SecProbe.io

CORRESP
1
filename1.htm

September
26, 2024

Kibum
Park

Office
of Real Estate & Construction

Division
of Corporation Finance

    Re:

    Pacaso
                                            Inc.

    Offering
    Statement on Form 1-A

    Filed
    September 9, 2024

    File
    No. 024-12501

Mr.
Park:

Please
see below for responses to the Division’s letter dated September 26, 2024 regarding the above captioned matter. All questions have
been addressed in Amendment No. 1 to the Offering Statement, on Form 1-A/A, filed September 26, 2024 (“Amendment”), as further
herein detailed.

Offering
Statement on Form 1-A

Cover
Page

1.
We note your disclosure on page 66 that while each share of Class A Common Stock entitles the holder to ten votes and each share of Class
C Common Stock entitles the holder to one vote, “Class D Common Stock and Class B Common Stock are non-voting and shall not be
entitled to vote on any company matter.” Please revise your cover page to describe any disparate voting rights between different
classes of your common stock. Please also reconcile the disclosure on the cover page, which states that you are offering Class D common
stock, with disclosure on page 66, which states that you are offering Class B common stock.

We
have revised the cover page and the summary of the Amendment to include the requested disclosures. We have also corrected the typo on
page 66 to make clear that the Company is offering Class D Common Stock.

We
appreciate your time and attention in this matter. If you have any questions or comments, please reach out to Arden Anderson, Esq. at
arden@crowdfundinglawyers.net.

Sincerely,

/s/
Dodson Robinette PLLC

d/b/a
Crowdfunding Lawyers