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May 23, 2023
Kos Ramirez Maximiliano
Chief Executive Officer
MARKY CORP.
San Sebastian 309, Martinica León,
Guanajuato, Mexico
Re:MARKY CORP.
Amendment No. 1 to Registration Statement on Form S-1
Filed April 25, 2023
File No. 333-271350
Dear Kos Ramirez Maximiliano:
            We have reviewed your 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.
Amendment No. 1 to the Registration Statement on Form S-1
Prospectus Summary
Overview, page 7
1.You state that you "provide" subscription-based information services.  We note, however,
that you do not appear to have generated any revenue from your platform and information
on your platform has not been updated since October 2022.  We also note your statement
in the risk factor on page 9 that "any profitability in the future from our business will be
dependent upon the successful development and implementation of our proposed
income/expense product and its successful marketing and sale."  Please clarify the current
stage of development of your business.  Disclose what steps need to be taken for you to
begin generating revenue and when you expect those steps to be completed.

 FirstName LastNameKos Ramirez Maximiliano
 Comapany NameMARKY CORP.
 May 23, 2023 Page 2
 FirstName LastNameKos Ramirez Maximiliano
MARKY CORP.
May 23, 2023
Page 2
Risk Factors, page 9
2.Please include a risk factor highlighting that there is no developed trading market for your
shares and that you may never develop a liquid trading market.
We are an emerging growth company under the JOBS Act..., page 10
3.Please update this section to reflect that the current revenue threshold for an emerging
growth company is $1.235 billion. Make similar revisions to the disclosure on page 19.
Refer to the definition of Emerging Growth Company in Rule 405 under the Securities
Act.
Use of Proceeds, page 21
4.You state that more information regarding use of proceeds from this offering is included
on page 38. However, there is no additional use of proceeds information there. Please
remove this cross reference.
5.We note that Kos Ramirez Maximiliano loaned the Company $70,000. Please tell us
whether you intend to use a portion of the net proceeds from the offering to repay those
loans.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
31
6.You state that you currently generate revenue from advertising on your information
platform. However, you later state that you have generated no revenue to date. Please
revise or advise.
Index to Audited Financial Statements, page 41
7.You disclose a footnote on pages F-2 through F-5 stating that “The accompanying notes
are an integral part of these condensed unaudited financial statements.” However, these
financial statements appeared to have been audited by your auditor. Please remove or
advise.
Note 3 - Summary of Significant Accounting Policies
Revenue Recognition, page F-6
8.Please revise your revenue recognition policy disclosure to indicate that you will be
applying ASC 606 and not ASC 605.  We refer you to ASC 606-10-S65-1.
Note 7 - Subsequent Events, page F-6
9.Please revise to disclose the date through which you evaluated subsequent events. Refer to
ASC 855-10-50-1(a).
General

 FirstName LastNameKos Ramirez Maximiliano
 Comapany NameMARKY CORP.
 May 23, 2023 Page 3
 FirstName LastName
Kos Ramirez Maximiliano
MARKY CORP.
May 23, 2023
Page 3
10.We note your statement that you believe you are not a shell company. However, we note
that you have had minimal operations to date, and the financial statements reflect assets of
cash and cash equivalents. Please disclose on the cover page and in the description of
business section that you are a shell company and add a risk factor that highlights the
consequences of your shell company status. Discuss the prohibition on the use of Form S-
8 by shell companies, enhanced reporting requirements imposed on shell companies
and the conditions that must be satisfied before restricted and control securities may be
resold in reliance on Rule 144.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Amanda Kim, Senior Staff Accountant, at (202) 551-3241 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters.  Please contact Austin Pattan, Staff
Attorney, at (202) 551-6756 or Matthew Crispino, Staff Attorney, at (202) 551-3456 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology