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April 28, 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 April 22, 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 to Form S-1 filed April 22, 2021
General
1.We note your revisions in response to our prior comment three.  However, certain
disclosure in your prospectus, such as the Plan of Distribution on page 24, continue to say
that the selling shareholders will sell shares at market prices.  Please revise throughout
your prospectus, as appropriate, to disclose that the selling shareholders will sell at a fixed
price and to name that price.

 FirstName LastNameMario Todd
 Comapany NameStark Focus Group, Inc.
 April 28, 2021 Page 2
 FirstName LastName
Mario Todd
Stark Focus Group, Inc.
April 28, 2021
Page 2
            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, Legal Branch Chief, at
202-551-3442 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services