SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3561
June 22,2009
ViaInternational Mail
Larysa Dekhtyaruk
Chief Executive Officer
Loran Connection Corp.
190 Dzerjinskogo St., Ovidiopol,
Odesska obl., 67801,
Ukraine
Re: Loran Connection Corp.
Registration Statement on Form S -1
FiledMay 28, 2009
File No. 333 -159517
Dear M s. Dekhtyaruk :
We have reviewed your filing and have the following comments. Where
indicated, we think you should revise your document in response to these comments. If
you disagree, we will conside r your explanation as to why our comment sareinapplicable
or a revision is unnecessary. Please be as detailed as necessary in your explanation. In
some of our comments, we may ask you to provide us with information so we may better
understand your discl osure. After reviewing this information, we may raise additional
comments.
Please understand that the purpose of our review process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in y our filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our
review. Feel free to call us at the telephone numbers l isted at the end of this letter.
General
1.We n ote the disclosure on page 25 that you will need to obtain additional
financing to operate y our business for the next six months. Please advise us what
consideration youhave given to providing your financial statements on a
liquidation basis.

Larysa Dekhtyaruk
Loran Connection Corp.
June 22, 2009
Page 2
Calculatio n of Registration Fee, page 2
2.We note that you have placed the number (2) indicating a second footnote to this
table regarding your reported registration fee. The underlying footnote, however,
is missing. Please either provide the footnote or delete the reference number.
Prospectus Cover Page, page 3
3.Please disclose here that there is no current market for your shares.
Prospectus Summary, page 5
4.Please add disclosure in this section noting that your auditor has issued a going
concern opinion.
5.Please disclose prominently in the Summary that you will need to obtain
additional financing to operate your business for the next six months. See page
25.
Termination of the Offering, page 5
6.Please revise the sentence to add “but in no event later than [ twoyears from the
effective date of the registration] ”and fill in the blank in your 424 prospectus.
Risk Factors, page 6
7.Please add a risk factor addressing the impact of the current worldwide slump on
the tourist market in Ukraine, or tell us why it is in applicable.
When our Shares of Common Stock Commence Trading, page 10
8.We suggest changing the “when” in the heading to “if.” Also, please revise to
clarify that one of the factors that will sharply limit liquidity of the shares is the
extremely small nu mber of holders.
Any Additional Funding We Arrange, page 11
9.Please quantify here the amount of additional capital you believe you will need in
order for your business plan to succeed. Elsewhere, in an appropriate place,
please give a breakdown of this a mount by category so that investors can judge
how realistic your business plan is.

Larysa Dekhtyaruk
Loran Connection Corp.
June 22, 2009
Page 3
We have no experience as a public company, page 11
10.Please add to this risk factor that you may be unable to absorb the costs associa ted
with being a public company and, if possible, provide your best estimate of the
costs of being public so that investors can gauge the seriousness of the risk.
Dilution, page 12
11.Since there is no dilution involved here because the shares of the selling
shareholders are already outstan ding, we suggest you delete this section.
Description of Securities, page 16
12.We note your statement in this section that as of March 31, 2009, you had 30
stockholders of record. This date is inconsistent with the date provided on page
22, which provides therecord date as the date of the registration statement.
Please revise to reconcile this inconsistency. Refer alsoto comment 21.
Description of Business, page 18
13.Please r evise this section to disclose the current state of your business. N ote that
the description of your business is intended to be an accurate description of your
business at the time of effectiveness. The majority of your current disclosure ,
however, provides a description of your aspirations and what you anticipate for
the company once it is fully operational .You should, additionally, provide
information regarding any affirmative steps that you have taken to move your
business closer to a stage thatyou anticipate will generate revenue.
14.Please revise the second sentence of the fi rst par agraph of this section to clarify
that one of the services you intend to provide is “finding” accommodations, not
providing accommodations. See the third bullet under “Reception and Support
Services.”
15.Please substantially revise the Business secti on to eliminate marketing language
aimed at tourists such as the last sentence of the third paragraph of this section:
“Hospitable Ukrainians will be delighted to introduce Slavic culture to their
foreign guests.” This prospectus is for selling securitie s, not vacations.
Reception and Support Services, page 18
16.As drafted, your business plan here does not make sense. Please revise to clarify,
if true, that your company will have already arranged such matters as
accommodation, organization of tours, etc. , prior to arrival of your customers at
the airport, not “at and after reception.”

