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July 19, 2023
Roman Zhezhel
President
Alixo-Yolloo Corporation
1065 SW 8th St
Miami, FL 33130
Re:Alixo-Yolloo Corporation
Registration Statement on Form S-1
Filed June 22, 2023
File No. 333-272825
Dear Roman Zhezhel:
            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.
Form S-1 filed June 22, 2023
Summary Financial Information, page 10
1.We note that total stockholder's deficit at February 28, 2023 in the table here does not
agree with total stockholders' equity in the balance sheet.  Please revise.
Risk Factors
Because Our Board of Directors Outside of the United States..., page 13
2.You state that your principal office is in Miami, FL but your principal operations are
located outside of the United States and your directors are not residents of the United
States.  Please disclose the location of your principal operations and the location of your
directors in the prospectus summary and risk factors.

 FirstName LastNameRoman Zhezhel
 Comapany NameAlixo-Yolloo Corporation
 July 19, 2023 Page 2
 FirstName LastName
Roman Zhezhel
Alixo-Yolloo Corporation
July 19, 2023
Page 2
Management's Discussion and Analysis or Plan of Operation
Results of Operations, page 23
3.We note that you generated $2,245 revenue in fiscal year 2022, but $0 revenue in fiscal
year 2023. Please clarify the nature of that revenue and if it is related to your ongoing
business of the Alixo app. or the API rental business.
Description of Business, page 25
4.We note that you refer to yourself as a development stage company on page 27 and that
your business plan includes continuously improving the user experience of your products
and services.  Please address the following:
•Clarify the completeness of the development of Alixo and whether it is still in the
beta or testing stage, or if it is available for full commercialization.
•Clarify whether there is a cost to currently download the Alixo app from Google Play
store or any application distributor.
•Clarify the number of downloads and registered users of your Alixo app.
•Clarify whether your API library currently exists and the size and scope of the APIs
currently available for rent.
•Clarify whether you must have an agreement with popular music streaming services
for your app. to operate, such as licenses for their APIs.
•Clarify how or who maintains, services, updates, or provides support for the Alixo
app or API rental service.
5.Please briefly describe how the Alixo app was developed.  We note, for example, that you
have nearly $35,000 in acquired intangible assets on your balance sheet.  Please clarify if
the Alixo app was developed internally, either by your founders or through a contractor,
or if it was primarily acquired.  If it was acquired, please describe the terms of that
acquisition as appropriate.
6.Please clarify the basis for your belief that the Alixo app “will be widely popular,”
“gaining popularity,” or “the app’s popularity will continue to rise.”  Provide actual user
or revenue information to support such assertions.
Director, Executive Officer, Promoter and Control Person, page 30
7.Please describe the role of your management as to the operations of your company.  Your
sole officer is listed as Roman Zhezhel, but you disclose that your director Rassul
Sadakbayev is responsible for all your operations.  Please clarify the role of Zhezhel in the
development and operation of your business.
8.Please revise your management biographies to clarify whether Mr. Zhezhel has any full-
time employment or business ventures that require a material amount of time outside of
his duties at Alixo-Yolloo.

 FirstName LastNameRoman Zhezhel
 Comapany NameAlixo-Yolloo Corporation
 July 19, 2023 Page 3
 FirstName LastName
Roman Zhezhel
Alixo-Yolloo Corporation
July 19, 2023
Page 3
Certain Relationships and Related Transactions, page 33
9.Please disclose whether Mr. Sadakbayev may demand repayment of his loans to you at
any time.  Also, clarify your disclosure that "Mr. Sadakbayev has no formal commitment,
arrangement, or legal obligation to advance or loan funds to the company."  We note that
you filed a loan agreement made in 2019 between the company and Mr. Sadakbayev.
Clarify whether the loan agreement is non-binding and/or whether the agreement has been
amended.
Plan of Distribution, page 34
10.You state that the offering will continue for one year (365 days) but state elsewhere that
the offering is for 240 days.  Please revise.
General
11.Please supplementally provide us with copies of all written communications, as defined
in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your
behalf, present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communications.
            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 Megan Akst, Senior Staff Accountant, at (202) 551-3407 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments
on the financial statements and related matters.  Please contact Edwin Kim, Staff Attorney, at
(202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Blaze Gries, CPA