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June 26, 2023

Keira Nakada

Angela Lumley

Scott Anderegg

Jennifer López Molina

Division of Corporation Finance

Office of Trade & Services

Securities & Exchange Commission

Washington, D.C.

Re: 	        Mike
the Pike Productions, Inc.

Amendment No. 1 to Registration
Statement on Form 10-12G

Filed April 28, 2023

File No. 000-55298

Dear Ms. Gorman:

The following are the issuer’s
response to your comment letter of May 22, 2023.

Amendment No. 1 to Form 10-12G filed April 28, 2023

Description of Business, page 4

1.
Please thoroughly revise this section to clarify and better describe the status of your current operations and your proposed business
operations. To the extent that you discuss future activity, please provide the status of development and indicate the timeframe for which
you anticipate these projects will take and the basis of your conclusions. Further, please discuss the actual operations of your business,
focusing on the particular means by which you will generate revenues and incur expenses. For example, discuss if you are going to produce
the film or TV series based on your intellectual property and if you intend to sell the property to a network or streaming service. Further
describe if you have had any formal or informal discussions to produce your projects with a distributor, network or streaming service.
Please also clarify the steps you have taken already, if any, to initiate your operations and the costs of these steps to you.

The company acquires and develops intellectual
property in the media and entertainment space to expand the universe of those materials in the form of feature film, television
series and more. This can also lead to additional opportunities in M&E arenas such as opportunities for merchandising,
publishing, virtual reality, augmented reality, artificial intelligence and video games/esports. We do this through our subsidiary,
Arowana Media Holdings, Inc. and its wholly owned subsidiary, Mike The Pike Entertainment, LLC, primarily via option or outright
purchase of certain rights to copywritten material of undervalued and/or legacy IP; usually books,graphic novels or other published
works, and develop them for screen in partnership with studios and production companies in exchange for upfront and/or backend fees,
royalties and profits. We currently have rights in the form of Option/Purchase Agreements as well as Shopping Agreements in certain
cases. These rights are intended to be monetized in accordance to industry standard monetization of intellectual property rights
which typically include, on a property adapted for Television Series, one or more of the following:

 ● Option Fee

 ● Acquistion/Purchase

 ● Pilot Services Fee

 ● Series Services Fee

 ● Consulting Services

● Contingent Participation (revenues derived from
ancillary sources- spinoffs, merchandising, licensing, etc.) and on a property adapted for Feature Film to typically include:

 ● Option Fee

 ● Acquisition/Purchase

● participation in Producer/ Executive Producer/Production
company fees (normally a percentage of the film’s budget), Negotiated Backend, Royalties and Box Office/Streaming bonuses

All projects are intended to enjoy ancillary revenues
as well, including participation in sequels,prequels, reboots, remakes, merchandising, as well as adaptations of the adapted
material which could include video games, web3, and, where viable, theme park rides/experiences. Identification of Rights include
reviewing properties for what management feels will have market viability as filmed entertainment, as well as outreach to
publishers, authors, creators, managers, agents, and otherwise, to obtain rights availability toward negotiating Option/Purchase
Rights Agreements. Development may entail attaching talent (director, screenwriter, actor), obtaining financing, creation of
materials such as screenplays, presentation decks or “lookbooks”, and/or partnerships with seasoned producers,
production companies and/or studios. Once properties are developed to management’s satisfaction, we then seek partnership with
studios, financiers, distributors to produce and distribute the project. The CEO has personally funded certain initiatives requiring
funding, such as the screenplay for Wish by Nicholls Fellow Joey Clarke Jr., as well as legal expenses for Option/Purchase
Agreements and, in many cases, has utilized “sweat equity” to build out presentation decks, website development,
lookbooks, and outreach to management, legal, talent and production companies to ensure projects meet their pipeline objectives.

Status on the projects (listed later in this document)
vary in timelines and benchmarks, and will be listed in addition to the project information for each title in subsequent pages. We
intend to monetize these assets by adapting to motion picture (feature film, limited series, ongoing series, etc.) in partnership
with or sales to studios and/or streamers such as

Netflix, MAX, Peacock, Hulu, Disney+, Paramount+, Amazon
Prime, etc.

The Company has currently engaged in both formal and
informal discussions with notable talent, producing partners, production companies, and studios to develop and produce each property
for its designated form of adaptation; initially, certain titles for series (such as Vampirella) and certain titles for feature film
(such as Wish). Details included in the

project descriptions to follow.

