SecProbe.io

October 10 , 2014

Via E -Mail
Daniel Davis , CEO
ASN Technologies, Inc.
10291 South 1300 East, #118
Sandy, UT 84094

Re: ASN Technologies, Inc.
Amendment No. 1 to Registration Statement on Form S -1
Filed September 22, 2014
  File No. 333 -198168

Dear Mr. Davis :

We have reviewed your amended registration statement and response letter and have the
following comments.  Unless otherwise noted, where prior comments are referenced, they refer
to our letter dated September 11, 2014.

General

1. We note that certain graphics  of your proposed web platform  appear on the inside of the
prospectus.  Please note that graphic presentations should accurately represent your
curre nt business.  For example, it does  not appear  appropriate to depict webpage
snapshots for a platform  that i s not yet operational.  For guidance, refer to our Securities
Act Forms Compliance and Disclosure Interpretation 101.02.   Please revise accordingly.

Summary, page 4

2. Your disclosure states in part that you are seeking funding “for the purpose of further
development and marketing of [y]our application.”   This statement conflicts with your
use of proceeds disclosures and your response to prior comment 10.  Please revise your
summary to  clarify, consistent with your prior response, that development of the web -
based application will be done by Mr. Davis in house  and that the offering proceeds and
existing cash resources will not be used to fund the development of the app.

3. You state that your prototype web  application can be accessed on the Internet .  The
under lying platform , however,  does not yet appear fully operational .  In this regard, we
note that you characterize the platform a s “functional” throughout the filing.  Please
revise your disclosure to reflect the current status of the platform  or advise as to  how this
characterization is consistent with your disclosure.

Daniel Davis
ASN Technologies, Inc.
October 10, 2014
Page 2

 Use of Proceeds, page 11

4. Your response notwithstanding, please revise the use of proceeds table to reflect the use
of net proceeds only.  Review your disclosure throughout, including “The Offering —Use
of Proceeds” on page 4 and “Liquidity and Capital Resources” on page 24, to cons istently
refer to your use of proceeds net of offering expenses . Refer to Item 504 of
Regulation S -K.

Marketing and Competition, page 18

5. We note your response to prior comment 13.  Please expand your disclosure to clarify
what you mean by your statement  that the data is “temporally -attenuated.”

Index to Financial Statements, page 22

Exhibit 23.1

6. Please provide a currently dated consent from your independent audit ors.  Refer to Item
601(b)(23) of Regulation S -K.

Management’s Discussion and Analysis of Financial Condition  and Results of Operations

Planned Operations and Budget for Fiscal Year Beginning July 1, 2014 , page 23

7. You state that development of the basic prototype was performed by Mr. Davis.
Additionally, on page 26, you state that you have not entered into an employment
agreement with Mr. Davis.  Expand your disclosure to address any risks relating to the fact
that your sole software developer has not entered into a contract governing the ownership
of any developed intellectual property assets.

You may contact Rebekah Lindsey , Staff Accountant, at (202) 551 -3303  or Patrick Gilmore ,
Accou nting Branch Chief, at (202) 551 -3406  if you have questions regarding comments on the
financial statements and  related matters.  If you have any other questions, please contact Ivan
Griswold, Attorney Advisor, at (202) 551 -3853 , or in h is absence, me at (202) 551 -3457 .

 Sincerely,

 /s/ Maryse Mills -Apenteng

Maryse Mills -Apenteng
Special Counsel

cc:  Via E-Mail
  Anthony D. Guenther, Esq.