SecProbe.io

June 15, 2011
Via E-mail

Ralph Montrone Chief Executive Officer Trail One, Inc. 1844 South 3850 West Salt Lake City, UT 84104
Re: Trail One, Inc.
Amendment No. 5 to Registrati on Statement on Form S-1
Filed on June 2, 2011
  File No. 333-170781

Dear Mr. Montrone:

We have reviewed your responses to the co mments in our letter dated May 20, 2011 and
have the following additional comments.
 General

1. We note your response to our prior comment one  and reissue in part.  Please revise
throughout your filing to reconcile the amount s that constitute your $45,000 annual burn
rate for the next twelve months.  In this re gard, we note your disclosu re in the second to
last paragraph on page 6 that your “estim ated annual expenses are approximately
$75,000,” your disclosure in the last paragraph of the Use of Proceeds section on page 12
that you have $13,232 of remaining offering co sts, your disclosure in the last full
paragraph on page 16 and the second full pa ragraph on page 24 that  your anticipate most
of your expenses to be “legal, accounting, tran sfer agent, and other costs associated with
being a public company,” your disclosure in the second sentence of the second full
paragraph on page 22 regarding your estimate d costs over the next six months and your
disclosure in the Satisfacti on of Our Cash Obligations fo r the Next Twelve Months
section on page 23 and the first paragraph of  the Plan of Operation section on page 24
with respect to your cash/capital requirements  for the next six months.  Please also
reconcile any of these disc losures as appropriate to clarify which of the $75,000 of
financing for your twelve month operating pl an, such as the $10,000 of costs for public
company reporting requirements , are included in your estimated $45,000 annual burn rate
and to reconcile the amounts required, such  as the $22,500 cost for acquiring aluminum
and developing and programming the CNC mach inery software set forth on pages 23 and
24 and the $16,000 cost set forth on pages 7, 17, 22, 25 and 26.

Ralph Montrone Trail One, Inc. June 15, 2011 Page 2

 Prospectus Summary, page 1

 General Introduction, page 1

2. Please revise the last paragraph on page  1 and elsewhere throughout your filing as
appropriate to disclose when you will run out  of money given your current burn rate.  In
this regard, we note that you do not have any cash or assets on your balance sheet as of
March 31, 2011.
 Management’s Discussion and Analysis of Financ ial Condition and Results of Operations, page
15
 General Overview; Nature of business, page 15

3. Please revise the sixth paragraph of this se ction to update your timing for providing an
internet site for customers to purchase automob ile license plate tags.  In this regard, we
note your disclosure in the third bullet point  on page 25 that you intend to allocate the
funds to develop your website within four m onths of those funds becoming available and
your disclosure in the third full paragraph on page 25 that Mr. Montr one expects to have
any financing completed in the next four months.

Results of Operations, page 20
 Interest Expenses, page 20

4. Please advise whether you have any agreements in place with Mr. Montrone, such as a
promissory note, for the loans you have receiv ed to date from Mr. Montrone.  In this
regard, we note your disclosure in Note 4 to  your financial statements on page F-9.  If
you do have any agreements with Mr. Montrone  for the loans you have received to date,
please file such agreements as an exhib it to your registration statement or advise.

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;

Ralph Montrone Trail One, Inc. June 15, 2011 Page 3

  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.
 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,
  /s/ Julie F. Rizzo
Julie F. Rizzo Attorney-Advisor
   cc:  Via E-mail

Steven Sager
 BK Consulting & Associates, P.C.