The Company intends to have projects set for production/principle
photography within the timeframe of each option and allowable extensions which may range, typically, anywhere from a total of 24 to 36
months, which is the case for our current projects; for instance, we have completed the screenplay for ‘Wish’ based on the
novel by Barbara O’Connor, and are partnered with a seasoned production company, Imprint Family Entertainment, and its principle,
Michael Becker, to work in collaboration to obtain financing, attach director and talent, and begin principle photography, which we anticipate
will be within the next 12 months.

Our Current Properties/Projects, page 5

2. Please revise your disclosure to describe the intellectual
rights that you own for each project including the term of your rights. Please file the intellectual property agreements or licenses
as exhibits. For example, we note a press release that you optioned Wish for adaption as a film in 2021. Please file as an exhibit your
option agreement. In addition, as some of your listed projects have previously been made into a film, Vampirella, or TV series, Silverwing,
please revise your disclosure to explain how you have rights in these properties when there are a pre-existing film or TV series.

The Company’s assets are primarily in the form
of Intellectual Property rights and currently include rights in the exclusive motion picture, television, DVD, Internet (i.e., a
program, web series or movie derived from the Work), and all subsidiary, allied, and ancillary rights to the Ella Clah series of
novels by Aimee and David Thurlo, which books in the Series are entitled “Blackening Song”, “Death Walker”,
“Bad Medicine”, “Enemy Way”, “Shooting Chant”, “Red Mesa”, “Changing
Woman”, Plant Them Deep”, “Tracking Bear”, “Wind Spirit”, “White

Thunder”, Mourning Dove”, Turquoise
Girl”, “Coyote’s Wife”, “Earthway”, “Neverending Snake”, “Black
Thunder”, and “Ghost Medicine”. Rights under Option for Purchase include all right, title and interest of every
kind or nature whatsoever in and to the Work including all rights under copyright, and Producer shall have the right to develop,
make, sell, produce, distribute, exhibit, broadcast (including without limitation, free broadcast, pay television, cable,
subscription, pay-per- view, video-on-demand, DVD and Internet), advertise, publicize, license, record and otherwise exploit the
Work and all other publications, productions and other derivative works based upon the Work in any and all languages, formats,
manners and media, whether now known or hereafter devised, throughout the universe in perpetuity, subject only to the Reserved
Rights, which consist of print publication and stage rights.

Ella Clah is currently in development; however due to
the Writers Guild of America strike which, as of the date of this document, is ongoing, we are unable to move forward in working
with a WGA writer, which is the Company’s intent. The Company has, however, secured interest from a writer to formulate a
pitch for studios prior to the strike and plans to resume working with the writer once the strike comes to a resolution, or
otherwise, if at all. A Presentation Deck based on the IP has been created by the Company and we have secured an Emmy award winning
Executive Producer to collaborate with us on developing the project and shopping to studios.

As well, we hold rights to the comic book series and certain
characters in the Vampirella universe

including the characters below:

1. Vampirella

2. Pendragon

3. Adam Van Helsing

4. Conrad Van Helsing

5. Lilith

6. Mad God Chaos

7. Blood Red Queen Of Hearts

8. Mistress Nyx

9. Hemmorhage

10. Von Kreist

11. Trixie Fattoni

12. Pixie Fattoni

13. Don Fattoni

14. Draculina

15. Passion

16. Monsignor Pesaro

17. Skaar

18. Passion

19. Tyler Westron

20. Anuberis

21. Tristan

22. The Scarlett Legion (Team)

23. The Sisterhood (Team)

24. Chelsea Cantrell

25. Ethan Shroud

26. The Unseelie Congress (collective of supernatural creatures)

27. Vampirella Army

28. Madek & Magdelene

29. The Kabal

30. Lorelei

31. Botis

32. Bazrys

33. Delilah William

34. Goodman William

35. Sophia

36. Le Fanu

37. Schuld

38. Cestus Dei

39. Yag-Ath Vermellus

40. Ikari: Sister of Rage from The Karasu Shimai

41. Zetsobou: Sister of Despair from The Karasu Shimai

42. Kanki: Sister of Delight from The Karasu Shimai

43. Gregory

44. Bazrys

45. Pantha

with rights included to develop, make, sell, produce,
distribute, exhibit, broadcast (including without limitation, free broadcast, pay television, cable, subscription, pay-per-view,
video-on- demand, DVD and Internet), advertise, publicize, license, record and otherwise exploit an audiovisual production based on
the Work and derivative audiovisual works based upon the Work (collectively, “Derivative Works”) in any and all
languages, formats, manners and media, whether now known or hereafter devised, throughout the universe in perpetuity, subject only
to the Reserved Rights, which include Print Publication Rights, Live Stage Reading Rights, Live Stage Rights, and Radio Recital
Rights Though there was a feature film based on the character Vampirella in 1996 as part of the ‘Roger Corman Presents’
series, the rights have since reverted to the publisher prior to the rights purchase agreement secured by the Company.

