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Hateley
& Hampton

Attorneys
& counselors

201
santa monica boulevard

suite
300

santa
monica, ca 90401-2224

Telephone
(310) 576-4758

Facsimile
(310) 388-5899

Email:
dhateley@hateleyhampton.com

February
11, 2015

Ms. Amanda
Ravitz

SECURITIES
AND EXCHANGE COMMISSION

100 F Street,
N.E.

Washington,
DC 20549

    Re:
    Quarta-Rad,
    Inc.

    Response to
    Comment letter dated July 25, 2014

    Amendment
    No. 1 to Form S-1

    Filed:
    June 30, 2014

    File
    No. 333-196078

Dear Ms.
Ravitz:

Enclosed
is the Pre-Effective Amendment No. 2 to the above Registration Statement. The changes are made in response to the initial Registration
Statement and to make appropriate updates. The paragraph numbers below correspond to the numbered comments in your comment letter
dated July 25, 2014.

General

    1.
    We
    refer to your disclosures on pages 12 and 25 concerning your status as an emerging growth company. Please supplementally provide
    us with any written materials that you or anyone authorized to do so on your behalf provides in reliance on Section 5(d) of
    the Securities Act to potential investors that are qualified institutional buyers or institutional accredited investors. Similarly,
    please supplementally provide us with any research reports about you that are published or distributed in reliance upon Section
    2(a)(3) of the Securities Act of 1933 added by Section 105(a) of the Jumpstart Our Business Startups Act by any broker or
    dealer that is participating or will participate in your offering.

    Response:
    There
    are no written materials that the Company or anyone authorized to do so on behalf of the Company provides to any potential
    investors that are qualified institutional buyers or institutional accredited investors. The Company is not aware of any research
    reports about it that are published or distributed by any broker or dealer as the Company intends to distribute the offering
    through its officers and directors.

Registration
Statement Cover Page

Hateley
& Hampton

Attorneys & counselors

Ms. Amanda
Ravitz

February
11, 2015

Page2  of
12

    2.
    You
    may not carry forward filing fees paid on any registration statement that has been abandoned by the Commission. Please confirm
    that you have paid the proper filing fee for the present registration statement.

    Response:
    The
    Company has paid the proper filing fee for the present registration statement.

Prospectus
Cover

    3.
    In
    light of the size of the offering costs disclosed on page 18 relative to the $75,000 maximum gross proceeds, please revise
    the prospectus cover to highlight both the costs of the offering and the maximum net proceeds you could receive in the offering.

    Response:
    Revised.
    The Company has increased the gross proceeds of the offering from $75,000 to $300,000 and had shown the net offering costs
    it will receive from the offering in a footnote. The Company has changed other applicable sections.

Prospectus
Summary, page 4

    4.
    We
    note your disclosure on page 4 indicating that you require approximately $75,000 in cash to accomplish the goals set out in
    your plan of operation. Please tell us whether the $75,000 is in addition to the cash that you presently have or whether you
    need an additional $75,000. Additionally, please reconcile the $75,000 figure with the figures in your Plan of Operation disclosure
    on pages 26 and 27.

    Response:
    The
    Company has increased the maximum offering size to $300,000 from $75,000 and intends to use the net proceeds from the offering
    in addition to the cash that it presently has on hand to acquire additional inventory and for working capital. The $75,000
    figure has been replaced with $300,000 and the increased amount has been reconciled with the figures in the Plan of Operation
    disclosure on pages 26 and 27.

    5.
    Please
    revise to explain briefly what a Geiger counter detects.

    Response:
    Revised
    to explain that a Geiger counters are instruments used for measuring ionizing radiation. It detects radiation such as beta
    particles, Gamma rays and X-rays using the ionization produced in a Geiger-Müller tube, which gives it name to the instrument.

Hateley
& Hampton

Attorneys & counselors

Ms. Amanda
Ravitz

February
11, 2015

Page 3 of
12

    6.
    We
    note your reference on page 4 and throughout the prospectus to “our products;” however, your disclosures on this
    page and elsewhere indicate that you sell products that you do not manufacture. Accordingly, please revise all references
    to “our” products to remove any implication that you actually make the products that you say you sell. Similarly,
    please revise your disclosure on pages 30 and 31 where you indicate that you launched a new product and launched a new software
    package.

    Response:
    Revised
    to indicate that the Company distributes products manufactured by a related party. Revised to indicate that the Company sells
    a new product manufactured by a related party. The Company’s majority shareholder developed software and has contributed
    it to the Company for its use.

