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April 7, 2021
Mario Todd
Chief Executive Officer
Stark Focus Group, Inc.
Suite 3001, 505 6th Street SW
Calgary AB T2P 1X5
Re:Stark Focus Group, Inc.
Post Effective Amendment No. 1 to Registration Statement on Form 1-A
Filed March 29, 2021
File No. 333-237100
Dear Mr. Todd:
            We have reviewed your post-effective amendment 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.
Post Effective Amendment No. 1 to Registration Statement on Form 1-A
Executive Compensation, page 41
1.Please update this section to include compensation for the most recently completed fiscal
year.
General
2.Please update to include audited financials for the most recently completed fiscal year and
related disclosure.
3.To sell shares at market prices, an existing trading market for those shares must exist in
order to satisfy Rule 501(b)(3) of Regulation S-K. The OTC Pink Marketplace, where
your shares are quoted, is not considered to be such a market. Accordingly, please revise

 FirstName LastNameMario Todd
 Comapany NameStark Focus Group, Inc.
 April 7, 2021 Page 2
 FirstName LastName
Mario Todd
Stark Focus Group, Inc.
April 7, 2021
Page 2
your cover page disclosure and make corresponding changes elsewhere in the prospectus,
as appropriate, to disclose that the selling shareholders will sell at a fixed price and
to name that price.
            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.
            Please contact Charlie Guidry at 202-551-3621 or Erin Jaskot at 202-551-3442 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services