SecProbe.io

Mail Stop 3030
February 29, 2016

Victor Shvetsky
Chairman, Chief Executive Officer, Secretary
 and Principal Financial and Accounting Officer
Quarta -Rad, Inc.
1201 N. Orange Street
Suite 700
Wilmington, DE 19801

Re: Quarta -Rad, Inc.
Amendment No. 3 to Registration Statement on Form S -1
Filed February 2, 2016
  File No. 333 -196078

Dear Mr. Shvetsky:

We have reviewed your amended registration 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 registration statement and providing the
requested information.   If you do not be lieve 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 registration statement and the information you
provide in response to thes e comments, we may have additional comments.   Unless we note
otherwise, our references to prior comments are to comments in our July 25, 2014 letter.

Business, page 28

1. Please expand your revisions in response to prior comment 9 to address the terms of t he
oral agreement relating to the term of the agreement, termination and exclusivity.  Please
also clarify how you “prepay for the products [you] purchase,” given the related party
payables reflected in your financial statements.

Revenues, page 26

2. Please  clarify the reasons underlying the changes you note.  For example, revise the
statement regarding “reduced demand for inventory in new markets [you] tested” to

 Victor Shvetsky
 Quarta -Rad, Inc.
February 29, 2016
Page 2

 clarify why demand was reduced and to what markets you are referring.  Please also
revise to cl arify how the “introduction of new models” caused decreased revenues.

Operating Expenses, page 26

3. We note your response to comment 8 and your updated disclosures.  Please revise your
filing to also include an explanation of the underlying reasons for the  changes in your
operating expenses for all of the periods provided.  For instance, please describe any
unusual or infrequent events or transactions or any significant economic changes that
materially affected the amount of reported income from continuing operations.

Major advantages, page 29

4. We note your response to prior comment 10.  It does not appear that you have revised to
explain what you mean by “proprietary tech library” and whether you or your affiliates
owns or controls this library.  Please revise.  Please also identify the engineers to whom
you have access and where they are employed.

Summary Compensation Table, page 34

5. Please update the disclosure provided pursuant to Regulation S -K Item 40 2 to be as of
your last -completed fiscal year, th e fiscal -year ended December 31, 2015.  We note that
your disclosure is currently as of September 30, 2015.

Certain Relationships . . ., page 35

6. Please reconcile the amount of related party payables referenced here as of December 31,
2013 and 2014 and Se ptember 30, 2015 with the amounts reflected in your balance sheets
for the periods ended December 31, 2013 and 2014 and September 30, 2015.  Also, the
balance sheet following your auditors’ reports says you had related party payables of
$170,647 and accoun ts payable of $52,434 as of December 31, 2014.  However, the
balance sheet as of December 31, 2014 that appears with your financial statements as of
September 30, 2015 reports different amounts.  Please reconcile.

Financial Statements, page 43

Note 2.  Summary of Significant Accounting Policies, page F -7

-Revenue Recognition, page F -9

7. We note your response to comment 12.  Please revise your filing to include the
significant points from your response which support the conclusion that you are the
primary obligor and should recognize revenue on a gross basis as outlined in  ASC 605 -
45. Specifically, please revise to include disclosure similar to last paragraph of your
response.

 Victor Shvetsky
 Quarta -Rad, Inc.
February 29, 2016
Page 3

 Exhibit 23.3

8. We note that the consent of your independent auditor refers to the report dated January
22, 2016 on your financial statements as of and for the period ending December 31, 2014.
However, we note from page F -1 that the referenced audit report date is actually February
1, 2016. Prior to requesting effectiveness , please have your independent auditor provide a
currently dated consent which references the proper report date.

You may contact Tara Harkins at (202) 551 -3639 or Kevin Kuhar, Accounting Branch
Chief, at (202) 551 -3662 if you have questions regarding com ments on the financial statements
and related matters.  Please contact Geoff Kruczek at (202) 551 -3641 or me at (202) 551 -3528
with any other questions.

Sincerely,

 /s/ Amanda Ravitz

 Amanda Ravitz
Assistant Director
Office of Electronics and Machine ry

cc:   Michael T. Connette, Esq.

 Donald P. Hateley, Esq.