SecProbe.io

May 20, 2011
 Ralph Montrone Chief Executive Officer Trail One, Inc.
1844 South 3850 West
Salt Lake City, UT 84104
Re: Trail One, Inc.
Amendment No. 4 to Registrati on Statement on Form S-1
Filed on May 9, 2011
  File No. 333-170781

Dear Mr. Montrone:

We have reviewed your responses to the co mments in our letter dated May 3, 2011 and
have the following additional comments.
 General

1. We note your response to our prior comment  11.  Please advise as to how the new
estimated cost to register the shares of common stock of $45,000 is consistent with your
estimated burn rate of $2,500.  We also  note that you anticipate $15,000 in costs
associated with public company reporting re quirements and newly applicable corporate
governance requirements and your disclosure in the first two sentences of the first full
paragraph on page 23 regarding $15,000 of estim ated costs over the next six months for
your direct sales program and the second fu ll paragraph on page 24 and the first full
paragraph on page 25 regarding $15,000 of es timated costs regarding the acquisition of
aluminum and developing and programming so ftware for the CNC machinery.  Please
reconcile each of these disclosures with your disclosures regarding your burn rate in the
last paragraph on page 1, second to last fu ll paragraph on page 17 and the second full
paragraph on page 25.

2. The financial statements should be updated to comply with Rule 8-08 of Regulation S-X.
It appears that you should now present interim fi nancial statements as of and for the three
and six months ended March 31, 2011.
 Prospectus Cover Page

3. We note your response to our prior comment four and reissue our comment.  We note
your disclosure in the last sentence on the pr ospectus cover page.  Please advise as to

Ralph Montrone Trail One, Inc. May 20, 2011 Page 2

what supplements you may have to the prospe ctus.  Alternatively, please delete the
reference to any supplemen ts to the prospectus.
 Prospectus Summary, page 1

 General Introduction, page 1

4. We note your response to our prior comment si x and reissue our comment.  It is still
unclear from your disclosure how you intend to market individualized license tags to the
wholesale market.  Please clarify what produc t will actually be sold  to the wholesale
customers.

5. We note your response to our prior comment eight and reissue our comment in part.
Please revise your disclosure on pages 15, 17, an d 27 to disclose consistently your plans
to raise capital through equity security sales, debt inst ruments, and priv ate financing.
 Risk Factors, page 6

We have a short development stage operating history, page 9

6. We note your response to our prior comment 12 and reissue in part.  Please revise this
risk factor because it appears to be incomplete or advise.
 Management’s Discussion and Analysis of Fina ncial Condition and Result of Operations, page
16

7. We note your response to our prior comment 16.  We note your disclosure in the first full
paragraph on page 18 and similar disclo sure on pages 23 and 26 regarding beginning
production of automobile license plate tags  once you have raised  the necessary $75,000
and developed and installed the software for the CNC machines.  We also note your
disclosure in the second full paragraph on page 24 and the fi rst full paragraph on page 25
regarding an estimated cost of $15,000 to ac quire aluminum and develop software and
program the CNC machinery.  Please advise  whether the $75,000 necessary financing
includes any estimated costs for developi ng software for and programming the CNC
machinery.
 Plan of Operation, page 25

8. We note your response to our prior comment 17 and reissue our comment in part.  Please
describe your plan of operation in more deta il here and in the Management’s Discussion
and Analysis of Financial Condition and Resu lts of Operations s ection.  For example,
please revise to indicate when you plan to begin producing the tags.  In doing this,
discuss each specific step you intend to take to begin producing the tags and your
intended sources and uses of funds.  Provide timeframes and quantified estimates of these

Ralph Montrone Trail One, Inc. May 20, 2011 Page 3

amounts for each step in producing the tags  and discuss what marketing methods you
intend to focus on.

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 Trail One, Inc. May 20, 2011 Page 4

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) 551-3574 with  any other questions.

Sincerely,

Julie F. Rizzo Attorney-Advisor
  cc (via fax): Steven Sager   (877) 255-9218