SecProbe.io

CORRESP
 1
 filename1.htm

 February
6, 2026

 Via
Edgar Transmission

 Ms.
Irene Paik / Ms. Sandra Hunter Berkheimer

 Securities
and Exchange Commission

 Division
of Corporation Finance

 Office
of Crypto Assets

 Washington,
D.C. 20549

 Re:
 Tron
 Inc. (the " Company ")

 Amendment
 No. 2 to Registration Statement on Form S-3

 Filed
 October 17, 2025

 File
 No. 333-288986

 Dear
Ms. Paik / Ms. Berkheimer,

 We
hereby provide a response to the comments issued in a letter dated December 19, 2025 (the "Staff's Letter") regarding
the Company's Registration Statement on Form S-3 (the "Registration Statement"). Contemporaneously, we are filing the
revised Registration Statement via Edgar (the "Amended S-3").

 In
order to facilitate the review by the Commission's staff (the "Staff") of the Amended S-3, we have responded to the
comments set forth in the Staff's Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff's
comments and correspond to the numbered paragraph in the Staff's Letter.

 Amendment
No. 2 to Registration Statement on Form S-3

 General

 1.
 We
 note your response to prior comment 1 that Mr. Justin Sun does not hold any officer position for the Company or any subsidiary thereof,
 is not in charge of any business unit, and does not perform any policy making functions. Please provide such disclosure in your prospectus
 where appropriate.

 Response:
In response to the Staff's comment, the Company has revised the disclosure on page 6 of the Amended S-3.

 2.
 We
 note your disclosure that SRM Ltd. is a limited company incorporated in the Hong Kong Special Administrative Region of the People's
 Republic of China and was formerly owned by Safety Shot, Inc. Please clarify whether you continue to have a subsidiary in Hong Kong
 and, if so, the operations conducted through that subsidiary. In addition, it appears your TRX treasury operations may be conducted
 in Hong Kong. To the extent you have operations in Hong Kong, please revise your filing, as applicable, to provide more specific
 and prominent disclosures about the legal and operational risks associated with China-based companies. For additional guidance, please
 see the Division of Corporation Finance's Sample Letter to China-Based Companies issued by the Staff in December 2021.

 Response: In
response to the Staff's comment, the Company has revised the disclosure on the cover page and on pages 11-12 and 39-42 of the
Amended S-3.

 3.
 We
 note your disclosure that the Company retains sole control of the wallet and private keys in Hong Kong and that Mr. Weike Sun and
 Mr. Zi Yang are authorized by the Board to make the arrangement for safeguarding and operating the private keys of the wallet. Please
 clarify whether Mr. Weike Sun and Mr. Zi Yang are located in Hong Kong. To the extent one or more of your officers and/or directors
 are located in China or Hong Kong, please provide a discussion of the enforcement risks related to civil liabilities due to your
 officers and/or directors being located in China or Hong Kong. Please identify each officer and/or director located in China or Hong
 Kong and disclose that it will be more difficult to enforce liabilities and enforce judgments on those individuals. For example,
 revise to discuss the limitations on investors being able to effect service of process and enforce civil liabilities in China, lack
 of reciprocity and treaties, and cost and time constraints.

 Response:
 In response to the Staff's comment, the Company has revised the disclosure on pages 39-42 of the Amended S-3.

 Prospectus
Summary

 Our
Business, page 3

 4.
 We
 note your disclosure on page 13 and 27 that after the August Warrant Exercise, Bravemorning
 held approximately 86.6% of the Company's outstanding Common Stock, and also Preferred
 Stock Shares which vote together with the Common Stock and increased Bravemorning's
 aggregate voting power to 92.5%. Please include disclosure about Bravemorning's aggregate
 voting power here and elsewhere that you discuss Bravemorning's ownership percentage
 of the Company's outstanding Common Stock.

 Response:
 In response to the Staff's comment, the Company has revised the disclosure on the cover page and on pages 3, 9 and 29 of
 the Amended S-3.

 Recent
Developments, page 7

 5.
 We
 note your disclosure that the Company entered into the Sun Advisory Agreement with Mr. Justin
 Sun on June 16, 2025 along with the issuance of the Preferred Stock Shares and the June PIPE
 Warrants. Please expand your disclosure to clarify the consideration that Mr. Justin Sun
 received or will receive in exchange for his services.

 Response:
 In response to the Staff's comment, the Company has revised the disclosure on the cover page and on page 8 of the Amended
 S-3.

 Risk
Factors

 Risks
Related to Our TRX Token Strategy and Holdings, page 28

 6.
 Please
 revise to include risk factor disclosure addressing the risk that due to Justin Sun's role as the founder of TRON and his continued
 association with the TRON blockchain system, his actions and statements have in the past and may in the future impact the price of
 TRX, which could in turn impact the company and the effectiveness of its treasury strategy.

 Response:
 In response to the Staff's comment, the Company has revised the disclosure on the cover page and on page 34 of the Amended
S-3.

 7.
 To
 the extent that you have an agreement with JustLend DAO, please revise to disclose the material terms of the agreement, including
 term and termination provisions. In addition, and to the extent material, please file it as an exhibit to the registration statement.

 Response :
The Company confirms with the Staff that there exists no separate agreement between it and JustLend DAO.

 *
* *

 Please
reach Ted Paraskevas, the Company's outside counsel at +1 212-407-4971 if you would like additional information with respect to
any of the foregoing. Thank you.

 Sincerely,

 /s/
 Richard Miller

 Richard
 Miller

 Chief
 Executive Officer