We are currently partnered with Dynamite Comics (the
publisher) and a notable animation studio in Vancouver, Canada (with award winning animated series on Amazon (Kirkman’s
‘The Invincibles’) , and whose principle has produced a number of award-winning feature films (including Angry Birds,
Star Wars: The Clone Wars, Escape from Planet Earth) which have enjoyed worldwide distribution and revenue and/or critical success.
We have agreed to produce an animated series based on the Vampirella universe as an inaugural project toward further exploitation of
the rights for screen and otherwise. Though the information is currently confidential, we are happy to share copies of
correspondence and agreements confidentially to support. We intend to monetize the project within the next 24 months.

We also have rights in Wish by Barbara O’Connor
to include all motion picture, all television rights (pay, free, cable, and otherwise) all home video rights. and all allied,
ancillary, and subsidiary rights in the Property, whether now known or hereafter devised (including without limitation prequel,
sequel, and remake rights, music and music publishing rights, soundtrack recording, comic book rights, and graphic novel right;
video game and interactive gaming rights, podcast rights and other exploitation rights, commercial tie-in and merchandising rights
(including without limitation the exploitation and/or licensing of characters and other elements of the Property for all types of
goods and services, theme parks, and other types of attractions), and all promotional publishing rights with the exception of novel
publication rights. including print and nondramatic audio rights (i.e. so-called "books-on-tape or e-books"
rights) subject to 7,500 word (but no more than 10% of the text) promotional publication rights; the right to publish the text of
the Property electronically; the right to broadcast the text of the Property, whether in installments or otherwise, by television or
radio in single-voice, non-dramatic readings {subject to Purchaser's right at all limes to exercise its television and radio
rights for purposes of advertising, promoting, publicizing, and/or otherwise exploiting any production based on the Property; live
stage rights; and all rights in all Owner-written and Owner-authorized sequels

(provided that Purchaser shall have a rolling right of
first negotiation and last refusal to option any such sequels). We are currently partnered with Imprint Family Entertainment (Groove
Tails) and its principals, including Michael Becker (https://deadline.com/2021/07/maryann-garger-michael-becker-launch-
imprint-family-entertainment-1234797003/ ) with a finished screenplay by Nicholl fellow Joey Clarke Jr.
(https://deadline.com/2021/08/wish-joey-clarke-jr-to-adapt-barbara-oconnor-book-for-the-screen- 1234813761/ ) to produce as a
feature film. We are currently out to directors and financiers to prepare for principle photography which we anticipate to be on or
about Spring 2024. Also, the Company has a shopping agreement to produce ‘Silverwing’ based on the Kenneth Oppel book
series with the founder of Bardel Entertainment (the original producer of the Canadian series produced in 2003). The founder
retained the rights to Silverwing and is in collaboration with Company to adapt the series to screen seeking worldwide distribution
alongside the development and production process. To date, a lookbook/deck has been completed for the project including 45%
participation for

Mike The Pike once, and if, a project is produced. Parties
have agreed in good faith and intends to formalize the agreement by late June 2023.

The Company also holds rights to writer/creator Mike
Baron’s (The Flash, The Punisher) ‘Biker’ series featuring protagonist Josh Pratt, which include all motion
picture, all television rights (pay, free, cable, and otherwise) all home video rights. and all allied, ancillary, and subsidiary
rights in the Property, whether now known or hereafter devised (including without limitation prequel, sequel, and remake rights,
music and music publishing rights, soundtrack recording; video game and interactive gaming rights, podcast rights and other
exploitation rights, commercial tie-in and merchandising rights (including without limitation the exploitation and/or licensing of
characters and other elements of the Property for all types of goods and services, theme parks, and other types of attractions), and
all promotional publishing rights with the exception of novel publication rights. including print and nondramatic audio rights

The Company also has an 11.3% stake in net profits to
the film “Beyond White Space”, which is anticipated to breakeven this year. The Company was a financier on the film, and
its principal, Mark Newbauer, a producer on the film which enjoyed a theatrical release in December 2018 and is now streaming on
various platforms. It is distributed by Vertical Entertainment and the trailer can be viewed here:
https://www.youtube.com/watch?v=_RihSzdaCtc

Risk Factors, page 7

3. In its current form, your risk factor discussion
appears relatively brief and does not disc