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United States securities and exchange commission logo
February 10, 2023
Oleg Bilinski
Chief Executive Officer
Mag Magna Corp.
325 W Washington St., Ste 2877
San Diego, CA 92103
Re:Mag Magna Corp.
Amendment No. 1 to Registration Statement on Form S-1
Filed January 30, 2023
File No. 333-268561
Dear Oleg Bilinski:
            We have reviewed your amended registration statement 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 registration 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 registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our December 22, 2022 letter.
Amendment No.1 to Form S-1 filed January 30, 2023
Cover Page
1.We note your response to our prior comment 2; however, request that a specific date be
included in relation to the termination of the offering, as required by Item 501(b)(iii) of
Regulation S-K. Please revise your disclosure accordingly.
Prospectus Summary, page 5
2.We note your response to our prior comment 5 and related revisions; however, also note
your continued reference to "ongoing and planned clinical trials for [y]our product
candidates" and your disclosure stating your intention and seek regulatory approval for
your "current product candidates and any future product candidates [you] may develop".

 FirstName LastNameOleg Bilinski
 Comapany NameMag Magna Corp.
 February 10, 2023 Page 2
 FirstName LastNameOleg Bilinski
Mag Magna Corp.
February 10, 2023
Page 2
In light of this disclosure, please revise the prospectus both in the Summary and Business
sections to set out the regulatory regime applicable to your current product(s), clarifying
the steps the company will have to go through to seek approval prior to commercialization
and revenue generation.
3.We note your response to our prior comment 6, including your revised disclosure on page
7 regarding the effects and functioning of MAGA and CHASIS and Exhibits 99.4 and
99.5, which are labeled as "product leaflets". Please disclose who generated the product
leaflets and how the claims contained therein were substantiated. Please also disclose
within the prospectus the basis for the claims made on page 7.
4.We note your response to our prior comment 7. Please expand your disclosure to explain
what the referenced registration process entailed and the significance of such registrations.
Please also discuss any preclinical and/or clinical studies conducted by IPAX to date.
5.We note your response to our prior comment 8; however, it is unclear what "optimizing
existing properties of components" means or entails. Please revise to clarify this
statement.
6.We note your response to our prior comment 10. Please revise your disclosure to include
the substance of your response, namely that the Company aims to workwith companies
engaged in feed additives distribution and poultry cultivation but has not yet engaged in
any material relationships with any companies. Please make clear that the company
currently has no "partners".
Risk Factors, page 15
7.We note your response to our prior comment 13 and we reissue in part. Please further
revise your disclosure to explain the consequences of not complying with the reporting
obligations applicable to the company after the registration statement is declared effective,
including those obligations arising under the Securities Exchange Act of 1934.
Dilution , page 27
8.We note your response to comment 19. Based upon your reported historical net tangible
book value and net offering proceeds of $17,000 at the 25% of shares sold from the
maximum offering available, please reconcile for us how you determined the $(3,629) of
post offering net tangible book value as of October 31, 2022. Please review the
calculations within the other scenarios of your offering sold as applicable.
Management
Executive Officers and Directors, page 34
9.We note your response to our prior comment 23. Please further revise your disclosure to
clarify whether Mr. Bilinski still serves as President and CEO of Mass Petroleum Inc. and
if not, provide the date such positions ended.

 FirstName LastNameOleg Bilinski
 Comapany NameMag Magna Corp.
 February 10, 2023 Page 3
 FirstName LastName
Oleg Bilinski
Mag Magna Corp.
February 10, 2023
Page 3
Item 17. Undertakings, page 62
10.We note the undertakings provided starting on page 62; however, such disclosure does not
appear applicable to this offering. We also note that you have not checked the Rule 415
box on the cover page; however, you appear to be conducting a continuous offering.
Please clarify whether Rule 415 applies and if so, provide the undertakings required by
Rule 415(a)(3). See Rule 415 of the Securities Act of 1933 and Item 512 of Regulation S-
K for guidance.
Statement of Operations, page F-2
11.We noted that you provided interim information for the three months ended October 31,
2022. Please revise your financial statements to also include your statement of operations
for the six months ended October 31, 2022.  This similarly applies to your statement of
changes in stockholders' equity (deficit) presented on page F-4.
Statement of Changes in Stockholders' Equity (Deficit), page F-3
12.Your statement of changes in stockholders' equity (deficit) does not appear
mathematically accurate. Please revise.
Statement of Cash Flows , page F-5
13.Your net income presented here does not agree with your net income on your statement of
operations for the period ended October 31, 2022. This also applies to your statement of
cash flows for the period ended April 30, 2022. Please revise.
            You may contact Tara Harkins at 202-551-3639 or Sasha Parikh at 202-551-3627 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Cindy Polynice at 202-551-8707 or Laura Crotty at 202-551-7614 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Roger D. Linn