SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 2, 2026

Richard Miller
Chief Executive Officer
Tron Inc.
941 W. Morse Blvd. Suite 100
Winter Park, FL 32789

 Re: Tron Inc.
 Amendment No. 3 to Registration Statement on Form S-3
 Filed February 6, 2026
 File No. 333-288986
Dear Richard Miller:

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

 Please respond to this letter by amending your registration 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 registration 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 December 19, 2025
letter.

Amendment No. 3 to Registration Statement on Form S-3
Risk Factors, page 17

1. Please disclose the location of your auditor's headquarters. Disclose
that trading in your
 securities may be prohibited under the Holding Foreign Companies
Accountable Act, as
 amended by the Consolidated Appropriations Act, 2023, and related
regulations if the
 PCAOB determines that it cannot inspect or investigate completely your
auditor for
 a period of two consecutive years, and that as a result an exchange may
determine to
 delist your securities.
In 2023, the PRC government initiated a series of regulatory actions and
statements, page 39

2. We note your disclosure in the risk factor heading that "[i]n the
future, [you] may be
 subject to PRC laws and regulations related to [your] current business
operations." Please
 revise to clarify that the legal and operational risks associated with
operating in the
 PRC also apply to any current or future operations in Hong Kong.
 March 2, 2026
Page 2

We may become subject to a variety of PRC laws and other obligations regarding
M&A Rules,
page 40

3. We note your disclosure here and throughout regarding your belief or
your
 management's understanding that you are not subject to certain PRC laws
and
 regulations. To the extent your disclosure is based on an opinion of
Hong Kong or PRC
 counsel, please identify counsel and file the consent of counsel as an
exhibit to the
 registration statement. If you did not consult counsel, please disclose
that an opinion was
 not obtained.
It may be difficult to enforce a judgment of U.S. courts for civil liabilities,
page 42

4. We note your disclosure in response to prior comment 3 regarding the
difficulty of
 enforcing civil liabilities in Hong Kong and China. Please clarify
whether you have any
 directors or officers located in China. In addition, to the extent your
disclosure is based
 on an opinion of Hong Kong or PRC counsel, please identify counsel and
file the consent
 of counsel as an exhibit to the registration statement. If you did not
consult counsel,
 please disclose that an opinion was not obtained.
 Please contact Irene Paik at 202-551-6553 or Sandra Hunter Berkheimer at
202-551-
3758 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Crypto
Assets
cc: Theodore H. Paraskevas, Esq
</TEXT>
</DOCUMENT>