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                              November 9, 2022

       Byron L. Bennett
       President
       Zergratran SA, Inc.
       501 East Las Olas Blvd., Suite 207
       Fort Lauderdale, FL 33301

                                                        Re: Zergratran SA, Inc.
                                                            Amendment No. 1 to
Offering Statement on Form 1-A
                                                            Filed October 31,
2022
                                                            File No. 024-12006

       Dear Byron L. Bennett:

             We have reviewed your amended offering 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 offering 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 offering statement and the
information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
October 18, 2022 letter.

       Amendment No. 1 to Form 1-A filed October 31, 2022

       Cover Page

   1.                                                   We note your disclosure
here and under Plan of Distribution and Selling Securityholders
                                                        continues to state that
your offering will terminate at the earlier of the date at which the
                                                        maximum amount has been
sold or the date at which the offering is earlier terminated by
                                                        the company at its sole
discretion and reissue comment 2. Please revise your disclosure to
                                                        comply with Rule
251(d)(3)(i)(F) of Regulation A as it appears that your offering may
                                                        extend beyond three
years.
 Byron L. Bennett
Zergratran SA, Inc.
November 9, 2022
Page 2

       Please contact Michael Purcell, Staff Attorney at 202-551-5351 or Karina
Dorin, Staff
Attorney at 202-551-3763 with any questions.



                                                           Sincerely,
FirstName LastNameByron L. Bennett
                                                           Division of
Corporation Finance
Comapany NameZergratran SA, Inc.
                                                           Office of Energy &
Transportation
November 9, 2022 Page 2
cc:       Jamie Ostrow
FirstName LastName