SecProbe.io

December 20, 2010
 Ralph Montrone Chief Executive Officer Trailone, Inc. 318 N. Carson Street
Carson City, NV 89701

Re: Trailone, Inc.
Registration Statement on Form S-1 Filed on November 23, 2010
  File No. 333-170781

Dear Mr. Montrone:

We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter by amending your registration 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 re gistration statement and the information you
provide in response to these comments, we may have additional comments.
 General

1. Please revise to provide disclosure require d by Items 102 and 407(a) of Regulation S-K.

2. The financial statements should be updated, as  necessary, to comply with Rule 8-08 of
Regulation S-X.
 3. Please provide a currently dated consent from the independent registered public
accountant in the amendment.

Prospectus Summary, page 6

 Overview, page 6

4. Please revise your disclosure to expl ain what you mean by “car jewelry.”

Ralph Montrone Trailone, Inc. December 20, 2010 Page 2

General Introduction, page 6

5. It appears unclear from your disclosure whethe r you have one type of license plate tag or
one tag that has been manufactured to  date.  Please revise or advise.

6. Please revise to indicate your monthly burn rate  as well as the amount  of time that your
present capital will last at this rate.

7. Please revise this section to describe in reasonable detail the li cense plate tag you are
developing.  Include a discussion of what it will look like, how it will be made and from
what materials.  Please also clarify whet her you are currently de veloping the product or
marketing the product, or both.  Your disclosure  on this point is inconsistent.  If you are
marketing the product, describe how you are doing so and to whom.

Business Development, page 6

8. You state that you are marketing a tag for sale to the general public.  Please revise here
and elsewhere in the prospectus to clarify your  target market.  For example, on page 27
you state that you are marketing a tag to autom obile specialty shops.  Please be specific
in your discussion of to whom you in tend to sell your products and how.

Risk Factors, page 10

9. We note your statement on page 28 that you have  not taken any steps to test the product
on automobiles.  Please add a risk factor so that investors can evaluate this risk.

10. It appears that the developm ent of your business is highl y reliant upon the manufacturing
capabilities of APMI with wh om you have no agreement.  Please include a risk factor
discussing the risk relate d to your reliance upon APMI.

We Have a History of Losses, page 10

11. Please revise to estimate the amount of your additional costs and expenses here.
Additionally, please include an estimate of  costs associated with public company
reporting requirements and costs associated wi th newly applicable corporate governance
requirements on page 13.
 If We Do not Obtain Additional Financing, page 10

12. Please revise this risk factor to include an estimate of additional financing you will need
to obtain here and on page 13.

Ralph Montrone Trailone, Inc. December 20, 2010 Page 3

We Have a Short Development St age Operating History, page 12

13. Please reconcile your disclosure that you are “continuing to build [your] customer base”
with the statement that you “do not have any customers at this time.”
 Special Note Regarding Forwar d-Looking Statements, page 15

14. You refer in this section to the expected imp act of a Share Exchange that is not otherwise
discussed in the prospectus.  Please revise or advise.
 Use of Proceeds, page 16

15. Please revise to clarify how you intend to pay the remaining $2,500 to cover your fees,
costs, and expenses of this offering.

16. You refer to an “investment agreement” with th e selling security holder.  Please file this
agreement as an exhibit to the registration statement and include a description of the
material terms of the agreement in the prospectus.
 Plan of Distribution, page 17

17. Please clearly disclose on page 18 that there can be no assurance that you will find a
market maker and no assurance that your shar es will be approved for trading on the OTC
Bulletin Board.
 Management’s Discussion and Analysis of Fina ncial Condition and Result of Operations, page
19

18. Please revise to discuss in greater detail your plan of operation for the next twelve
months by providing a more deta iled discussion of your plan for raising additional capital
including each step required as well as a ny contingencies in the raising of additional
capital.  In addition, provide a discu ssion of how long you can satisfy your cash
requirements, given your current amount of wo rking capital.  As part of your discussion,
disclose your monthly burn rate.

19. It appears from your prior disclosure on page 16 that the majority of audit fees, legal fees,
and all other expenses associated with the offering in the amount of $15,500 have already
been paid.  Please revise your disclosure on pa ge 20 that you intend to pay these fees as
they become due or advise.  Similarly, revise your disclosure on pages 25 and 27.

