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March 28, 2024
Varton Berian
Chief Executive Officer
Certiplex Corporation
663 Rancho Santa Fe Rd Suite 628
San Marcos, CA 92078
Re:Certiplex Corporation
Amendment No. 3 to Registration Statement on Form S-1
Filed March 7, 2024
File No. 333-274531
Dear Varton Berian:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration 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 registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our February 15, 2024 letter.
Amendment No. 3 to Registration Statement on Form S-1
Cost of Business Module, page 23
1.We note your response to prior comment 2 and reissue it in part. Please revise here to
further disclose whether you establish, operate or otherwise participate in all of the
businesses of the business modules prior to selling them; if you do not, please indicate the
percentage of business modules sold that relate to businesses you establish, operate or
otherwise participate in, and the percentage of business modules sold that relate to
businesses established and described to you by your customers. To the extent you operate
the businesses of business modules prior to selling the related business modules, disclose
the average length of time you operate such businesses before selling the business module.

 FirstName LastNameVarton Berian
 Comapany NameCertiplex Corporation
 March 28, 2024 Page 2
 FirstName LastName
Varton Berian
Certiplex Corporation
March 28, 2024
Page 2
Description of Business
Pro Sun Lights, page 24
2.We note your response to prior comment 4 and reissue it. Please revise here to further
disclose the material terms of the licensing agreement, including the material obligations
of both parties and termination provisions. Refer to Item 601(b)(10) of Regulation S-
K. As an example only, although we note your disclosure that "the agreement commenced
on the Effective Date and will continue in full force in perpetuity," we note the licensing
agreement states that "[e]ither party may terminate this Agreement immediately upon
delivery of written notice to the other Party specifying clearly the grounds for termination
if the other party commits a material breach of its obligations under this Agreement and
fails to cure the breach within 90 days after written notice of the breach is received by the
breaching Party" and that "termination will be without prejudice to any liability incurred
prior to the effective date of termination."
Financial Statements, page 36
3.Please update your financial statements to include the fiscal year ended December 31,
2023 pursuant to Rule 8-08 of Regulation S-X.
            Please contact Amy Geddes at 202-551-3304 or Theresa Brillant at 202-551-3307 if you
have questions regarding comments on the financial statements and related matters. Please
contact Rucha Pandit at 202-551-6022 or Lilyanna Peyser at 202-551-3222 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services