    7.
    Please
    tell us your basis for highlighting on page 5 your sales using Amazon.com, Buy.com and Sears.com. In this regard, please tell
    us whether you have made material sales through each of these three channels.

    Response:
    Revised
    to remove reference to specific online retailers. The Company’s sales are now to independent, third party customers.

    8.
    In
    the last paragraph of this section on page 6, you indicate that the aggregate market value of your common stock based on the
    offering price of $0.05 per share is $3,750,000. Please explain to us how this amount was computed.

    Response:
    Revised
    to correct the aggregate market value reflecting the new offering price per share.

Procedures
and Requirements for Subscriptions, page 20

    9.
    Please
    tell us why you believe that it is appropriate to include detailed instructions for stock subscriptions in this document,
    along with payment information, when your registration statement is still in review and has not been declared effective. Please
    confirm that you have not received any subscriptions to date.

    Response:
    Revised.
    The Company has not received any subscriptions.

Dilution,
page 20

    10.
    Please
    revise to present your net tangible book value per share before the offering as of the date of the most recent balance sheet
    provided.

    Response:
    Revised.

Hateley
& Hampton

Attorneys & counselors

Ms. Amanda
Ravitz

February
11, 2015

Page 4
of 12

Management’s
Discussion and Analysis of Financial Condition and Results of Operations, page 24

For the
three months ended March 31, 2014 compared with the three months ended March 31, 2013, page 25

    11.
    Please
    revise to provide a discussion of the material items affecting your results of operations and the underlying causes for various
    material changes to the extent necessary to an understanding of your business as a whole as well as the known or expected
    future impact of any referenced factors on operating results. In this regard, provide a comparative analysis of the changes
    in your revenues, cost of goods sold and operating expenses for the periods presented in the financial statements. Refer to
    Item 303(a)(3) and Instruction 4 to Item 303(a) of Regulation S-K. For further guidance, please refer to SEC Interpretive
    Release No. 33-8350 (FRR No. 72) and SAB Topic 13.B. This comment also applies to the same MD&A presentation for the year
    ended December 31, 2013 compared with the year ended December 31, 2012.

    Response:
    Revised
    to include the Company’s financial statements as of September 30, 2014 compared to September 30, 2013 with the comparative
    analysis.

Business,
page 28

    12.
    Please
    revise your disclosure to explain your historical and current operations and clarify what exact function you and your affiliates
    perform. For example, please clarify the nature of the inventory and consignment arrangements with your affiliates, including
    the material terms of any written or oral agreements you have with these affiliates. Please also revise your Summary disclosure
    on page 4 to clarify these same issues.

    Response:
    Revised.
    The Company purchases its products from Quarta-Rad, Ltd. (QRR), the manufacturer of the RADEX product line. The Company has
    an oral agreement with QRR for the exclusive distribution rights for the sale of the RADEX products in the United States,
    Europe, and Asia (other than China). The Company sells the products directly through online retailers and through resellers.

    From
    the Company’s inception through the beginning of 2013, it sold the products through Star Systems Japan (SSJ), a related
    party company, based on an oral agreement. Commencing in 2013, the Company discontinued its related party sales and sells
    through online retailers and resellers.

    The
    Company purchases its inventory for shipments to the US and Asia. It purchases its inventory DDP (Delivery Duty Paid) for
    deliveries to the European Union. The Company enters into a written agreement or purchase order for each order that it makes
    when it purchases its inventory.

Hateley
& Hampton

Attorneys & counselors

Ms. Amanda
Ravitz

February
11, 2015

Page5  of
12

    13.
    Please
    explain to us why the company controlled by your minority shareholder does not simply sell directly to the company controlled
    by your majority shareholder or why your majority shareholder does not simply sell its inventory on Amazon.com instead of
    having you sell it via that website. Please also revise your disclosure to clarify the purpose of your involvement in these
    transactions.

    Response:
    Revised
    to explain the Company’s sales arrangements. Quarta-Rad, Ltd (QRR) was intent on developing U.S. and European Union
    markets and because of that offered a preferable purchase price to the Company but not to Star Systems Japan (SSJ). It was
    expected that the U.S. market would expand quickly. QRU tried to combine all sales through one global distributor, which is
    QRU. SSJ discontinued selling inventory due to a lack of demand in Asia and inability to effectively provide customer support.
    The Company offers multi-lingual product support through its independent sales agent. SSJ does not sell directly in USA because:

    a)
    it
    does not have US checking account to receive the money;

    b)
    also
    it does not poses strong English customer service necessary for American consumers;

    c)
    there
    was no long term plan to sell off inventory in USA. Due to drop in demand in Japan, SSJ decided to exit this business hence
    the company sold off its remaining inventory and it no longer sells Geiger counters in Japan.

