Correspondence 0001493152-25-004422 from POWERDYNE INTERNATIONAL, INC. (PWDY) (CIK 0001435617) (PWDY)
POWERDYNE INTERNATIONAL, INC. (PWDY) (CIK 0001435617)
Date: Jan. 31, 2025 · CIK: 0001435617 · Accession: 0001493152-25-004422
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File numbers found in text: 000-53259
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CORRESP
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filename1.htm
BARNETT
& LINN
ATTORNEYS
AT LAW
60
Kavenish Drive • Rancho Mirage, CA 92270
www.barnettandlinn.com
WILLIAM
B. BARNETT
TELEPHONE:
442-274-7571
Attorney/Principal
wbarnett@wbarnettlaw.com
January
31, 2025
Division
of Corporation Finance
Office
of Technology
Securities
and Exchange Commission
100
F Street NE
Washington
D.C. 20549
Attn:
Joseph Kempf, Staff Attorney
Robert
Littlepage, Staff Attorney
Re:
Powerdyne International, Inc. (the “Company”)
Form
10-K for the Fiscal Year Ended December 31, 2023
Filed
May 8, 2024
File
No. 000-53259
Dear
Mr. Kempf:
Please
accept my apology for the lateness of this response to your December 19, 2024, comment letter to our client, Powerdyne International,
Inc.
Form
10-K for the Fiscal Year Ended December 31, 2023
Report
of Independent Registered Public Accounting Firm, Page F-2
1. In
accordance with your comment, we hereby acknowledge that the Company’s auditor, Olayinka
Oyebola & Co., has been charged by the Securities and Exchange Commission (the “SEC”)
with aiding and abetting violations of the antifraud provisions of the federal securities
law. We also agree to disclose such information in the Company’s future filings with
the SEC, including how, if such charges were upheld and penalties and injunctive relief were
imposed, such actions would impact on the Company and any investment in the Company’s
securities.
We
believe that we have responded to all your comments fairly and reasonably. Please do not hesitate to contact the undersigned as soon
as possible should you have any further questions or comments.
Thank
you for your cooperation and courtesies in this matter.
Very truly yours,
/s/ William B. Barnett
Barnett & Linn
William B. Barnett
WBB:
lg
cc/
Mr. O’Rourke, CEO