapany
January 20,NamebrooqLy,
            2022        Inc.
January
Page 2 20, 2022 Page 2
FirstName LastName
Cautionary Statements Regarding Forward-Looking Statements, page 6

3.       Section 21E of the Securities Exchange Act of 1934 and Section 27A of
the Securities Act
         of 1933 do not apply to initial public offerings. Accordingly, please
revise to remove these
         references.
Implications of Being an Emerging Growth Company, page 9

4.       Please update this section to reflect that the current revenue
threshold for an emerging
         growth company is $1.07 billion. Refer to the definition of Emerging
Growth Company in
         Rule 405 under the Securities Act.
Description of Business
Industry Background, page 35

5.       You disclose that your business offering is a unique combination of
social networking
         platforms and online food ordering platforms. However, there appears
to be no discussion
         in the prospectus of how your food ordering platforms operate. Please
revise or advise.
Exhibits

6.       Please file executed copies, rather than or in addition to the    Form
of" versions, of
         Exhibits 10.1, 10.2, 10.3, and 10.4.
7.       Please file a consent from your auditor as an exhibit. Refer to Item
601(b)(23) of
         Regulation S-K.
General

8.       Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communications.
        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.
 Panagiotis N. Lazaretos
brooqLy, Inc.
January 20, 2022
Page 3

       You may contact Melissa Walsh, Senior Staff Accountant, at (202)
551-3224 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
regarding
comments on the financial statements and related matters. Please contact Olivia
Bobes, Staff
Attorney, at (202) 551-7361 or Matthew Crispino, Staff Attorney, at (202)
551-3456 with any
other questions.



FirstName LastNamePanagiotis N. Lazaretos                Sincerely,
Comapany NamebrooqLy, Inc.
                                                         Division of
Corporation Finance
January 20, 2022 Page 3                                  Office of Technology
FirstName LastName