SecProbe.io

August 30, 2024
Tjin Patrick Soetanto
Chief Executive Officer
NusaTrip Incorporated
28F AIA Central, Jl. Jend. Sudirman No.Kav. 48A
RT.5/RW.4, Karet, Semanggi
Kota Jakarta Selatan
Daerah Khusus Ibukota
Jakarta 12930, Indonesia
Re:NusaTrip Incorporated
Amendment No. 3 to Draft Registration Statement on Form S-1
Submitted August 16, 2024
CIK No. 0002006468
Dear Tjin Patrick Soetanto:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on EDGAR.
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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Amendment No. 3 to Draft Registration Statement on Form S-1
Cover page
You disclose that upon the consummation of this offering, Heather Maynard will control
75,000 Shares of the Company’s Super Voting Preferred Stock, giving her a majority of
the aggregate voting power of the Company’s voting securities upon the consummation of
this offering. We note that such issuance to Ms. Maynard is still a blank to be completed
on page 6. We note that in a similar transaction, the Thoughtful Media Group Inc. Form
S-1 filed August 15, 2024 (333-281589), Ms. Maynard is also disclosed as owner
of 75,000 shares of Super Voting Preferred Stock, giving her approximately 82.4% of the
voting power of Thoughtful Media. Considering that both you and Thoughtful Media 1.

August 30, 2024
Page 2
Group appear to have common stock 100% owned by SOPA, please discuss why SOPA
has given majority voting power to Ms. Maynard. As part of your response, please discuss
any relationships, agreements, affiliations, or any understanding that Ms. Maynard has or
has had with SOPA, its officers and directors and/or its majority owner Dennis Nguyen.
In this regard, it appears that Ms. Maynard and Mr. Nguyen are partners in other business
dealings, such as in 2018, Ms. Maynard appears listed as the registered agent for the
Dennis Nguyen Family Foundation, a California business, and Mr. Nguyen appears listed
as a shareholder of H&D Mediterranean along with Ms. Maynard.
Risk Factors
We may have conflicts of interest with our Controlling Stockholders..., page 30
2.You disclose that your "Controlling Stockholders" will continue to be your Controlling
Stockholders immediately upon the completion of this offering and may have significant
influence in determining the outcome of any corporate actions or other matters that
require stockholder approval, such as mergers, consolidations, change of your name, and
amendments to your articles of incorporation. Your controlling shareholder appears to be
Heather Maynard. From her biographical sketch, she appears to lack business experience
in running or managing a public company or a travel agency or OTA. Please detail the
risk from having majority control in one person, including someone lacking experience in
managing a publicly listed company or travel agency or OTA.
Business, page 55
3.We note various graphical presentations and narrative disclosure attributed to third
parties, such as "Bain analysis," Phocuswright, or World Tourism Organization.  As
previously requested in comment 18 in our January 26, 2024 letter, please ensure that you
disclose the source of and the date of any third party data and make clear the disclosure
that is attributed to third parties. We note also data in a table on page 57 discloses it is
"up-to-date as of August 2022" and that a table on page 60 discloses that "2021-2024"
were "projected." Considering the passage of time, please provide more current
information to describe your industry.
Management, page 74
4.You disclose that Ms. Maynard will spend the majority of her time devoted to your
business upon the effectiveness of this IPO. Considering her role as the Executive
Chairwoman of Thoughtful Media and the majority owner of Thoughtful Media as well as
the CEO of H&D Mediterranean, please disclose how Ms. Maynard will split her time
among such entities.

August 30, 2024
Page 3
            Please contact Joanna Lam at 202-551-3476 or Shannon Buskirk at 202-551-3717 if you
have questions regarding comments on the financial statements and related matters. Please
contact Timothy S. Levenberg at 202-551-3707 or Kevin Dougherty at 202-551-3271 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Ted Paraskevas, Esq., of Loeb & Loeb LLP