    14.
    Please
    also clarify the nature of the 2013 expansion to your sales plan. In this regard, your disclosure under the “Principal
    Products” heading on page 29 and in Note 5 on page F-8 appear to indicate that you only sell RADEX products, which are
    manufactured by your affiliate. As such, please explain the basis for your disclosure on page 28 indicating that you expanded
    your sales “outside of those related party transactions.” Also, describe the nature of the “Internet sales
    and sales third party resellers” so that investors can understand how your business operates and how these sales differ
    from the ones conducted in prior years. Please also clarify your Summary disclosure on page 4 to address these same issues.

Hateley
& Hampton

Attorneys & counselors

Ms. Amanda
Ravitz

February
11, 2015

Page 6
of 12

    Response:
    Revised
    to clarify the Company’s sales. The Company’s inventory is sold in the following manner: directly through its
    website and through Amazon web stores in the U.S., Canada, and the European Union. As the Company develops its customer base,
    it contacted resellers in consumer electronics and safety businesses and offered them the opportunity to sell its inventory
    on either:

    a)
    drop-shipment,
    where the Company receives a PO from a reseller and completes the order by shipping directly to a client, while billing the
    reseller; or

    b)
    wholesale
    purchase, where resellers purchase 10 or more units from the Company at one time for wholesale pricing and complete the orders
    themselves. The majority of the resellers prepay 100% of the purchased inventory or are offered Net30 terms. The Company determines
    pricing on a vendor-by-vendor basis. The Company no longer handles consignment sales. The Company does not enter into written
    contracts with its resellers.

    15.
    Please
    revise your disclosure on page 28 to explain the significance of the 2012 order that came from an unnamed “reseller.”
    Did this order constitute a material portion of your 2012 revenue?

    Response:
    The
    Company’s management believed that in 2012 worldwide demand for Geiger counters was increasing and several resellers
    approached the Company to sell the Geiger counters it was importing from QRR. The relationship between the Company and each
    reseller varied. Most of the resellers were interested in a one-time purchase. Others were interested in a long-term relationship
    and presently continue to resell the Company’s inventory. The Company’s resell arrangements were not significant
    to its overall sales strategy (less than 4% of sales) and did not result in a material portion of the Company’s 2013
    revenues. Beginning in 2012 and to the present, the Company’s sales are primarily derived from Amazon and direct sales.

16. Please revise your disclosure
on page 28 to describe your “distribution agreements” and your “reseller network.”

    Response:
    The
    Company enters into oral agreements with a customer or resellers. The Company quotes a price and the customer prepays for
    the delivery. As a customer develops a payment history with the Company, the Company offers Net30 payment terms. The Company’s
    sales on Amazon Vendor are governed by its agreement with Amazon and specifies Net 60 payment terms. Purchases from QRR are
    all on purchase order based where the terms of delivery and inventory are stipulated and payment amounts are clearly indicated.
    The Company’s agreement with QRR is an oral agreement.

Hateley
& Hampton

Attorneys & counselors

Ms. Amanda
Ravitz

February
11, 2015

Page 7
of 12

Radiation
Detection Equipment, page 29

    17.
    Please
    revise to clarify what types of radiation these products detect.

    Response:
    Geiger
    Counters such as RD1503+, RD1212 and RD1706 detect ionizing radiation types: Beta, Gamma and X-Rays. The few units we sell
    are RADEX MR-160N Radon Gas detectors that detect ionized Alpha particles in the Radon gas, and EMI Detectors that are used
    to detect Electro-Magnetic non-ionized radiation (such as emitted by high-power electrical lines, microwaves and anything
    that uses electricity).

Major
advanta ges…, page 29

    18.
    Please
    identify the “highly experienced engineers” who you can access and with whom they are currently employed. Please
    revise to explain what the “proprietary tech library” is and whether you developed it and whether your or your
    affiliates own it.

    Response:
    Revised.

Distribution
Arrangements, page 30

    19.
    Please
    revise to explain whether the “few” independent distribution arrangements that you reference are material to your
    business. If so, please also revise to describe each of these arrangements.

    Response:
    Revised
    to explai