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SEC Comment Letter 0000000000-25-003205 to Skkynet Cloud Systems, Inc. (SKKY)

Skkynet Cloud Systems, Inc.
Date: March 25, 2025 · CIK: 0001546853 · Accession: 0000000000-25-003205

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File numbers found in text: 000-54747

Date
March 25, 2025
Author
Division of
Form
UPLOAD
Company
Skkynet Cloud Systems, Inc.

Letter

Re: Skkynet Cloud Systems, Inc. Form 10-K for the Fiscal Year Ended October 31, 2024 Form 10-Q for the Fiscal Quarter Ended January 31, 2025 File No. 000-54747 Dear Lowell Holden:

March 25, 2025

Lowell Holden Chief Financial Officer Skkynet Cloud Systems, Inc. 2233 Argentia Road, Suite 302 Mississauga, Ontario Canada L5N 2X7

We have limited our review of your filing to the financial statements and related disclosures and have the following comment.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 10-Q for the Period Ended January 31, 2025 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 12

1. In future filings, please expand your revenue discussion to provide additional details around trends impacting your results of operations and to quantify the extent to which changes are attributable to changes in price, volume, product or service offerings, or other market factors. For example, we note that your current disclosures attribute your 31.3% increase in revenue to higher sales by Cogent but do not provide quantification, context, and clarity in regard to the underlying drivers. Refer to Item 303(b)(2)(iii) of Regulation S-K. In closing, 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. March 25, 2025 Page 2

Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202- 551-3361 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Technology

Show Raw Text
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<TEXT>
 March 25, 2025

Lowell Holden
Chief Financial Officer
Skkynet Cloud Systems, Inc.
2233 Argentia Road, Suite 302
Mississauga, Ontario
Canada L5N 2X7

 Re: Skkynet Cloud Systems, Inc.
 Form 10-K for the Fiscal Year Ended October 31, 2024
 Form 10-Q for the Fiscal Quarter Ended January 31, 2025
 File No. 000-54747
Dear Lowell Holden:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-Q for the Period Ended January 31, 2025
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 12

1. In future filings, please expand your revenue discussion to provide
additional details
 around trends impacting your results of operations and to quantify the
extent to which
 changes are attributable to changes in price, volume, product or service
offerings, or
 other market factors. For example, we note that your current disclosures
attribute your
 31.3% increase in revenue to higher sales by Cogent but do not provide
quantification,
 context, and clarity in regard to the underlying drivers. Refer to Item
303(b)(2)(iii) of
 Regulation S-K.
 In closing, 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.
 March 25, 2025
Page 2

 Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage
at 202-
551-3361 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
</TEXT>
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