SecProbe.io

May 28, 2025
Michael Farr
Chief Executive Officer
Superstar Platforms Inc.
586 Cobb Parkway S., Suite 900
Marietta, GA 30060
Re:Superstar Platforms Inc.
Registration Statement on Form 10-12G
Filed May 1, 2025
File No. 000-56744
Dear Michael Farr:
            We have reviewed your filing and have the following comment(s).
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to this
letter, we may have additional comments.
Registration Statement on Form 10-12G filed May 1, 2025
Item 1. Business
1.We note the following disclosure: "Superstar Platforms, a leading national technology
conglomerate, is the parent company that owns and controls a diversified portfolio of
subsidiaries across various industries. Growth will primarily be driven through
strategic acquisitions." Please revise to expand on your business developments,
including those of your "subsidiaries." Please refer to the applicable provisions of
Item 101 of Regulation S-K.
2.Please refer to the last full sentence under subsection titled "Business." Please revise
to provide the number of shares for each class of securities that the Company is
authorized to issue.
Item 1A. Risk Factors
Please revise the risk factors section generally to disclose risk factors that are
specific to you, your business operations, and your securities. In this regard, we note 3.

May 28, 2025
Page 2
certain references that do not appear to be relevant to your business operations,
including references to HIPPA, and your statement that you are "providing secure
information storage and maintaining the confidentiality of proprietary, confidential
and trade secret information" of your clients.
4.We note your reference to "acquisition of the Group." Please revise to provide the
definition of "the Group," and supplement your disclosure to describe such
transaction, or advise. In this regard, we also note your reference to "the recent
acquisition" under "ITEM 3-Properties." To the extent you are referring to the same
"acquisition" transaction, please also revise to provide additional details under that
section.
Item 2. Financial
5.Please provide the information called for by Items 303 and 305 of Regulation S-K, or
advise. We note that, while you refer the readers to "'Management’s Discussion and
Analysis of Financial Condition and Results of Operations' in Exhibit 99.1," no such
exhibit has been filed with the registration statement. To the extent you are a smaller
reporting company, advise us whether you believe Item 305(e) of Regulation S-K
applies and revise your disclosure accordingly.
Item 4. Security Ownership of Certain Beneficial Owners and Management
6.Please update the information in this section as of the most recent practicable date and
provide the address of beneficial owners who are not "[y]our executive officers and
directors," including MacFund Holdings, Convenient Grourmet Group LP, and
Venkateswarlu Garikapati. Refer to Item 403 of Regulation S-K.
Item 5. Directors and Executive Officers
7.Please revise this section generally to provide the information called for by Item 401
of Regulation S-K, including all positions and offices with the registrant held by each
director and executive officer, family relationships, and business experience during
the past five years of each director and executive officer.
Item 6. Executive Compensation
8.Please provide all the information called for by Items 402 and 407(e)(4) of Regulation
S-K. To the extent you are a smaller reporting company, please advise us whether you
believe Item 407(g)(1) applies and revise your disclosure accordingly.
Item 7. Certain Relationships and Related Transactions, and Director Independence
9.Please provide all the information called for by Items 404 and 407(a) of Regulation S-
K as of the latest practicable date.

May 28, 2025
Page 3
Item 10. Recent Sales of Unregistered Securities
10.Please provide, to the extent relevant, the information called for by Item 701 of
Regulation S-K as to Beneficial Owners disclosed under "ITEM 4-Security
Ownership of Certain Beneficial Owners and Management."
Item 11. Description of Registrant's Securities to be Registered
11.Please revise to provide all the information called for by Item 202 of Regulation S-K.
In addition, we note your disclosure regarding your Preferred Stock and "EROP
Enterprises LLC." As this appears to be the first time such disclosure is presented in
your registration statement, please revise the registration statement throughout where
relevant to include the appropriate disclosure as to your Preferred Stock and EROP
Enterprises LLC.
Item 15. Financial Statements and Exhibits
Balance Sheets
12.We note the amounts Due to Related Party on the balance sheets. Please provide the
disclosures required by ASC 850-10-50-1.
Notes to the Audited Financial Statements
Note 4 - Common Stock
13.Please revise this footnote to describe the transactions underlying the issuance of
shares during 2023 and 2024.
Statements of Operations
14.Please correct the typographical error and disclose the amount of officers' salary
incurred during the year ended December 31, 2023.
General
15.Please revise the registration statement to provide a clear picture of your business and
current operations. For example, while you state that you are a "parent company that
owns and controls a diversified portfolio of subsidiaries across various industries,"
your disclosure focuses on PawnTrust, Inc. as your main current operation. In other
parts of your disclosure, you mention "[y]our consultants" and "[y]our products and
services," but it is unclear what the role of your "consultants" are, or what your
"products and services" consist of. We also note that your financial statements
disclose no assets except for cash. Please revise the registration statement throughout
to clearly differentiate between activities you have implemented to date, activities you
are in the process of implementing, and those that will be done in the future. We note
that the disclosure in this filing appears, in part, anticipatory in nature. In this regard,
we note your "plans to leverage Artificial Intelligence" into PawnTrust. To the extent
you discuss your future plans for operations throughout the filing, such as
incorporating Artificial Intelligence onto your platform, the discussion should be
balanced with a time frame for implementing future plans, the steps and costs
involved, and any obstacles involved before you can commence the planned
operations, including the need for additional financing. If financing is currently not
available, please make that clear.

May 28, 2025
Page 4
16.You have checked the box for "Non-accelerated filer" but not "Smaller reporting
company." You also state in the risk factor section, however, that you "are a 'smaller
reporting company.'" Please revise to correctly identify the status of the Company.
17.Please revise the registration statement generally to provide up to date information as
of the most practicable date. For example, we note that, in certain sections, you
provide information as of December 31, 2024, including in regards to the total number
Common Stock issued and outstanding under Item 4. In other sections, however,
information is provided as of March 31, 2025, April 15, 2025, or April 16, 2025,
including, for example, under Item 11 as follows: "Superstar Platforms Inc. has
authorized one billion shares of $0.001 par value Common Stock of which
177,231,656 were issued and outstanding as of each of April 16, 2025." Please revise
for consistency.
18.Please be advised that your registration statement will automatically become effective
60 calendar days after filing. Upon effectiveness, you will become subject to the
reporting requirements of the Securities Exchange Act of 1934, even if we have not
cleared comments. In the event it appears that you will not be able to respond to all of
our comments by the 60th day, you may wish to consider withdrawing your
registration statement and refiling it. Please confirm your understanding.
            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.
            Please contact Ta Tanisha Meadows at 202-551-3322 or Lyn Shenk at 202-551-3380
if you have questions regarding comments on the financial statements and related
matters. Please contact Eddie Kim at 202-551-8713 or Dietrich King at 202-551-8071 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services