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United States securities and exchange commission logo
February 13, 2024
Gyuheyn Jeon
Chief Executive Officer
Reelcause Inc.
4760 S. Pecos Road, Suite 103
Las Vegas, NV 89121
Re:Reelcause Inc.
Registration Statement on Form 10-12G
Filed January 18, 2024
File No. 000-56627
Dear Gyuheyn Jeon:
            We have reviewed your filing and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to this letter,
we may have additional comments.
Registration Statement on Form 10-12G
Risk Factors , page 7
1.We note your disclosure that members of management are not required to commit full
time to the company and that they are currently engaged in other business endeavors.
Please revise to state how many other companies your officers and directors are involved
with and whether any of these business endeavors also involve shell companies. In
addition, please revise the descriptions of business experience of directors and officers in
Item 5 to describe any current business endeavors. We note that here is no other business
experience described for any of your directors or officers since the date their service to the
company began in 2018, 2017 or 2022 for Mr. Jeon, Mr. Song or Mr. Lee, respectively.
Executive Compensation, page 21
2.We note that your executive officers and directors did not receive any compensation for
the years 2021 or 2022. Please update your compensation disclosure to reflect the fiscal
year ended December 31, 2023.

 FirstName LastNameGyuheyn  Jeon
 Comapany NameReelcause Inc.
 February 13, 2024 Page 2
 FirstName LastNameGyuheyn  Jeon
Reelcause Inc.
February 13, 2024
Page 2
Item 7. Certain Relationships and Related Transactions, page 22
3.We note additional information regarding related party transactions in Note 4 to your
audited and interim financial statements. Please include similar information in your
disclosure in this section.
The Company's executive officers are in a position to influence certain actions requiring
shareholder vote, page 25
4.Please reconcile disclosure in this risk factor stating that shares of preferred stock have
super-voting provisions with disclosure under "Preferred Stock" on page 24 which
indicates that Series A Preferred has one vote. Please also clarify the current percentage of
all outstanding shares that your executive officers own and their voting power as a
percentage of all outstanding shares.
Exhibits
5.Please file a complete copy of your articles of incorporation and all amendments as an
exhibit to the registration statement. The document that has been filed is for TradeOn Inc.
and appears to be missing a number of provisions.
General
6.Please note that the registration statement will become effective by operation of law 60
days after your filing date of January 18, 2024. If you are unable to address our comments
within this 60-day period, you should consider withdrawing your Form 10 prior to
effectiveness and re-filing a new Form 10 that includes changes responsive to our
comments. Once the registration statement becomes effective, you are responsible for
filing quarterly and other reports required by Section 13 of the Securities Exchange Act of
1934. We also may continue to comment on your registration statement after the effective
date.
7.Please provide a discussion of any other blank check or shell companies in which any
member of your management may have been involved. The discussion should include the
name of each company, the date of the initial public offering or registration, offering
price, aggregate dollar amount raised, purpose of the offering, any business combinations
that have occurred, dates of such transactions, consideration given and received and
management’s subsequent involvement in the company.
8.We note that the website rcitgroup.net includes a page that indicates the company is
located in Korea. With a view toward disclosure, please tell us whether you or your
officers or directors are controlled by, or have substantial ties with a non-U.S. person.
Please include risk factor disclosure that addresses how this fact could impact your
ability to complete an acquisition. For instance, discuss the risk to investors that you may
not be able to complete an acquisition with a U.S. target company should the transaction
be subject to review by a U.S. government entity, such as the Committee on

 FirstName LastNameGyuheyn  Jeon
 Comapany NameReelcause Inc.
 February 13, 2024 Page 3
 FirstName LastName
Gyuheyn  Jeon
Reelcause Inc.
February 13, 2024
Page 3
Foreign Investment in the United States (CFIUS), or ultimately prohibited. Disclose that
as a result, the pool of potential targets with which you could complete an acquisition may
be limited.

9.We note that your common stock OTC Pink Market under the symbol “RCIT." We also
note that the OTC Market page for RCIT links to a website www.rcitgroup.net.
This website appears to be for an energy company named ReelCause R&D for which
Wooduck Lee serves as CEO. Please tell us whether you are affiliated with this company
and if so, whether ReelCause R&D is still operational. To the extent that you have control
over this website, please revise the website and your registration statement to correct this
discrepancy, and revise disclosure in the Explanatory Note stating that you do not
maintain a website.
            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.
            Please contact Ameen Hamady at 202-551-3891 or Isaac Esquivel at 202-551-3395 if you
have questions regarding comments on the financial statements and related matters. Please
contact Catherine De Lorenzo at 202-551-3772 or Pam Long at 202-551-3765 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       William B. Barnett, Esq.