SecProbe.io

February 4, 2020
Alton “Ace” Chapman, Jr.
Chief Executive Officer
Freedom Internet Group Inc.
151 Calle San Francisco, Suite 200
San Juan, Puerto Rico 00901
Re:Freedom Internet Group Inc.
Registration Statement on Form S-1
Filed January 10, 2020
File No. 333-235873
Dear Mr. Chapman:
            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 registration 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 registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-1 filed January 10, 2020
Principal Shareholders, page 20
1.Please identify any greater than 5% beneficial owners underlying the SAFE conversions
or advise.  See Item 403(a) of Regulation S-K.  Also disclose whether your officers and
directors plan to acquire shares in the offering.  We note your assumption in footnote (1)
to the table.
Description of Our Business
Customers, page 22
2.Please describe the material terms of your agreements with Wiz Motions, LLC, Offito,
LLC, and Growth Stack, Inc., such as the duration, events of default and termination
provisions.

 FirstName LastNameAlton “Ace”  Chapman, Jr.
 Comapany NameFreedom Internet Group Inc.
 February 4, 2020 Page 2
 FirstName LastName
Alton “Ace”  Chapman, Jr.
Freedom Internet Group Inc.
February 4, 2020
Page 2
Material Agreements, page 24
3.Please disclose the milestones that would result in the company's obligations to pay
additional cash consulting fees.
Related Party Transactions, page 28
4.We note your related party transaction disclosure in footnote 5 to the financial statements
and your statement that “the Company is a member of a group of entities affiliated
through common management.”  Please provide the disclosure required by Item 404(d) of
Regulation S-K or advise.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Jeffrey Lewis at 202-551-6216 or Jennifer Monick at 202-551-3295 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Ronald (Ron) Alper at 202-551-3329 or Brigitte Lippmann at 202-551-3713  with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       David Bovi