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CORRESP
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NAPLOY CORP.

95 Lias Estate Kafe district Abuja,

FCT 900108 Nigeria

Telephone:
+13072133163

Email: naploy.corp@tutanota.com

December 06, 2023

Michael Fay, Terence O'Brien

Juan Grana and Margaret Schwartz

Division of Corporation Finance

Office of Industrial Applications and Services

U.S. Securities and Exchange Commission

100 F Street, NE,

Washington, DC 20549

  Re:
  NAPLOY CORP.

  Registration Statement on Form S-1

  Filed October 6, 2023

  File No. 333-274889

Dear Michael Fay, Terence O'Brien, Juan Grana and Margaret Schwartz:

In response to your letter dated November 2, 2023 pursuant to the Securities
Exchange Act of 1933, as amended, please find the Company’s Amendment No.1 to the Registration Statement on Form S-1, as filed with
the Securities and Exchange Commission on October 6, 2023

Registration Statement on Form S-1

Cover Page, page iii

1. Please disclose, on the cover page, the national securities exchange
where the securities being offered will be listed or other market(s) where the securities will be quoted. Refer to Item 501(b)(4) of Regulation
S-K.

Response: We have added the following disclosure:

The securities being offered by Naploy Corp. will be listed and traded
on the following national securities exchanges and markets: OTC (Over-the-Counter) Market, Nasdaq Stock Market, QB (OTCQB).

2. Please disclose, on the cover page, any
arrangements to place the proceeds from the offering in an escrow, trust, or similar account. If no arrangements have been made, please
state so and disclose the effect on investors. Refer to Item 501(b)(8) of Regulation S-K.

Response: We have added the following disclosure:

There are no any arrangements to place funds into an escrow, trust,
or similar account; any funds received from the sale of stock will be placed into the Company's bank account and will be immediately available
to us. We intend to use the proceeds raised in this offering for the uses set forth in the proceeds table. The failure of funds used to
effectively grow our business could result in unfavorable returns or no income at all. This could have a significant adverse effect on
our financial condition and could cause the price of our common stock to decline.

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Summary, page 3

3. Please revise to provide further information and context, including
a timeline for development, with regard to the technologies listed on page 3 that you intend to implement in the Naploy app.

Response: We have added the following disclosure:

Phase 1: Improvement of the AI technology (Months 1-6)

The first phase of development focuses on refining our AI-powered Symptom
Diagnostic feature. Within the initial six months, our primary objective is to improve the accuracy and depth of diagnostic capabilities.

Phase 2: Basic Feature Implementation (Months 1-12)

From the 1st month till 12th, we plan to integrate essential features
such as the Map View, Reviews, and Booking Services. These features will provide users with an initial level of functionality, facilitating
their engagement with medical institutions and content within the app.

Phase 3: Advanced Feature Implementation (Months 6-18)

The following six to eighteen months will be dedicated to more advanced
feature implementations. This includes Notifications, Marketing Opportunities, Body Map Symptom Checker, and Language Translation capabilities.
These additions aim to significantly enhance the user experience and app functionality.

Phase 4: Completion and Testing (Months 12-18)

The following twelve to eighteen months, the focus will be on finalizing
the integration of the Personal Health Tracker, Medicine Reminder, and conducting comprehensive testing for the entire app. This phase
ensures the stability, usability, and reliability of all features.

The app will continuously undergo updates and refinements to enhance
user experience, improve accuracy, and maintain the highest performance standards.

4. We note your statement on page 2: "Our Naploy app is your
go-to source for the latest health news and updates. Naploy App offers an article library- News Blog that deals with the most common health
topics." We also note your statement on page 21: "Our “Naploy App” is regularly updated with articles written by
healthcare professionals and industry experts." Please revise to clarify where this content is sourced from, given you state elsewhere
you have no employees. To the extent you license this content please revise to describe such arrangements and file such agreements as
exhibits to your Registration Statement or tell us why you are not required to do so.

Response: We have added the following disclosure:

The content provided on our app is primarily sourced from reputable
open channels, ensuring credibility and accuracy. In addition to open sources, we curate content from trusted platforms such as https://medicalxpress.com/.
It's pertinent to highlight that we do not engage in content licensing agreements as we are utilizing the information from reliable open
sources and ensure that our users receive high-quality, updated, and relevant health information through the Naploy app.