Larysa Dekhtyaruk
Loran Connection Corp.
June 22, 2009
Page 4
17.If other venues, such as tourist bureaus, provide some or all of your support
services for free, such as providing a list of restaurants or inexpensive
accommodations, please disclose and clarify why you believe that tourists would
pay you for services available elsewhere for free.
Website Marketing Strategy, page 20
18.Please revise the first sentence of this section to disclose the anticipated cost of
developing your websit e, if known.
19.Please revise to clarify the terms of your purchase of advertising space from the
US–Ukraine Foundation of Washington, D.C. You have not identified any
expenses in your financials that would reflect this. If the costs will be paid at a
later date, please discuss the terms of this future commitment in your
Management’s Discussion and Analysis Section and how it will affect your
liquidity .Also, please file the agreement as an exhibit with your next amendment.
Offices, page 21
20.Please tell us why you have selected the completion of the offering as the date
you will establish an office elsewhere. We note that this is a selling shareholder
offering which will not provide any funds for your company.
Market for Common Equity and Related Shareh older Matters, page 22
21.Please p rovide adefinitive record date for the number of your stockholders . This
measurement should be as of the most recent practicable date. Refer to Item 201
of Regulation S -K.
22.Please revise the first sentence to clarify that the 2.9 million shares will be
available for resale subject to the limitations you mention once you are subject to
the 34 Act for 90 days.
Plan of Operation, page 24
23.Please revise in the next amendment to disclose the costs you are budgeting for
each of the items mentioned. Also, please file any agreements which you have
negotiated and describe their terms in the Business section.
Available Information, page 26
24.Please disclose whether you will be required to file reports, other than this
registration statement, with the Securities and Exchange Commission and, if so,
what reports will be required. Also ,disclose whether you will be required to send
annual reports to security holders. If not, disclose whether you will do so

Larysa Dekhtyaruk
Loran Connection Corp.
June 22, 2009
Page 5
voluntarily and whether you will provide audited financials with the reports .
Refer to Item 101(h)(5) of Regulation S -K.
Security Ownership of Certain Beneficial Owners and Management, page 29
25.Please revise this table to provide separate disclosures for each beneficial owner ,
required under Item 403 ,to show to the number of shares owned by each and the
percentage of the outstanding shares those number s represent . This disclosure
should be in addition to the disclosure regarding the percentage of ownership by
management in the ag gregate.
Certain Relationships and Transactions, page 29
26.Please revise to disclose the sale of shares to Larysa Dekhtyaruk and Artem Kruk,
both related parties, in this section.
27.Please also revise to disclose within this section the transaction discus sedunder
Note 5 to your financial statements onpage F -11.Include the name of the related
party.
Outside Back Cover Page
28.Please add the dealer prospectus delivery obligation language required by Item
502(b) of Regulation S -K.
Other Expenses of Issu ance and Distribution, page II -1
29.Please revise to disclose printing fees associated with your distribution of the
prospectus, if any.
Recent Sales of Unregistered Securities, page II -3
30.We note that the dates for your issuance of shares differ between pa ragraphs one
and four of this section. The first paragraph states that you issued 900,000 shares
to Larysa Dekhtyaruk on November 28, 2008. The fourth paragraph states,
however, that 2,900,000 shares, which appear to include the 900,000 shares
discussed in the first paragraph, were issued on December 4, 2008. Please revise
to reconcile this inconsistency.
31.Similarly, the sixth paragraph in this section states that you completed your
offering of 1,890,000 shares in a private placement on March 31, 2009. On page
12, however, you state that the private placement of the 1,890,000 shares was
completed on March 19, 2009. Please revise to reconcile this inconsistency.

Larysa Dekhtyaruk
Loran Connection Corp.
June 22, 2009
Page 6
Regulation S Compliance, page II -4
32.Please revise the last paragraph in this section to id entify which of the instruments
you list (e.g., your bylaws or a contract) requires you to refuse the transfer of
securities not made in accordance with the provisions of Regulation S.
Undertakings, page II -5
33.Please delete the last two paragraphs of you rundertakings.
Exhibit 3.1
34.Please refile this exhibit with the entire articles of incorporation.
Exhibit 5.1
35.Either revise your legal opinion to include consent to the reference to your firm in
the prospectus or file a separate consent doing so in the next amendment.
**********
As appropriate, please amend your registration statement in response to these
comments. You may wish to provide us with marked copies of the amendment to
expedite our review. Please furnish a cover letter with your amendment that keys your
responses to our comments and provides any requested information. Detailed cover
letters greatly facilitate our review. Please understand that we may have additional
comments after reviewing your amendmen t and responses to our comments
Weurge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all information required under
the Securities Act of 1933 and that they have provided all information investors requi re
for an informed investment decision. Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
Notwithstanding our co mments, in the event the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the
time of such request, acknowledging that:
 should the Commission or the staff, acting pursuant to dele gated authority,
declare the filing effective, it does not foreclose the Commission from taking any action
with respect to the filing;
 the action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and

Larysa Dekhtyaruk
Loran Connection Corp.
June 22, 2009
Page 7
 the company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the C ommission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Division of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.
We will consider a written request for acceleration of the effective date of the
registration statement as confirmation of the fact that those requesting acceleration are
aware o f their respective responsibilities under the Securities Act of 1933 and the
Securities Exchange Act of 1934 as they relate to the proposed public offering of the
securities specified in the above registration statement. We will act on the request and,
pursuant to delegated authority, grant acceleration of the effective date.
We direct your attention to Rules 460 and 461 regarding requesting acceler ation
of a registration statement. Please allow adequate time after the filing of any amendment
for further review before submitting a request for acceleration. Please provide this
request at least two business days in advance of the requested effective date.
Please contact Matthew Spitzer at (202) 551 -3227 or me at (202) 551 -3750 with
any questions.
Sincerely,
Max A. Webb
Assistant Director
cc: Dean Law Corp.
Via facsimile: ( 206)493-2777