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November 21, 2023
Nataliia Petranetska
Chief Executive Officer
Sky Century Investment, Inc.
220 Emerald Vista Way #233
Las Vegas, NV 89144
Re:Sky Century Investment, Inc.
Registration Statement on Form 10-12G
Filed October 26, 2023
File No. 000-56603
Dear Nataliia Petranetska:
            We have reviewed your filing and have the following comments.
            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 and any amendment you may file in response to this letter,
we may have additional comments.
Registration Statement on Form 10-12G
Item 1. Description of Business, page 1
1.Please revise this section to more thoroughly describe the status of your current and
proposed business operations. For example, please clearly indicate which products and
services, including those discussed on page 2 (e.g., the Cannabis News Application, RSS
feed sales, web design services, and IT services), you currently provide, as well as the
percentage of revenues generated by each. To the extent that you discuss products and
services that you do not currently provide but anticipate providing in the future, please
disclose that you do not currently provide them, the status of development and anticipated
timeframe and expenses for these projects, and the person(s) who will develop such
projects, as well as your basis for such statements.
2.Please supplement this section with a discussion of the effect on your business of existing
or probable governmental regulations, including those applicable to your role within the
cannabis industry and your business activities involving use of data. Refer to Item

 FirstName LastNameNataliia Petranetska
 Comapany NameSky Century Investment, Inc.
 November 21, 2023 Page 2
 FirstName LastNameNataliia Petranetska
Sky Century Investment, Inc.
November 21, 2023
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101(h)(4)(ix) of Regulation S-K. Please also add appropriate risk factor disclosure on this
topic.
General Background of the Company, page 1
3.We note your statement that you acquired the “complete proprietorship” of Cannabis
News LLC in 2020. Please provide additional detail regarding the nature and material
terms of this acquisition, and describe your current organizational structure. You also state
here that Cannabis News LLC "possesses ownership of" the Cannabis News Application,
while page F-9 indicates that the application was transferred to Sky Century Investment,
Inc. pursuant to an Intellectual Property Assignment Agreement; please revise for
accuracy and consistency.
4.Please clarify Khamijon Alimzhanov’s role in relation to the company. For example, you
state on page 3 that Nataliia Petranetska is your sole employee, but page F-12 references
“salary debt” owed to Mr. Alimzhanov. Further, provide detail regarding the amount,
nature and timing of Mr. Alimzhanov’s “personal funding” of certain software
development expenses and, if such funding constitutes a related party transaction within
the meaning of Item 404 of Regulation S-K, please provide the disclosure required by
Item 404(a) under “Item 7. Certain Relationships and Related Transactions and Director
Independence.”
Item 1A. Risk Factors, page 3
5.Please add, at the beginning of this section, a risk factor regarding the fact that your
auditor has expressed substantial doubt about your ability to continue as a going concern,
and the risks related to the same. Acknowledge your losses to date and working capital
deficit. Please also add or supplement a risk factor to discuss your auditor’s inability to
obtain comfort over the accuracy of revenues from sales recognized in the years ended
May 31, 2022 and May 31, 2023.
6.In your risk factors related to employees and workforce talent on pages 4 and 5, you use
terms such as “our executive officers” and “other key personnel,” which is inconsistent
with your statement on page 3 that you have a single employee. Please revise your risk
factor disclosure to clarify the current state of your workforce and discuss any risks
associated with having a single employee. We also note that this employee seems to serve
as your sole director. Please add a risk factor acknowledging, if true, that you have a
single, non-independent director and discussing risks related to the lack of a majority
independent board of directors and board committees.
Item 2. Financial Information
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 8
7.Please expand your discussion to provide a quantified analysis of the significant drivers
behind material changes in your results of operations and liquidity and capital resources