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Risk Factors

Risks Associated With Our Company, page 6

5. Please disclose the material risks associated with failing to
develop content for the Naploy app, partnering with medical institutions and advertisers in Nigeria and elsewhere in Africa, and any potential
disruptions to the Naploy app, such as technological issues and software bugs, as applicable.

Response: We have added the following disclosure:

MATERIAL RISKS ASSOCIATED WITH FAILING TO DEVELOP CONTENT FOR THE NAPLOY
APP, PARTNERING WITH MEDICAL INSTITUTIONS AND ADVERTISERS IN NIGERIA AND ELSEWHERE IN AFRICA

Failing to develop content for the Naploy app could result in a lack
of engaging and informative material for users, leading to decreased app usage and potential loss of interest. Users may turn to other
sources for health information, affecting the app's credibility and popularity.

Challenges in establishing fruitful partnerships with medical institutions
and advertisers across Nigeria and other African regions pose a substantial risk. Difficulties in these collaborations might hinder the
app's ability to form strong alliances within the healthcare industry. Without these partnerships, Naploy could face limitations in accessing
a wider user base, impacting its capacity to offer varied, verified, and valuable medical information. Such limitations could potentially
affect the platform's overall growth and influence its position within the industry.

POTENCIAL DISRUPTIONS TO THE NAPLOY APP, SUCH AS TECNNOLOGICAL ISSUES
AND SOFTWARE BUGS

Technical issues and software bugs are inherent risks in any app development.
Regular updates and maintenance are crucial to address bugs and ensure the app's smooth operation. Moreover, disruptions caused by technological
issues may result in downtime, affecting user experience and trust. In regions with limited access to stable internet connections, the
app's functionality may be compromised, limiting its reach and effectiveness. All this could have a material adverse effect on our financial
condition and results of operations.

Risk Factors

Risks Associated With Our Company, page 8

6. Please advise if there are any Nigerian laws, regulations, administrative
determinations or similar constraints that could impact your operations. If so, please disclose these as has been done for U.S. federal
and state laws and regulations. As an example only, we note that on page 9 you reference laws passed by many states requiring companies
to notify individuals of data security breaches. Given you intend to operate outside of the United States for the foreseeable future,
please revise to discuss any applicable Nigerian or other applicable laws regarding data security and privacy. Please also elaborate further
regarding any other risks particular to operating in Nigeria.

Response: We have added the following disclosure:

WE WILL FALL UNDER THE PURVIEW OF NIGERIAN LAWS, REGULATIONS, AND ADMINISTRATIVE
DECISIONS THAT HAVE THE POTENTIAL TO INFLUENCE OUR OPERATIONS.

Operating in Nigeria exposes our company to specific risks related
to data security and privacy laws. Nigerian regulatory frameworks and any changes to these laws can impact our operations, especially
in handling sensitive health information.

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Data Protection Landscape: Nigeria may have specific data protection
laws that govern the collection, processing, and storage of personal and health-related information. Compliance with these laws is crucial
for protecting user data and maintaining their trust. Any lapses in data security or privacy practices may result in legal consequences
and reputational damage.

Regulatory Changes: The dynamic nature of data protection regulations
introduces uncertainty. Changes in Nigerian data protection laws or the introduction of new regulations may necessitate adjustments to
our data-handling practices, potentially leading to increased compliance costs. Non-compliance with all the Nigerian Laws may result in
penalties.

OTHER RISKS PARTICULAR TO OPERATING IN NIGERIA

Infrastructure and Connectivity Challenges: Nigeria faces challenges
related to infrastructure and internet connectivity. Potential disruptions in service due to these challenges may impact user experience
and app functionality. Cultural Sensitivity: Nigeria has diverse cultural and religious practices. Content and advertising should be mindful
of cultural sensitivities to avoid unintentional offense. Political and Economic Instability: Nigeria has experienced periods of political
and economic instability. These factors can affect the business environment and should be monitored for potential impacts on operations.
Local Partnerships: establishing strong local partnerships is crucial for navigating the business landscape in Nigeria. This includes
collaborations with medical institutions, advertisers, and other stakeholders.

