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May 4, 2022
John V. Whitman, Jr.
Chief Executive Officer and Chairman
GGTOOR, INC.
430 Walker Lane
Thomasville, Georgia, 31792
Re:GGTOOR, INC.
Offering Statement on Form 1-A
Filed April 7, 2022
File No. 024-11856
Dear Mr. Whitman:
            We have reviewed your offering statement and have the following comments.  In some of
our comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to this letter by amending your offering statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.  After reviewing any amendment to your offering statement and the information you
provide in response to these comments, we may have additional comments.
Form 1-A filed on April 7, 2022
We have a history of operating losses and we may need additional financing to meet our future
long-term capital requirements., page 7
1.Please revise to update your disclosure. We note your reference to the year ended May 31,
2019.
Executive Compensation, page 25
2.Please update the executive compensation table with executive compensation for fiscal
year 2021.
General
3.We note in your disclosure that the company is in negotiations with a Netherlands
Corporation engaged in NTFs.  Please clarify whether the references to NTFs are meant to

 FirstName LastNameJohn V. Whitman, Jr.
 Comapany NameGGTOOR, INC.
 May 4, 2022 Page 2
 FirstName LastName
John V. Whitman, Jr.
GGTOOR, INC.
May 4, 2022
Page 2
be references to NFTs, otherwise known as non-fungible tokens.
4.Rule 251(b)(3) provides that Regulation A is not available for issuers of securities that are
development stage companies that wither have no specific business plan or purpose, or
have indicated that their business plan is to merge with or acquire an unidentified
company or companies.  We note from your disclosure that you do not appear to have a
business plan.  Please provide us with a detailed analysis as to why you are eligible to
conduct this offering under Regulation A.
5.You disclose that you may sell up to 250,000,000 shares at a price range of between
$0.001 and $0.08 per share.  We note that if the offering were fully subscribed at $0.08
per share it would equal $20 million.  However, we also note you have issued common
stock in the last year.   Please reduce the volume of securities you are offering if you have
sold securities in the past year so you do not exceed the $20 million limit.   See Rule
251(a)(1).
6.We note that you have indicated in Part I that you do not intend to price this
offering after qualification pursuant to Rule 253(b). You have also disclosed a price range
of $0.001 to $0.08 on the cover page. Note that you use the midpoint of a price range in
Part I, Item 4 of Form 1-A because you intend to price the offering after qualification.
Please revise to make your disclosures consistent.
            We will consider qualifying your offering statement at your request.  In connection with
your request, please confirm in writing that at least one state has advised you that it is prepared
to qualify or register your offering.  If a participant in your offering is required to clear its
compensation arrangements with FINRA, please have FINRA advise us that it has no objections
to the compensation arrangements prior to qualification.
            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 Erin Donahue, Staff Attorney at 202-551-6001 or Sherry Haywood, Staff
Attorney at 202-551-3345 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing