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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

AI Filing Summary & Sentiment

File numbers found in text: 000-53259

Date
Jan. 31, 2025
Author
/s/ William B. Barnett
Form
CORRESP
Company
POWERDYNE INTERNATIONAL, INC. (PWDY) (CIK 0001435617)

Letter

Division of Corporation Finance Office of Technology Securities and Exchange Commission 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

Show Raw Text
CORRESP
1
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