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April 12, 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. 3 to Registration Statement on Form S-1
Filed April 5, 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 March 6, 2023 letter.
Amendment No. 3 to Registration Statement on Form S-1 filed April 5, 2023
Prospectus Summary, page 5
1.Please revise the Prospectus Summary to provide a balanced presentation of your business
to date, clearly stating that you have generated no revenues and quantifying your
accumulated deficit. Please also clarify that no clinical trials have been conducted within
the U.S. and that none of the claims made regarding the components have been reviewed
by U.S. regulatory authorities.
2.We note your response to our prior comment 1 and reissue in part. We note you have
revised your registration statement to state the following: "As long as our company does
not produce CHASIS and MAGA components, Mag Magna Corp. is not subject to FDA
regulations. However, in the event that if we were to implement CHASIS and MAGA

 FirstName LastNameOleg Bilinski
 Comapany NameMag Magna Corp.
 April 12, 2023 Page 2
 FirstName LastNameOleg Bilinski
Mag Magna Corp.
April 12, 2023
Page 2
formulas and their direct sale that falls under the FDA's purview, the Company undertakes
to obtain all permits and comply with FDA regulations prior to commencing production."
Please revise your disclosure to clearly explain when the company would be required to
seek and obtain FDA approval, as it is not apparent from the prospectus. Please also
clearly state whether or not Ipax LLC has obtained FDA approval for the use of MAGA
and CHASIS in feed products. If neither the company nor Ipax LLC has obtained FDA
approval, please explain what activities the company may conduct at this time without
such approval. If the company may not distribute, market and sell products containing
MAGA and CHASIS in the U.S. at this time and without further regulatory approvals,
please clearly state this in the Summary, MD&A and Business sections. Please also
clearly state other jurisdictions where the company is authorized to distribute, market and
sell products at this time, if any.
3.We note your response to our previous comment 2 and reissue in part. Please revise your
disclosure in the Prospectus Summary to include an overview of the data used to support
the claims made regarding MAGA and CHASIS.  Please also explain the relevance of the
Ukrainian review and certificates to the company's operations in the U.S. and elsewhere,
as applicable. If the company is conducting operations in Ukraine, please so state.
Alternatively, please explain why Ukrainian certificates and authorizations were sought if
no operations are being conducted in Ukraine.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Overview, page 29
4.We note your response to our prior comment 3 and the newly added disclosure on page
29. Please revise this disclosure to clarify to what State you refer when you say that your
application passed "a State patent examination" and where the Department of Bird
Diseases, Bees and Physicochemical Research of the Republican Unitary Enterprise
“Institute of Experimental Veterinary Medicine named after S.N. Vyshelessky” is
located.  Please also clarify in this discussion that the clinical trial was not supervised by
the U.S. FDA and that the FDA has not passed on the safety or efficacy of MAGA or
CHASIS.  Please also explain, both here and throughout the document, how this data
allows you to distribute, market and sell MAGA and CHASIS in the U.S. or elsewhere.
Business, page 30
5.Please revise the Business section to include the data obtained in your clinical trial,
detailed in Exhibit 99.8, to support the claims made regarding MAGA and CHASIS.

 FirstName LastNameOleg Bilinski
 Comapany NameMag Magna Corp.
 April 12, 2023 Page 3
 FirstName LastName
Oleg Bilinski
Mag Magna Corp.
April 12, 2023
Page 3
            You may contact Tara Harkins at 202-551-8707 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