SecProbe.io

Mail Stop 4561
  October 2 , 2015

Lakhwinder Singh Sidhu, President
SavMobi Technology Inc.
73B Bank Avenue
Amritsar, Punjab, 143001
India

Re: SavMobi Technology Inc.
Registration Statement on Form S -1
Filed September 8, 2015
  File No. 333-206804

Dear Mr. Sidhu :

 We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

 Please respond to this letter by amending your registratio n statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

 After reviewing any amendment to your regi stration statement and the information you
provide in response to these comments, we may have additional comments.

General

1. We note your disclosure on page 36 stating that you “ expect the balance of the proceeds
to be mainly applied to further costs of this prospectus and administrative costs. ”
However, we note your tabular disclosure on page 16 indicating that irrespective of the
proceeds raised, you intend to allocate a majority of the proceeds towards general
business development, and sales and marke ting.  Please ensure that your disclosure
consistently describe your intended allocations of proceeds.

2. With respect to every third -party statement in your prospectus, such as the  Borell
Associates report , please ensure that you have disclosed the report d ates, and provide us
with the relevant portions of the industry research reports you cite.  To expedite our
review, please clearly mark each source to highlight the applicable portion containing the

Lakhwinder Singh Sidhu
SavMobi Technology Inc.
October 2, 2015
Page 2

 statistic, and cross -reference it to the appropriate loca tion in your prospectus and tell us
whether any of the reports were prepared for you.

3. Revise your summary to disclose that your auditors have expressed substantial doubt
about your ability to continue as a going concern.

Risks and Uncertainties Facing th e Company, page 6

4. We note your disclosure on page 22, where you estimate the total software development
cost for your platform an d app at $38,000.  Please revise your disclosure here to describe
quantitatively the threshold gross offering amount required to fund the software
development.

Use of Proceeds, page 8

5. You state that  you may fund you r operations through loans based on a verbal agreement
with Mr. Sidhu .  Where you reference such loans throughout the document, please also
state whether the agreement with Mr. Sidhu to provide funding is legally binding , to the
extent that it is not, revise throughout to state  clearly and unequivocally that  there is no
guarantee that he will provide such funding.

Risk Factors , page 9

6. Please add a risk f actor that clearly and unequivocally states that you have not yet
developed your software platform or app, and that the resultant risk is that you may never
be able to develop a product that is operational or marketable.

7. Please add a separately captioned  risk factor disclosing the minimum number of months
that you will be able to conduct your planned operations using currently available capital
resources.  In addition, disclose the minimum dollar amount of funding you require to
implement your business plan for a minimum period of one year.  Revise your discussion
in Capital Resources and Liquidity to also include this information.

“Because our sole officer  and director resides abroad…,” page 13

8. Please provide a more detailed description of your risk factor addressing why
shareholders may have difficulties enforcing their legal rights under  United States
securities laws.  Please address the risk U.S. stockh olders face in:

 effecting service of process within the United States against your officer;
 enforcing judgments obtained in U.S. courts based on civil liability provisions of the
U.S. federal securities laws in foreign courts against your officer; and
 bringing an original action in foreign courts to enforce liabilities based on the U.S.
federal securities laws against your officer.

Lakhwinder Singh Sidhu
SavMobi Technology Inc.
October 2, 2015
Page 3

 “Because our Company is a shell company …,” page 13

9. Please expand your disclosure to explain that  Securities Act Rule 144 will not be
available  for privately placed shares, and highlight the impact on your ability to attract
additional capital to implement your business plan or sustain operations.

Plan of Distribution, page 19

10. You state that you int end to sell the shares outside the United States, particularly in India.
Please expand your plan of distribution discussion with respect to your plan to sell shares
in India.

11. You state that the offering may be extended 90 days beyond the period described in this
section, or “such period as the Company deems reasonable.”  Please revise your
disclosure to ensure that your intentions in regards to extending the offering period are
balanced with the requirements of Rule 415 and section 10(a)(3) of the Securiti es Act.

Description of Securities to be Registered

Non-cumulative voting, page 20

12. You state that if the offering is completed the “present shareholders” will hold 21% of the
offering.  This st atement is inconsistent with your disclosures in the  beneficial ownership
table.  Please revis e or advise.

Description of Business

Market Opportunity and Value Proposition , page 24

13. We note that you reference the boom in the smartphone market as potentially providing
your company the opportunity to generate more revenue through your proposed Mobile
Marketing Platform.   Please refocus your discussion on the specific market opportunity
you intend to pursue, which you state is vendor tools technology.

Competition, page 25

14. We note your disclosure referring to your “current revenue streams” and statement that
your “primary source of revenue comes from local, small businesses.”  Since y ou have
yet to generate revenues, these disclosures appear inappropriate, as they suggest the
contrary.

15. Please expand your disclosure to describe with more specificity on what competitive
bases you intend to distinguish yourself.

Lakhwinder Singh Sidhu
SavMobi Technology Inc.
October 2, 2015
Page 4

 Directors  and Executive Officers

Business Experience, page 31

16. Please revise  the description relating to Mr. Sidhu’s  professional background  to ensure
that such disclosures fully comply with Item 401(e) of Regulation S -K.  For example,
disclose Mr. Sindhu’s  principal occupations  and employment, in a chronologically
complete manner, for the five year period immediately precedi ng the date of
effectiveness.

17. We note your disclosure stating that Mr. Sidhu has not held any previous directorships in
the past five years.  However, w e note tha t the Nevada Secretary of State’ s website
indicates that in addition to serving as an officer for SavMobi Technology, Inc., Mr.
Sidhu served as an officer  and director  for SavMobi, Inc. , within the past five years.
Please advise whether this is yo ur CEO, and if so, please provide your analysis for why
such professional experience is not disclosed in the registration statement.    To the extent
material, revise your discussion of trademarks on page 25 to discuss whether your ability
to obtain a trade mark may be impacted by the prior formation of SavMobi, Inc.

You may contact Morgan Youngwood, Staff Accountant, at (202) 551 -3479, or Stephen
Krikorian, Accounting Branch Chief, at (202) 551 -3488, if you have any questions regarding
comments on the finan cial statements and other related matters.  If you have any other questions,
please contact Ivan Griswold, Attorney -Advisor, at (202) 551 -3853 or in his absence, me at
(202) 551 -3462.  If you require further assistance, please contact Barbara C. Jacobs, As sistant
Director, at (202) 551 -3730.

        Sincerely,

        /s/ Mark P. Shuman

        Mark P. Shuman
        Branch Chief - Legal
Office of Information
Technologies and Services

cc:  Andrew Befumo , Esq.
 Befumo and Schaeffer, PLC