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                               November 7, 2023

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

                                                        Re: IMA Tech Inc.
                                                            Amendment No. 3 to
Registration Statement on Form S-1
                                                            Filed October 27,
2023
                                                            File No. 333-273283

       Dear Liliia Havrykh:

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

              Please respond to this letter by amending your registration
statement and providing the
       requested information. 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 letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our October 18, 2023
letter.

       Form S-1/A filed October 27, 2023

       Our Company, page 9

   1.                                                   We note your response
to prior comment 1. Please provide a more complete discussion
                                                        regarding the
development of your codebase, including whether you entered into any
                                                        material agreements
with external developers and the terms of those agreements, quantify
                                                        the costs for the
periods presented, and file the agreements as exhibits, or tell us why it is
                                                        not required. In
addition, to the extent true, clarify that the company has limited control
                                                        over the open-source
software used and provide corresponding risk factor disclosure as
                                                        appropriate.
 Liliia Havrykh
FirstName  LastNameLiliia Havrykh
IMA Tech Inc.
Comapany 7,
November   NameIMA
              2023    Tech Inc.
November
Page  2    7, 2023 Page 2
FirstName LastName
       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