SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 29, 2025

Hossein Haririnia
Treasurer
HNO International, Inc.
41558 Eastman Drive, Suite B
Murrieta CA 92562

 Re: HNO International, Inc.
 Form 10-K for the fiscal year ended October 31, 2024
 Filed March 20, 2025
 File No. 000-56568
Dear Hossein Haririnia:

 We have reviewed your filing and have the following comments.

 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 to this letter, we may have additional
comments.

Form 10-K for the fiscal year ended October 31, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Results of Operations, page 25

1. Revise the discussion of Operating Expenses to quantify the amounts and
the
 underlying reasons for the changes between comparative periods. For
example, the
 discussion may describe why general and administrative expenses
increased by
 $557,202, share based compensation decreased $405,812, and the reason
for the
 increase in depreciation and amortization expense of $142,732. See Item
303(b)(2) of
 Regulation S-K.
Liquidity and Capital Resources, page 25

2. Expand your discussion of Liquidity and Capital Resources to disclose
any material
 commitments for capital expenditures and disclose the general purpose of
such
 commitments and the anticipated sources of funds to fulfill them, as
required by Item
 303(b)(1)(ii) of Regulation S-K.
 May 29, 2025
Page 2

Report of Independent Registered Public Accounting Firm, page F-2

3. Please have your auditor remove the language in the second paragraph
under Basis of
 Opinion which states and auditing standards generally accepted in the
United States.
 Please refer to PCAOB Auditing Standard 3101.
Balance Sheets, page F-4

4. On page 6, you disclose that you have taken delivery of 10 hydrogen
carbon cleaners
 for sale to customers in mid-March 2025. Your disclosure indicates that
these items
 are held for sale in the ordinary course of business. Please disclose if
the hydrogen
 carbon cleaners have been accounted for as inventory under ASC 330. If
not, please
 explain the accounting treatment, including the accounting guidance that
is applicable.
Statements of Operations, page F-5

5. We note the presentation of stock-based compensation as a separate line
item. The
 significant accounting policy on page F-12 states that the expense in
included within
 the same income statement line as cash compensation for consultants and
employees
 who receive the awards. Please revise the statements of operations
presentation and
 the footnote to comply with SAB Topic 14.F.
Note 3 - Summary of Significant Accounting Policies, page F-12

6. Please provide disclosure regarding segments, as required by ASC
280-10-50 and
 Accounting Standards Update No. 2023-07.
Form 10-Q for the fiscal quarter ended January 31, 2025
Note 2 - Financial Statement Restatement, page 9

7. We note that the interim period as of a for the three months ended
January 31, 2024
 presents adjustments for which there are no descriptions. We refer you
to adjustments
 to Property and equipment, net, Long-term asset, net, Right-of-use
asset, and Lease
 liability. Please provide a description of the nature of these errors.
See ASC 250-10-
 50-7.
 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 Brian McAllister at 202-551-3341 or Kimberly Calder at
202-551-3701
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
</TEXT>
</DOCUMENT>