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CORRESP
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filename1.htm

MAG
MILE CAPITAL, INC.

1141
W. Randolph St.

Suite
200

Chicago,
IL. 60607

February
14, 2024

Via
Edgar Correspondence

Austin
Pattan, Esq.

Staff
Attorney

Office
of Technology

Division
of Corporation Finance

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

    Re:

    Mag
    Mile Capital, Inc.

    Amendment
    No. 1 to Registration Statement on Form S-1

    Filed
    December 13, 2023

    File
    No. 333-274354

Dear
Mr. Pattan:

Mag
Mile Capital, Inc. (the “Company”) is transmitting this letter in response to comments received from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) by letter dated December 13, 2023, with respect to the registration
statement on Form S-1 (File No. 333-274354) that was submitted to the Commission on September 6, 2023 and amended by Amendment No. 1
filed on December 13, 2023 (the “Registration Statement”). This letter is being submitted together with the filing of the
Company’s Amendment No. 2 to the Registration Statement on Form S-1 (“Amendment No. 2”). The numbered paragraphs below
correspond to the numbered comments in that letter and the Staff’s comments are presented in bold italics.

Form
S-1/A filed December 13, 2023

Prospectus
Summary, page 4

1.
We note your response to our prior comment 3 including your statement that you “service a number of significant customers
that own hotels and that have a license to be branded by one of these companies.” Please qualify this statement by providing a
detailed discussion of your material customer relationships for the periods presented. Your revised disclosure should include whether
you generate material revenue concentration from these customers and whether you have any material agreements with them.

Response:
We have provided in Amendment No. 2 a detailed discussion of our material customer relationships for the periods presented with the franchisees
of the hotel brands mentioned, including the material revenues generated from these customers and that we did not have any material agreements
with the hotel brands.

Austin
Pattan, Esq.

 February
14,  2024

Page
2 of 2

2.
Please provide unaudited interim financial statements for the nine-month periods ended September 30, 2023 and 2022 that reflect the reverse
merger consummated on March 20, 2023 in an amended filing.

Response:
We have provided in Amendment No. 2 our unaudited interim financial statements for the nine-month periods ended September 30, 2023 and
2022 that reflect the reverse merger consummated on March 20, 2023.

3.
Refer to the Index to Consolidated Financial Statements on page F-10. Please delete the reference to “audited” for
the Balance Sheets as of July 31, 2022.

Response:
We have amended our disclosure to delete the reference to “audited” for the Balance Sheets as of July 31, 2023.

If
you have any further comments or questions regarding our response, please contact our legal counsel, Ernest M. Stern, Culhane Meadows
PLLC at (301) 910-2030 and by email at estern@cm.law. If you cannot reach him, please contact the undersigned at rshah@magmilecapital.com.

    Sincerely,

    /s/
    Rushi Shah

    Rushi
    Shah, President and CEO

Cc:
Ernest M. Stern, Esq., Culhane Meadows PLLC

 Encl.