SecProbe.io

CORRESP
 1
 filename1.htm

 April
14, 2025

 VIA
EDGAR TRANSMISSION

 Securities
and Exchange Commission

 Division
of Corporation Finance

 Office
of Energy & Transportation

 Re:
 NusaTrip
 Incorporated (the " Company ")

 Registration
 Statement on Form S-1

 Filed
 March 21, 2025
 File
 No. 333-285997

 Dear
SEC Officers,

 As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated April 11, 2025 from the Securities
and Exchange Commission (the "Commission") in which the staff of the Commission (the "Staff") commented on the
above-referenced Registration Statement on Form S-1 (the "Form S-1"). For the Staff's convenience, the Staff's
comments have been stated below in their entirety, with the Company's responses set out immediately underneath those comments.
Please note that all references to page numbers in the responses are references to the page numbers in a revised Form S-1 (the "Amendment"),
filed concurrently with the submission of this letter in response to the Staff's comments.

 Registration
Statement on Form S-1

 Explanatory
Note, page 0

 1.
 Please
 revise to ensure that the language is accurately tailored to the facts of this new filing on Form S-1. In that regard, you currently
 state: "The information included in this Post-Effective Amendment No. 1 amends the Registration Statement and the prospectus
 contained therein. No additional securities are being registered under this Post-Effective Amendment No. 1....".

 Response :
 In response to the Staff's comment, the Company has removed the relevant disclosures under the Explanatory Note on page 0.

 Capitalization,
page 38

 2.
 Please
 revise your table and surrounding disclosure on page 38 to address the following items or explain why no revision is required:

 ●
 The
 Pro Forma cash, short term liabilities and total liabilities including lease obligations balances appear to include an adjustment
 for the $1,600,002 proceeds from the Convertible Notes offering. However, as the Convertible Notes were issued in fiscal year 2024,
 it is unclear why these amounts are not included in the Actual (Audited) balances.

 Response :
 In response to the Staff's comment, the Company has revised the relevant disclosure on pages F-27, Alt-3 and II-2
of the Amendment. The previous disclosure inadvertently indicated "issued" with respect to the Convertible Notes on October
18,2024, however, the Convertible Notes were converted on February 10, 2025.

 ●
 The
 amounts disclosed in footnotes 1 and 2 to the table do not fully support the adjustments to calculate the additional paid in capital
 on a Pro Forma and Pro Forma As Adjusted basis. Revise the amounts or clarify the additional balances included in the adjustments.

 Response :
 In response to the Staff's comment, the Company has revised the relevant disclosure on page 38 of the Amendment.

 Management,
page 80

 3.
 Please
 update the ages of your executive officers and directors. For example, we note that your CEO Tjin Patrick Soetanto has remained 52
 since your first submission in 2023. See Item 401(a) and (b) of Regulation S-K.

 Response :
 In response to the Staff's comment, the Company has amended the relevant disclosures on page 80 of the Amendment.

 Executive
Compensation, page 84

 4.
 We
 note your disclosure of 2024 compensation , as well as the terms of employment agreements disclosed thereunder. However,
 certain executive officer and director compensation differs materially from the terms of their employment agreements. When there
 is any material variance, please disclose the material terms of each named executive officer and director's compensation as
 paid in 2024. See Item 402(o) of Regulation S-K.

 Response :
 In response to the Staff's comment, the Company respectfully submits that the effectiveness of the respective employment agreements
between Tjin Patrick Soetanto, Yee Siong Tan, Albert Nicolas, and Anson Neo and the Company is conditioned upon the effective
date of the Company's registration statement for the initial public offering. As a result, both Tjin Patrick Soetanto's
and Yee Siong Tan's 2024 compensation align with their existing agreements with SOPA and both Albert Nicolas' and
Anson Neo's 2024 compensation align with their existing agreements with PT Tunas Sukses Mandiri, a subsidiary of the Group. Further,
the Company respectfully submits that only Heather Maynard's employment agreement is currently effective. As a result, Ms. Maynard's
2024 compensation aligns with her employment agreement as disclosed in exhibit 10.8 of the Amendment.

 Financial
Statements

 Note
15 - Segment Information, page F-27

 5.
 We
 note your disclosure in Note 15 that management has determined the Company has one reportable segment. We further note the disclosures
 on page 69 which identify your reportable segments as B2B, B2C and Hotel Platform and your disclosures at page F-9 indicating that
 you have five reportable operating segments, (i) Ticketing, (ii) Online advertisement, (iii) Hotel reservation, (iv) Hotel technology
 platform software, and (v) Ancillary that you aggregate into one reportable segment. Please reconcile the inconsistencies between
 these disclosures. In addition, the adoption of ASU 2023-07 includes disclosure requirements for entities that have a single reportable
 segment. Expand your disclosures to address these new requirements as noted in ASC 280-10-50-20. You may also refer to the guidance
 in ASC 280-10-55-15D through 55-15F.

 Response :
 In response to the Staff's comment, the Company has revised the relevant disclosure on pages 69 and F-9 of the Amendment.

 Note
17 - Subsequent Events, page F-27

 6.
 Expand
 your footnote disclosures to address how the issuance of the Convertible Notes Offering on October 18, 2024, as further amended on
 November 13, 2024 were accounted for in your financial statements as of and for the year ended December 31, 2024. We understand the
 notes were subsequently converted after the fiscal year end in February 2025.

 Response :
 In response to the Staff's comment, the Company revised the relevant disclosure on pages F-27, Alt-3 and II-2 of the Amendment.
The previous disclosure inadvertently indicated "issued" with respect to the Convertible Notes on October 18,2024, however,
the Convertible Notes were converted on February 10, 2025.

 Please
do not hesitate to contact Lawrence Venick at (310) 728-5129 or Ted Paraskevas at (917) 974-3190 of Loeb & Loeb LLP with any questions
or comments regarding this letter.

 Sincerely,

 /s/
 Lawrence Venick

 Lawrence
 Venick

 cc:
 Mr. Tjin Patrick Soetanto