SecProbe.io

Mail Stop 3030
December 21, 2017

Via E -mail
George Henschke
Interim Chief Financial Officer
KT High -Tech Marketing, Inc.
14440 Big Basin Way #12
Saratoga, CA  95070

Re: KT High -Tech Marketing, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2016
Filed March 3 0, 2017
Form 10 -Q for the Quarterly Period Ended September 30, 2017
Filed November 17, 2017
File No . 000-55564

Dear Mr. Henschke :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After review ing your response to these  comments, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 2016

Item 9A. Controls and Procedures

Management's Annual Report on Internal Control over Financial Reporting, page 18

1. Please amend  the filing to describe the material weaknesses identified in your internal
controls over financial reporting as of December 31, 2016, as require d by Item 308(a) (3)
of Regulation S -K.  Clearly explain to us management’s conclusion that these material
weakn esses did not also impact your disclosure controls and procedures at December 31,
2016.

George Henschke
KT High -Tech Marketing, Inc.
December 21 , 2017
Page 2

 2. In the requested amendment, revise management’s report to identify the version of the
Committee of Sponsoring Organizations of the Treadway Commission (COSO) Internal
Control - Integrated Framework that was used to perform your assessment, i.e., the 1992
Framework or the Updated Framework issued in 2013 .  Please refer to Item 308(a)(2) of
Regulation S -K.

Form 10 -Q for the Quarterly Period Ended September 30, 2017

Item 4.  Control s and Procedures, page 15

3. Management’s  conclu sion that  your disclosure controls and procedures were effective
“due to the inadequate recordation of certain transactions and communication of those
transactions to those integral to [your] disclosure procedures ” appears to be incongruous,
as the items noted appear to be deficiencies or weaknesses. Further,  we note that your
management concluded that your disclosure controls and procedures were not effective  at
March 31, 2017 because of the same issues.   Please amend the filing to correct the
disclosure, or explain to us how management was able to conclude that your disclosure
controls and procedures were effective as of September, 30, 2017 in light of the issues
identified.  This comment also app lies to your June 30, 2017 Form 10 -Q.  Refer to the
guidance in Item 307 of Regulation S -K and Exchange Act Rule 13(a) -15(e).

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.

You may contact Tara Harkins  at (202) 551 -3639 or Lynn D icker , Senior Accountant , at
(202) 551 -3616 with any questions.   You may also reach  me at (202) 551 -3662.

Sincerely,

 /s/ Lynn Dicker for

Kevin J. Kuhar
Accounting Branch Chief
       Office of Electronics and Machinery