 FirstName LastNameNataliia Petranetska
 Comapany NameSky Century Investment, Inc.
 November 21, 2023 Page 3
 FirstName LastNameNataliia Petranetska
Sky Century Investment, Inc.
November 21, 2023
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from period to period. When a change is attributable to more than one factor, please
quantify each material component. Please refer to the guidance in Item 303 of Regulation
S-K.
Item 4. Security Ownership of Certain Beneficial Owners and Management, page 9
8.Please update the information in this section to be as of the most recent practicable
date. Include a footnote explaining Cede & Co.'s inclusion in the table.
Item 6. Executive Compensation, page 11
9.Please revise to provide executive compensation information for the fiscal year ended
May 31, 2023 and a narrative description of the material terms of the Employment
Agreement and Compensation Agreement with Ms. Petranetska. Refer to Item 402(m)–(r)
of Regulation S-K.
Item 7. Certain Relationships and Related Transactions and Director Independence, page 11
10.Please revise to provide the information regarding the “interest-free demand loan” from
Ms. Petranetska called for by Item 404(a)(5) of Regulation S-K. Additionally, you state on
page F-12 that $75,619 was due to a related party as of May 31, 2023, but here you
indicate that the amount of your related party loan was $100,000 as of May 31, 2023;
please revise for consistency.
11.Please confirm that you have provided all information required by Item 404 of Regulation
S-K for the appropriate time period, or revise. Refer to Item 404(d) and Instruction 1 to
Item 404. For example, we note potentially disclosable activity in 2020 related to the Loan
Assignment Agreement discussed on page F-13.
Item 10. Recent Sales of Unregistered Securities, page 11
12.On page F-12, you discuss various issuances of convertible debt and the conversion of
debt into shares of common stock. Please provide the disclosure contemplated by Item
701 of Regulation S-K with respect to such issuances and conversions that occurred
within the past three years or explain why you are not required to do so.
Item 11. Description of Company's Securities To Be Registered, page 11
13.In this section and under "Possible Issuance of Additional Securities" on page 6, you
characterize your common stock as having no par value. Please reconcile these statements
with the indication on the cover page of the registration statement that your common stock
has a $0.001 par value.

 FirstName LastNameNataliia Petranetska
 Comapany NameSky Century Investment, Inc.
 November 21, 2023 Page 4
 FirstName LastNameNataliia Petranetska
Sky Century Investment, Inc.
November 21, 2023
Page 4
Item 13. Financial Statements and Supplementary Data
Report of Independent Registered Public Accounting Firm, page F-1
14.We note that your auditors have issued a qualified audit opinion. Please obtain and file a
new audit report that is unqualified and complies with the requirements in PCAOB
Auditing Standards 2415 and 3101. Please refer to the guidance in SAB Topic 1.E.2.
Item 15. Financial Statements and Exhibits, page 13
15.Please file as an exhibit a complete copy of your amended Articles of Incorporation as
currently in effect. In this regard, we note that the Articles of Incorporation as filed
contemplate that the name of the company is Band Rep Management, Inc. and that there
are 75,000,000 authorized shares of capital stock, which is inconsistent with the statement
on page 12 that there are 500,000,000 shares of common stock authorized.
16.Please file as exhibits all material contracts and plans of acquisition or disposition
discussed in the registration statement, including the Asset Purchase Agreement and
Promissory Note with Cannabis News LLC, the Data Purchase Agreement and
Promissory Note with ITEQ Logic Ltd., the Agreement and Promissory Note with
Marketbiz Limited, and the Employment Agreement and Compensation Agreement with
Ms. Petranetska. Refer to Items 601(b)(2) and 601(b)(10) of Regulation S-K.
General
17.Please update your filing with interim financial statements in accordance with Rule 8-08
of Regulation S-X.
18.We note that the business description in your OTC Pink company profile characterizes
you as "selling the highest quality CBD products using only pharmaceutical grade
ingredients." Please clarify whether your current business activities include the sale of
CBD products and, if so, add appropriate disclosure under "Item 1. Description of
Business," "Item 1A. Risk Factors," and throughout the registration statement to reflect
this fact.
19.Please note that your registration statement becomes effective automatically 60 days after
its initial filing pursuant to Section 12(g)(1) of the Exchange Act. You will then be subject
to the reporting obligations of the Exchange Act, including the requirement to file Forms
10-K, 10-Q, and 8-K, even if comments remain open on this registration statement. If you
do not wish to become subject to these reporting requirements before completion of our
review, you may wish to consider withdrawing this registration statement before it
becomes effective automatically.

 FirstName LastNameNataliia Petranetska
 Comapany NameSky Century Investment, Inc.
 November 21, 2023 Page 5
 FirstName LastName
Nataliia Petranetska
Sky Century Investment, Inc.
November 21, 2023
Page 5
            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.
            Please contact Tony Watson at 202-551-3318 or Angela Lumley at 202-551-3398 if you
have questions regarding comments on the financial statements and related matters. Please
contact Rebekah Reed at 202-551-5332 or Lilyanna Peyser at 202-551-3222 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Marc Applbaum