Risk Factors

Risks Associated With This Offering

Our Directors will Continue to Exercise Significant Control over
our Operations..., page 11

7. On page 11, you state that currently 25% of all shares of common
stock of the Company are beneficially owned by all officers and directors as a group. However, in a previous risk factor on page 10, you
state that a total of 2,000,000 shares of common stock have been issued to Mr. Arnold. Likewise, the Beneficial Ownership Table on page
38 of the Registration Statement discloses Mr. Arnold as currently holding 2,000,000 shares of common stock, or 100% of the Company's
common stock. Please reconcile this discrepancy in the disclosure. Please also disclose that as the current sole holder of the Company's
common shares, Mr. Arnold may elect the entire Board of Directors.

Response: We have resolved this discrepancy in the disclosure

Description Of Our Business, page 19

8. On page 19 of the Registration Statement, Symptom Diagnostic
is described as "an advanced tool that uses high-grade AI technology to provide diagnoses" and as a main feature of the Naploy
app. Please advise, and disclose as applicable, whether Symptom Diagnostic and/or the Naploy app will require any regulatory approvals
in the United States, Nigeria or elsewhere.

Response: We have added the following
disclosure:

For Naploy App and Symptom Diagnostic feature do not require regulatory
approval in the United States, Nigeria or elsewhere because they provide information rather than direct medical advice. For the health
app, despite providing useful functionalities, users are strongly encouraged to seek professional medical advice, especially when experiencing
severe symptoms. The app's features are intended for informational purposes only and must not replace the guidance of a medical professional
in cases of severe symptoms or critical health concerns.

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9. Please provide disclosure regarding plans for expansion beyond
Nigeria. Please disclose both the timeframe and geographic scope of the planned expansion.

Response: We have added the following
disclosure:

In addition, within two-three years after the success of the Nigerian
market, we intend to popularize the application to other African countries, starting with neighboring Benin, Chad, Cameroon and Niger.
Furthermore, potential target countries for expansion could encompass regions such as Kenya, South Africa, and Ethiopia. The company intends
to evaluate the market readiness and demand within these countries and strategically expand its services to cater to these regions, ensuring
the compatibility of the online health platform with the local healthcare landscapes and technological infrastructure.

Description Of Our Business

Our Mobile Application And The Process, page 21

10. Please revise the disclosure on pages 21 and 22 of the Registration
Statement to clearly distinguish between existing and future functionality and features of the Naploy app and provide a sense of the scope
of currently available content on the Naploy app. For example, we note you state that your app includes a Clinic Search feature that involves
your "team" interacting with clients and that you have "expert managers," yet you state elsewhere that you have no
employees. Please also disclose here when the Naploy app was created, how many users and advertisers you currently have (we note in the
Risk Factors you state you have not yet attracted any potential customers), and more clearly distinguish between what content and services
are available on the Naploy app and what content is available on the Naploy website.

Response: We have reviewed and revised our disclosures.

Description Of Our Business

Revenues, page 23

11. Under "Referral fees" on page 23 of the
Registration Statement, the disclosure seems to state that, in the future, the Naploy app will be able to earn referral fees from
medical institutions for each new patient that the Naploy app directs to them. Please advise whether there are any material
contracts or letters of intent to which you have entered into with any medical institutions for such referrals and, if so, revise to
describe such agreements and file them as exhibits to your Registration Statement or tell us why you believe you are not required to
do so. Revise to also describe any regulatory implications of receiving referral fees from medical institutions.

Response: We have added the following
disclosure:

As of the current date, Naploy Corp. does not have any material contracts
or letters of intent with medical institutions for referral arrangements. The revenue model relies on potential future collaborations
with medical institutions, and we will ensure that any such agreements comply with regulatory requirements.

It's important to note that, at present, there are no regulatory implications
to address as we have not yet engaged in formal agreements with medical institutions for referral fees. Any future collaborations will
be approached with careful consideration of regulatory compliance to ensure transparency and adherence to applicable standards.

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12. Please explain how the "Prices for Services" and "Prices
for Services in the future" on page 23 of the Registration Statement are derived. If these are estimates and not current prices,
please state more clearly in the disclosure that these are not actual prices being charged.

Response: We have added the following
disclosure:

The "Prices for Services" and "Prices for Services in
the future" are based on estimated ranges derived from market research, industry benchmarks, and an assessment of the value provided
by our services. These figures are not static and may be subject to change based on various factors, including market conditions, service
enhancements, and feedback from clients.

Description Of Our Business

Market Overview, page 24

13. On page 24 of the Registration Statement, the disclosur