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 April 1, 2025

Nataliia Petranetska
Chief Executive Officer
Sky Century Investment, Inc.
220 Emerald Vista Way #233
Las Vegas, NV

 Re: Sky Century Investment, Inc.
 Amendment No. 1 to Registration Statement on Form 10-12G
 Filed March 14, 2025
 File No. 000-56603
Dear Nataliia Petranetska:

 We have reviewed your filing and have the following comment(s).

 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.

Amendment No. 1 to Registration Statement on Form 10-12G filed March 14, 2025
Item 1. Description of Business, page 1

1. Where you discuss the portion of your business regarding "the selling of
RSS feeds
 and Podcasts," please elaborate on how you generate revenues from these
activities,
 including how agreements or arrangements with clients and with sources
of the feeds
 and podcasts are structured. Additionally, we reissue the portion of
prior comment 2
 asking that you explain how the material contracts with ITEQ Logic Ltd.
and
 Marketbiz Limited on file as exhibits relate to your business
activities.
Item 1A. Risk Factors, page 4

2. We note your disclosure in response to prior comment 20 clarifying that
all
 outstanding shares of preferred stock are held by Yan Tie Ying. Please
add a risk
 factor highlighting the disparate voting rights of your preferred stock
and resulting
 concentration of control. Quantify the percentage of voting power that
 Ying controls through ownership of preferred and common stock, and state
whether
 April 1, 2025
Page 2

 they control and/or significantly influence the outcome of matters
requiring
 shareholder approval, as applicable.
Dependence on a Limited Number of Clients, page 6

3. Please provide additional detail regarding the level of customer
concentration within
 your business, such as the percentage of revenues in recent financials
periods resulting
 from one or a few major clients. Provide this information in your Item 1
business
 disclosure as well. To the extent you are substantially dependent on any
particular
 client(s), describe the material terms of your arrangements with them
and file any
 related written agreement as an exhibit to the registration statement.
Outstanding Notes Payable and Potential Dilution, page 8

4. We note your response to prior comment 5 and added disclosure that you
"may incur
 future notes payable to third parties." Please further revise to address
the promissory
 notes held by ITEQ Logic Ltd and Marketbiz Limited discussed at page
F-26.
 Disclose the aggregate outstanding amount payable to third parties and
the number of
 shares of common stock that could be issued if remaining outstanding
amounts are
 converted in full.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Overview, page 9

5. You disclose on page 12, "For the three months ended November 30, 2024,
the
 Company did not generate revenues due to a lack of proper customer
outreach as the
 Company shifted its focus to new markets and redirected resources toward
exploring
 new industry opportunities, particularly in IT Services and marketing."
You also
 disclose on pages 2 and 10 that the selling of RSS Feeds and Podcasts
accounted for
 zero revenues for the three months ended Nov. 30, 2024. Please revise
your
 discussion of the Cannabis News application and RSS Feeds and Podcasts
segments to
 accurately reflect the current status of segment operations, and your
focus on
 developing new business in the IT Services and Marketing Services
segments. Also,
 revise your discussion of the RSS Feeds and Podcasts segments elsewhere
in the
 prospectus including on pages 1, 2, 4 and 9 in Item 1 for consistency.

Item 7. Certain Relationships and Related Transactions and Director
Independence, page 17

6. Please update your disclosure regarding the 2021 Loan Agreement to
disclose the
 amount due to Nataliia Petranetska as of November 30, 2024 and the most
recent date
 for which information is available. In this regard, the outstanding
amount is provided
 only as of August 31, 2024, whereas more recent financial statements are
included in
 the filing and Item 404(a)(5) calls for the amount outstanding "as of
the latest
 practicable date." Similarly update your disclosure of payroll
liabilities due to
 Petranetska.
Item 10. Recent Sales of Unregistered Securities, page 18

7. We reissue prior comment 12 in part. Please provide the information
required by Item
 701 of Regulation S-K with respect to all convertible notes or other
debt securities
 April 1, 2025
Page 3

 issued by the company within the past three years. In this regard, it
appears that these
 issuances constituted sales of unregistered securities, and your
disclosure focuses only
 on the conversion of such notes into shares of common stock. For
example, provide
 the information required by Item 701 (e.g., date of sale, title and
amount of securities
 sold, and consideration) regarding the promissory notes issued to
Marketbiz Limited,
 ITEQ Logic, and Cannabis News LLC discussed at page F-26.
Notes to Financial Statements for the Years Ended August 31, 2024 and 2023
Note 5. Stockholders` Deficit, page F-11

8. We note your revised disclosures in Item 10 on page 18 and in Note 5 on
page F-11.
 However, the number of shares issued to Khamijon Alimzhanov between
November
 1, 2022 and January 5, 2023 totaling 49,592,469 common shares for
conversion of
 notes payable and salary debt does not appear to reconcile to the
19,092,469 common
 shares beneficially owned by him in Item 4 on page 15. Please clarify or
revise.
Note 6. Related Party Transactions, page F-12

9. Please reconcile the payroll liabilities to your director Ms.
Petranetska of $160,000
 and $100,000 at August 31, 2024 and 2023, respectively, with the amounts
on your
 consolidated balance sheets at the reporting dates. If such amounts are
included in
 accounts payable and accrued expenses on your consolidated balance
sheets at August
 31, 2024 and 2023, please revise to separately present amounts due to
related parties
 for accounts payable and accrued expenses. This comment also applies to
the accrued
 payroll liabilities to your director of $175,000 and $160,000 at
November 30, 2024
 and August 31, 2024, respectively, in Note 6 on page F-25. Refer to Rule
4-
 08(k)(1) of Regulation S-X.
10. Please revise your disclosures to include the issuance of 21,142,857
common shares to
 Mr. Alimzhanov on November 1, 2022 for the conversion of outstanding
notes
 payable as disclosed in Note 5 on page F-12. Please note this revision
also applies to
 the disclosure in Note 6 on page F-25 of your interim financial
statements for the
 three months ended November 30, 2024.
11. It appears the disclosure of the 30,232,558 shares authorized for
issuance on July 1,
 2022 represents the same 15,116,279 shares disclosed as issued on
November 23,
 2022 and the 15,116,279 shares issued on December 12, 2022. Please
clarify or
 revise. Please note this revision also applies to the disclosure in Note
6 on page F-
 25 of your interim financial statements for the three months ended
November 30,
 2024.
 April 1, 2025
Page 4

 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 Robert Shapiro at 202-551-3273 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
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