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CORRESP
1
filename1.htm

September
23, 2025

Charli
Wilson

Kathleen
Krebs

Office
of Technology

Division
of Corporation Finance

Securities
and Exchange Commission

Washington
DC 20549

    Re:
    RAD
    Technologies Inc.

    Offering
    Statement on Form 1-A

    Post-qualification
    Amendment No. 1

    Filed
    August 26, 2025

    File
    No. 024-12513

Dear
Ms. Wilson and Ms. Krebs:

Thank
you for the opportunity to respond to the comment letter received from the staff of the Division of Corporate Finance (the “Staff”)
on September 15, 2025 regarding the post-qualification amendment to the Offering Statement on Form 1-A of RAD Technologies Inc. (the
“Company”). The comments are set out below followed by the Company’s response.

Post-qualification
Amendment No. 1 to Offering Statement on

Form 1-A General

 1. Under
                                            Rule 251(a)(2), the sum of the aggregate offering price of the current offering and aggregate
                                            sales for all securities sold pursuant to other offering statements within the 12 months
                                            before the start of and during the current offering cannot exceed $75 million. We note that
                                            the aggregate offering price of the current offering is $72,539,998.89, and the explanatory
                                            note on the cover page indicates that to date, approximately 22,619,999 Class B shares have
                                            already been sold, representing $11,454,018.34 in gross proceeds. Please adjust your offering
                                            to comply with the $75 million cap or explain why you believe the current offering complies
                                            with Rule 251(a).

The
value of the current offering, which includes cash value of the shares and implied value of the Bonus Shares, reflects an aggregate amount
that includes amounts previously sold, and not in addition to. This has been clarified throughout to avoid confusion.

 2. Your
                                            original Form 1-A qualified 21,818,181 Class B shares and disclosed that the offering would
                                            terminate as follows: 

 ● Cover
                                            page: “The Offering will terminate at the earlier of the date at which the maximum
                                            offering amount has been sold or the date at which the offering is earlier terminated by
                                            the Company at its sole discretion.”

 ● Plan
                                            of distribution: “The Company intends for this offering to continue until one year
                                            following qualification by the SEC, or until sooner terminated by the Company.”

 ● Plan
                                            of distribution: “The Offering will terminate at the earliest of: (1) the date at which
                                            the maximum offering amount has been sold, (2) the date which is three years from this offering
                                            being qualified by the Commission, and (3) the date at which the offering is earlier terminated
                                            by us at our sole discretion.”

Because
the original Form 1-A qualified 21,818,181 Class B shares, it appears that the offering terminated when the offering closed on June 15,
2025, with the sale of 22,619,999 Class B shares. Please file a new Form 1-A for the current offering or advise why you believe the original
offering has not been terminated. In addition, disclose what exemption you relied on for the sale of the additional shares beyond the
amount qualified under the original Form 1-A.

The
stated value on the explanatory note and in Part I of the last filed post-qualification amendment included an incorrect value for the
number of shares having been already issued in this offering due to an error in the calculation in an Excel document for the purposes
of this post-qualification amendment, which did not impact the shares received by investors . The amount has been corrected to 21,646,621.

Cover
Page

 3. Please
                                            revise so that it is clear when the offering will terminate. Your disclosure on the cover
                                            page and within the plan of distribution is inconsistent.

The
Company has amended its disclosure regarding termination of the Offering.

Risk
Factors, page 7

 4. Your
                                            “Plan of Distribution” section indicates that, after $17 million shares are sold
                                            for cash, closing of subscriptions will include a portion of shares offered by the company
                                            and a portion of shares offered by selling shareholders. Please provide a risk factor addressing
                                            that the company’s offering is not separate from the selling shareholders’ offering,
                                            purchasers in the offering will not be able to choose whether they are buying shares from
                                            the company or selling shareholders, and this may result in the company receiving less proceeds.

The
Company has amended its Offering Statement to include a risk factor regarding certain proceeds from the Offering being received by selling
shareholders rather than by the Company.

Plan
of Distribution and Selling Security Holders

Bonus
Shares for Certain Investors (Up to 15%), page 37

 5. We
                                            note that Bonus Shares are disclosed as “up to 15%” in some places and 20% in
                                            other places within the filing. Please revise for consistency throughout.

The
Company has amended its Offering Statement to correct the references to the percentage of Bonus Shares available in the Offering.

Thank
you again for the opportunity to respond to your questions to the Offering Statement of RAD Technologies Inc. If you have additional
questions or comments, please contact me at andrew@crowdchecklaw.com.

Sincerely,

/s/
Andrew Stephenson

Andrew Stephenson

Partner

CrowdCheck
Law LLP

cc: Jeremy
                                            Barnett, Chief Executive Officer, RAD Technologies Inc.