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April 26, 2024
Dan Novaes
Chief Executive Officer
Mode Mobile, Inc.
One East Erie Street, Suite 525
Chicago, IL 60611
Re:Mode Mobile, Inc.
Offering Statement on Form 1-A
Filed March 28, 2024
File No. 024-12419
Dear Dan Novaes:
            We have reviewed your offering statement and have the following comments.
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies 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 offering statement and the information you provide in
response to this letter, we may have additional comments. References to our prior comments
refer to our letter dated March 11, 2024.
Offering Statement on Form 1-A
Current (Gibraltar) Limited & $CRNC Token Issuance, page 17
1.Please incorporate your responses to prior comment 3 in your Offering Circular.
Securities Being Offered, page 26
2.We note your response to prior comment 4 regarding the rights and privileges of your
equity securities. In your selling securityholders' table on page 42, you indicate that your
selling securityholders will convert their Seed Series Preferred, Class A Common Stock,
and Class B Common Stock underlying Options into 30 million Class AAA Common
Stock and offer these shares in this Offering Statement. However, in this section, you do
not indicate that such shares are convertible into Class AAA Common Stock. Instead, you
disclose that Class AAA Common Stock, Class B Common Stock, Class C Common
Stock, and Seed Series Preferred shares are convertible into Class A Common Stock under
certain circumstances. Please clarify this discrepancy.

 FirstName LastNameDan Novaes
 Comapany NameMode Mobile, Inc.
 April 26, 2024 Page 2
 FirstName LastName
Dan Novaes
Mode Mobile, Inc.
April 26, 2024
Page 2
Plan of Distribution and Selling Security Holders, page 36
3.We note your response to prior comment 6 regarding your bonus share program for
existing shareholders of other companies listed on page 37.  While you indicate you have
no commercial relationship with each of these companies, please clarify if these
companies are aware you are offering bonus shares to their existing shareholders and if
there is an arrangement or expectation, or lack thereof, of offering similar bonus shares to
their shareholders in future offerings. Further, while you indicate the criteria used for each
entity to be chosen, please clarify how you discovered or identified each company. For
example, if they were referred to you by your placement agent or other sources.
            We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            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. We also remind you that, following qualification of your Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered by the report.
            Please contact Edwin Kim at 202-551-3297 or Matthew Derby at 202-551-3334 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Andrew Stephenson