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19MAG
MILE CAPITAL, INC.

1141
W. Randolph St.

Suite
200

Chicago,
IL. 60607

 April
26,  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. 3 to Registration Statement on Form S-1

    Filed
    March 8, 2024

    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 March 18, 2024, 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, Amendment No. 2 filed February 14, 2024, and Amendment No. 3 filed on March 8, 2024 (the “Registration
Statement”). This letter is being submitted together with the filing of the Company’s Amendment No. 4 to the Registration
Statement on Form S-1 (“Amendment No. 4”). The numbered paragraphs below correspond to the numbered comments in that letter
and the Staff’s comments are presented in bold italics.

Amendment
No. 4 to Registration Statement on Form S-1

Financial
Statements, page F-1

1.
We note that you had net losses in 2021 and for the nine months ended September 30, 2023. Please tell us whether you expect to report
net income for the year ended December 31, 2023. If so, please explain the basis for your belief in light of the net loss of $2.7 million
for the nine month period ended September 30, 2023. If not, please provide updated audited financial statements for the year ended December
31, 2023, as required pursuant to Rule 8-08(b) of Regulation S-X.

Response:
We had a net loss for the year ended December 31, 2023, and have provided updated audited financial statements for the year ended December
31, 2023.

Austin
Pattan, Esq.

 April
26,  2024

Page
2 of 2

General

2.
You state that the common stock qualifies “only for proprietary broker-dealer quotations on the Expert Market.” Please
add a risk factor disclosing the specific reasons why your stock is being quoted only on the Expert Market, the uncertainties and risks
to shareholders and the impact on the liquidity of the shares being offered for resale. Clarify, if true, that the quotations in the
Expert Market are restricted from public viewing and that only broker-dealers and professional or sophisticated investors are permitted
to view quotations in Expert Market securities.

Response.
Since our common stock is eligible for “Unsolicited Quotes Only” we have added a risk factor to state that such stocks have
a higher risk of wider spreads, increased volatility and price dislocations and that investors may have difficulty selling this stock.

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.