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July 11, 2023
Sean Peace
Chief Executive Officer
RoyaltyTraders LLC
1053 East Whitaker Mill Rd.
Suite 115
Raleigh, NC 27604
Re:RoyaltyTraders LLC
Offering Statement on Form 1-A
Post-Qualification Amendment No. 6
Filed June 14, 2023
File No. 024-11532
Dear Sean Peace:
            We have reviewed your 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 offering 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 offering statement and the information you
provide in response to these comments, we may have additional comments.
Post-Qualification Amendment No. 6 to Offering Statement on Form 1-A
Risk Factors, page 5
1.Please revise your registration statement to include a Risk Factor summary as required by
Item 3(b) of Form 1-A.
Investor Perks
NFT Perk, page 20
2.Please provide us with your detailed legal analysis as to why your “NFT Perk” program
through OneOf does not involve the offer and sale of securities within the meaning of
Section 2(a)(1) of the Securities Act of 1933, the offer and sale of which should be
registered under the Act. Your analysis should address the NFTs themselves and the

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program or ecosystem through which the NFTs are being issued. See Gary Plastic
Packaging Corp. v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 756 F.2d 230 (2d Cir.
1985).
3.Please provide your analysis explaining why the value of the NFTs offered in connection
with the purchase of each RSU in the offering should not count towards the aggregate
offering price.
4.Please provide a materially complete description of the NFTs offered through the OneOf
platform, including whether there are any perks or benefits flowing from holding the
NFTs. Please expand your disclosure to explain whether there are any differences in the
NFTs to be issued on the Tezos blockchain.
The Company's Business
Overview of Our Company, page 52
5.We note your disclosure that record labels are provided with “tools and strategies enabled
by the SongVest Platform to collectively promote albums” and that this promotion could
potentially further the success of a release and generate more revenue. Please describe
how the SongVest platform is utilized to achieve these goals.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Emerging Growth Company, page 58
6.Disclosure here indicates that you will qualify as an emerging growth company and that
this will be significant if and when you become subject to the ongoing reporting
requirements of the Securities Exchange Act of 1934. Please revise to clarify whether you
intend to register a class of securities under Section 12 of the Exchange Act and whether
you intend to do so by filing a Form 10 or a Form 8-A in connection with this offering
statement. To the extent you intend to become an Exchange Act reporting company in
connection with this offering, please revise to briefly summarize your Exchange Act
reporting obligations. Otherwise, please revise to briefly summarize your reporting
obligations as a Tier 2 Regulation A issuer and remove all references to an initial public
offering.
Part II and III
Management's Discussion and Analysis of Financial Condition and Results of Operations
Issuances of Equity, page 60
7.You disclose that the Simple Agreements for Future Equity (SAFEs) are convertible "at
the option of the company" upon an equity financing in which up to $5.0 million in
proceeds are received.  On page F-14 you disclose that the SAFEs will "automatically
convert" into Conversion Units upon the closing of the next equity financing or in the
event of a company transaction prior to the next equity financing, which ever comes
first. Please revise to clarify these apparent inconsistencies and revise your disclosures to

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Sean Peace
RoyaltyTraders LLC
July 11, 2023
Page 3
address the following:
•Explain what is meant by "next equity financing" or "Company transaction" as it
relates to the conversion of such SAFEs and whether conversion is at the option of
the company or automatic.
•Disclose how the Conversion Units will be determined.
•Clarify whether there have been any conversions into equity as of the date of this
Offering Statement and if so, the number of Conversion Units issued.
Securities Being Offered
Waiver of Right to Trial by Jury, page 70
8.We note that Section 6 of the Subscription Agreement includes an exclusive forum
provision and a jury trial waiver provision for certain claims against you.  Please add risk
factor disclosure regarding the two provisions and address, without limitation, how these
provisions may impact shareholder rights and whether they apply to claims under the
federal securities laws.
General
9.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
            We will consider qualifying your offering statement at your request.  If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            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.
            You may contact Joyce Sweeney, Senior Staff Accountant, at 202-551-3449 or Kathleen
Collins, Accounting Branch Chief, 202-551-3499 at  if you have questions regarding comments
on the financial statements and related matters.  Please contact Charli Gibbs-Tabler, Staff
Attorney, at 202-551-6388 or Jeff Kauten, Staff Attorney, at 202-551-3447 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology