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                             October 18, 2023

       Liliia Havrykh
       Chief Executive Officer
       IMA Tech Inc.
       34 N Franklin Ave 687
       Pinedale, WY 82941

                                                        Re: IMA Tech Inc.
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed October 5,
2023
                                                            File No. 333-273283

       Dear Liliia Havrykh:

            We have reviewed your amended registration statement and have the
following
       comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a 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 letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our September 22,
2023 letter.

       Amendment No. 2 on Registration Statement on Form S-1

       Our Company, page 9

   1.                                                   We note your response
to prior comment 2. In light of your limited operating history and
                                                        limited operating
expenses to date, please revise to provide a more complete discussion
                                                        regarding the
development and implementation of your "proprietary AI models." As part
                                                        of your disclosure,
clarify how you iteratively developed "advanced machine learning
                                                        techniques" and trained
neural network models using curated datasets, with specificity,
                                                        including whether your
sole officer independently developed the underlying software or
                                                        codebase. To the extent
the AI models were not developed by your sole officer, clarify if
                                                        they were off-the-shelf
AI program or models provided by third parties or if they were
                                                        pre-selected
algorithms, AI models, or chatbots.
 Liliia Havrykh
FirstName  LastNameLiliia Havrykh
IMA Tech Inc.
Comapany
October  18,NameIMA
             2023    Tech Inc.
October
Page  2 18, 2023 Page 2
FirstName LastName
Audited Financial Statements
Note 5. Related Party Transactions, page F-6

2.       We note the revised disclosure regarding the loan from the CEO and
sole director of the
         Company. Please revise to disclose the total amount available under
the loan agreement.
         Similarly revise the note disclosure in the July 31, 2023 financial
statements.
       Please contact Joyce Sweeney at 202-551-3449 or Christine Dietz at
202-551-3408 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Marion Graham at 202-551-6521 or Matthew Derby at 202-551-3334 with any
other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Technology
cc:      Robert Zepfel