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 May 22, 2025

Juan Gabriel Diaz
Chief Executive Officer
Software Effective Solutions, Corp.
6500 River Place Boulevard
Building 7, Suite 250
Austin, Nevada 78730

 Re: Software Effective Solutions, Corp.
 Amendment No. 2 to Offering Statement on Form 1-A
 Filed May 19, 2025
 File No. 024-12591
Dear Juan Gabriel Diaz:

 We have reviewed your amended offering statement and have the following
comments.

 Please respond to this letter by amending your offering statement and
providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we
note
otherwise, any references to prior comments are to comments in our May 8, 2025
letter.

Amendment No. 2 to Offering Statement on Form 1-A
General

1. Regulation A requires that you use the upper end of your price range to
disclose the
 aggregate offering amount of this offering. Refer to Rule 253(b)(2) of
Regulation A
 (but note that the midpoint is used in Part I, Item 4 of Form 1-A).
Please revise
 throughout your offering statement to ensure that you are consistent
with your
 disclosure of the maximum offering amount. In particular, please revise
the tabular
 disclosure on the cover page to clearly disclose the maximum primary and
resale
 offering amounts as opposed to using a range. When fixing the maximum
volume,
 please use the upper end of your price range in each instance.
Additionally, please
 revise the table to include a separate additional line that discloses
the total aggregate
 May 22, 2025
Page 2

 offering amount, which should include both the primary and resale maximum
 amounts.
2. We note your response to prior comment 2, as well as your revised
disclosure that
 contemplates a volume range between 14,646,667 and 47,500,000 resale
securities.
 We reissue the comment in part. Please revise throughout the offering
statement,
 including the cover page, to fix the resale volume at the maximum number
of
 securities that the selling securityholders may offer, which appears to
be 47,500,000
 according to your disclosure. Refer to Rule 253(b)(4). Additionally,
revise to
 reconcile with your cover page disclosure, which states that you are
offering up to
 47,000,000 Shares of Common Stock Offered by Selling Shareholders.
Last,
 consider explaining by footnote how you are calculating the maximum
volume of
 securities and whether you are accounting for the interest on the Subject
Convertible
 Notes.
3. We note your disclosure on page 15 that [t]o the extent the Subject
Convertible
 Notes are not converted into Conversion Shares, all unissued Conversion
Shares
 would be available for sale by us hereunder, as well as your
disclosure on page 12
 that, [s]hould we become obligated to issue a significant number of
Conversion
 Shares, our inability to offer and sell such issued Offered Shares for
cash could have a
 negative effect on our business and operating results. Please remove
these
 statements or tell us why the shares underlying the Subject Convertible
Notes would
 be available for offer and sale by you.
4. Clarify whether and how the company and Jose Gabriel D az will
determine, and
 investors will know, if shares are being acquired from the company or the
Selling
 Shareholders.
5. Your disclosure indicates the minimum purchase requirement solely applies
to the
 Company Offered Shares. Please provide your analysis as to whether such
condition
 impermissibly delays the offering of the Company Offered Shares, or
revise to clarify
 that the minimum purchase requirements applies to all shares in the
offering. Refer to
 Rule 251(d)(3)(i)(F) of Regulation A.
 Please contact Alexandra Barone at 202-551-8816 or Matthew Derby at
202-551-
3334 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Eric Newlan, Esq.
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