20. Please revise to explain your “direct sale s model through Mr. Montrone” on page 20 and
elsewhere.  In addition, explain how do you plan to “educate automobile advertisers
about [your] products and work to obtai n sales” on page 20 and elsewhere.

Ralph Montrone Trailone, Inc. December 20, 2010 Page 4

Liquidity and Capital Resources, page 24

21. Please reconcile for consistency your disclosure  that you “do not believe that [you] shall
be forced to enter into any l ong or short term debt arrangements” with your disclosure on
pages 6, 10 and elsewhere in your registration statement th at you will need to obtain
additional financing in order to complete your business plan.
 Plan of Operation, page 26

22. Please revise significantly your  plan of operation and MD&A  sections to discuss your
detailed plan to become operational and thr ough to revenue generation.  This discussion
should include each specific step you intend to  take toward this goal and describe your
intended sources and uses of funds, providi ng timeframes and quantified estimates of
these amounts for each step.

23. Your plan of operation is entirely relia nt upon additional financing of $75,000.  Please
discuss the specific actions you have taken and intend to take in order to acquire this
financing.  Please also discuss your expected timeline for completing this financing.  In
addition, please discuss what type of experience Mr. Montro ne has in such financing
activities that would be relevant to the company’s current needs.

24. We note your disclosure in notes to financia l statements on page F-6 that your products
will be available in “USDM (American); JOM (Japanese); EURO (European) and AU
(Australian) dimensions.”  If you plan to  market your products internationally, please
include a brief discussion of these plans in the plan of operation section of your
registration statement or advise.
 Organization Within Last  Five Years, page 27

25. You do not appear to provide any services.  Pl ease revise your disc losure that you intend
to “put [your] servic e on the internet” for consistency or advise.
 Unique Features of the Company, page 28

26. Please briefly describe the “CNC machine.”

Description of Products, page 28

27. Please expand your product desc ription to include your product’s major features and
characteristics.  If applicable, explain how it differs from other similar products currently
on the market.

28. Please expand your disclosure to clarify your st atement that you “own all the rights to the
specifications for the automobile license plate tag.”  Revise your registration statement to

Ralph Montrone Trailone, Inc. December 20, 2010 Page 5

disclose whether you registered any tradem arks, patents or hold  other intellectual
property rights.
 The Automobile License Plate Industry, page 29

29. Please revise your disclosure on page 30 to remove quotes from your competitors.
Instead, briefly list and describe your competition.
 Niche Industry, page 31

30. It is unclear from your disclosure what your niche is.  Please revi se your disclosure to
provide sufficient information about the nich e market within your industry or advise.
 Employees, page 31

31. You state on page 27 that you have two employees.  On page 31, however, you only
mention Mr. Montrone.  Pl ease revise or advise.

32. Please revise this discussion to clarify how much time Mr. Montrone currently devotes to
the affairs of the company and when he will begin to devote 40 hours a week.

Management, page 31
 Directors, Executive Officers, Promoters and Control Persons, page 31

33. You state that Ralph Montrone is your promoter.  Please prov ide all required disclosure
pursuant to Item 404(c) of Regulation S-K fo r Mr. Montrone and any other promoters or
advise.
 Management Biographies, page 32

34. Please list Mr. Montrone’s posi tion with Western Sheet Metal for the last five years.
Refer to Item 401(e) of Regulation S-K.
 Interest of Management and Others  in Certain Transactions, page 35

35. Please provide the disclosure  required by Item 404(a) fo r the “transaction described
above” in this section.
 Item 17.  Undertakings, page II-2

36. It does not appear that you are conducting an underwritten offering.  Please remove the
first paragraph in this section because it doe s not appear to appl y to your offering or
advise.

Ralph Montrone Trailone, Inc. December 20, 2010 Page 6

 Exhibit 5.1

37. Please revise the legal opinion to refere nce Form S-1 filed on November 23, 2010, as
amended.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:
• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission 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

• the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

Ralph Montrone Trailone, Inc. December 20, 2010 Page 7

You may contact Patrick Kuhn at (202) 551- 3308 or Lynwood Shenk at (202) 551-3380
if you have questions regarding comments on the financial statements and related matters.
Please contact Tonya Bryan at (202) 551- 3601 or me at (202) 551-3469 with any other
questions.
Sincerely,

Justin Dobbie Special Counsel
 cc (via fax): Leo J. Moriarty   (714) 316-1306