SecProbe.io

April 24, 2020
William Drury
President and Treasurer
Hub Deals Corp.
200 Rector Place, Suite 17F
New York, New York 10280
Re:Hub Deals Corp.
Amendment No. 1 to Registration Statement on Form S-1
Filed April 10, 2020
File No. 333-236684
Dear Mr. Drury:
            We have reviewed your amended 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.  Unless we note
otherwise, our references to prior comments are to comments in our [Month day, year] letter.
Form S-1 Amendment No. 1 filed on April 10, 2020
Description of Business, page 23
1.We note your revisions in response to our prior comment 4 and your disclaimer that your
website is not included as part of your prospectus.  However, we note from your website
your process for a person to bid on a item and the large spectrum of products that you are
offering for sale.  Please augment your discussion to describe each category of products
you are offering and any differences in how you would promote and sell those different
categories of products (e.g., fine art versus real estate).  Please also provide details on the
process by which a person would bid on and purchase a luxury product using your system,
and how you will generate income from the sale of each category of products on your
site.  We also note that you include real estate on your website; please disclose whether

 FirstName LastNameWilliam Drury
 Comapany NameHub Deals Corp.
 April 24, 2020 Page 2
 FirstName LastName
William Drury
Hub Deals Corp.
April 24, 2020
Page 2
the company or your chief executive officer is a registered real estate broker or advise on
how your real estate sale process works given the regulations of the real estate industry
that are not applicable to the sale of luxury products.
2.We note your revisions to your disclosure in response to prior comment 6.  Please expand
your disclosure to include a brief discussion of any process by which you authenticate and
appraise the luxury goods that you purchase to resell on your site or that you agree to offer
on your site on behalf of a current owner, or state that you have no such process. Please
also clarify whether you provide potential buyers with any assurances regarding the
authenticity and value of the products offered on your site.
3.It appears that you will offer for sale on your website products that are currently owned by
private owners, as well as products that you purchase from private owners and seek to
resell.  If true, please revise your disclosure to clarify that this is the case.  In addition,
please disclose the process by which you identify products to be offered on your site, the
material terms of your agreements to sell products that are currently owned by others,
and the process by which you identify, appraise and purchase products for resale by the
company.  Please also revise your disclosure to describe how your marketing efforts that
target potential buyers will differ from your marketing efforts that target potential sellers.
Further, please describe any fees or commissions that the parties to any auction, including
the company in its roles as seller and/or intermediary broker, will pay or collect.
Other Expenses of Issuance and Distribution, page 34
4.Please include your legal fees of $15,000 in your expense chart, or tell us why that is
unnecessary.  Please see Item 511 of Regulation S-K.
            You may contact Suying Li, Staff Accountant at 202-551-3335 or Doug Jones, Staff
Accountant at 202-551-3309 if you have questions regarding comments on the financial
statements and related matters.  Please contact Scott Anderegg, Staff Attorney at 202-551-3342
or Lilyanna Peyser, Special Counsel at 202-551-3222  with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services