SecProbe.io

Mail Stop 4631
July 14, 2016

Via E -mail
Michael Mo
Chief Executive Officer
KT High -Tech Marketing Inc.
14440 Big Basin Way, #12
Saratoga, California 95070

Re: KT High -Tech Marketing Inc.
  Registration Statement on Form  S-1
Filed  June 28, 2016
  File No.  333-212272

Dear Mr. Mo :

We have limited our review of your registration statement to those issues we have
addressed in our 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 registration statement and providing the
requested information .  If you do not believe our com ments 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 registration statement and the information you
provide in response to these  comments, w e may have  additional comments.

General

1. Please note that security holders who receive s ecurities from a shell  company are considered
underwriters in connection with any resale of those s ecurities .  Please revise your disclosure
to indicate that the selling security holders will offer and sell their shares for a fixed price for
the duration of the offering, disclose the price at which the selling security holders will offer
their shares, and identify the resellers as underwriters.  With respect to the primary offering,
notwithstanding the disclosure that indicates that the company will offer the shares at $1.00
until the company’s stock is listed on a national securities exchange or quoted on the OTCBB
and thereafter at prevai ling market prices, the company is not permitted to conduct an at the
market primary offering under Rule 415(a)(1)(x).  Please revise your disclosure throughout
the prospectus to remove a ny and all indications that the company will offer and sell its share
at ma rket prices.

Michael Mo
KT High -Tech Marketing Inc.
July 14, 2016
Page 2

 2. Please describe how the selling security holders acquired the securities they may offer and
sell pursuant to the registration statement, including the dates of the transactions and the
consideration paid by the selling security holders.

3. Please identify by name the natural person(s) who exercise voting or investment control or
both with respect to the shares held by any of the selling security holders that are not natural
persons.   For guidance, please refer to Question 140.02 of the Regulation S -K Compliance
and Disclosure Interpretations.

4. Please disclose any position, office, or other material relationship that any selling security
holder has had within the past three years with you or any of your predecessors or affiliates.
Refer to Item 507 of Regulation S -K.

5. Given the amount and nature of your current assets and operations, it appears that you may
be a shell company.  Please note that the definition of a shell company as set forth in Rule
405 of Regulation C under the Securities Act of 1933  does not turn on whether the company
is actively pursuing a business plan.  Please revise disclosure throughout the registration
statement to state that you are currently a shell company, or otherwise provide us with a
detailed legal analysis explaining w hy you would not qualify as such.

Other expenses of issuance and Distribution, page 44

6. Please fill in all blanks in this section whe n you file your next amendment.

Recent Sales of Unregistered Securities, page 44

7. We note your disclosure that 3,800,000 shares of your common stock were issued pursuant to
a Regulatio n D offering.  It does not appear that you have filed a Form D.  Please advise.

Exhibits , page 44

8. Please provide an opinion that addresses the legality of the shares of common stock  offered
by the company and the selling security holders.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all appl icable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement , please provide a written statement from the company
acknowledging that:

Michael Mo
KT High -Tech Marketing Inc.
July 14, 2016
Page 3

  should the Commission or the staff, acting pursuant to delegated authority , declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve  the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above r egistration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact Asia Timmons -Pierce, Staff Attorney, at (202) 551 -3754  or me at (202)
551-3397 with any questions.

Sincerely,

 /s/ Jay Ingram

Jay Ingram
Legal Branch Chief
Office of Manufacturing and
Construction