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MERCALOT INC.

C/ de l’Illa Formentera, 54, Quatre Carreres,

46026 Valencia, Spain

Telephone:
+13072630861

Email: mercalot.inc@safedealconnect.com

October 10, 2024

To Tanisha Meadows, Suying Li,

Rucha Pandit and Taylor Beech

Division of Corporation Finance

Office of Industrial Applications and Services

U.S. Securities and Exchange Commission

100 F Street, NE,

Washington, DC 20549

  Re:
  Mercalot Inc.

  Registration Statement on Form S-1

  Filed August 27, 2024

  File No. 333-281804

Dear Ta Tanisha Meadows, Suying Li, Rucha Pandit and Taylor Beech:

In response to your letter dated September 23,
2024 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 August 27, 2024.

Registration Statement on Form S-1

Cover Page

 1. Please move the Item 501(b)(10) legend and date of the prospectus from the cover page of the registration
statement to the cover page of the prospectus.

Response:

The Item 501(b)(10) legend and date
of the prospectus have been moved as requested.

 2. We note your disclosure on page 6 that you will seek to have a market maker file an application with FINRA
for your common stock to be eligible for trading on the OTC Market, Nasdaq Stock Market, and OTCQB "[a]fter the effective date
of the registration statement (emphasis added)." We also note your disclosure that you do not currently "have an arrangement
in place for a market maker to file such an application and there is no guarantee that [you] will be able to find one to do so."
Please prominently include these representations on the prospectus cover page.

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Response:

We have added the following disclosure
on the prospectus cover page:

“Also, Mercalot Inc. intends
to seek a market maker to file an application with the Financial Industry Regulatory Authority (FINRA) to have our common stock become
eligible for trading on the OTC Market, Nasdaq Stock Market, and OTCQB after the effective date of the registration statement. However,
we currently do not have an arrangement in place for a market maker to file such an application, and there is no guarantee that we will
be able to find one willing to do so.”

 3. We note your disclosure here that "Mercalot Inc. qualifies as an 'emerging growth company.'"
Please revise your disclosure, for example, in the Prospectus Summary, to provide a summary discussion regarding the implications of being
an EGC (e.g., that you may take advantage of certain reduced reporting requirements that are otherwise applicable to larger public companies
and whether you intend to take advantage of these reduced reporting requirements and exemptions), as well as what conditions would result
in you ceasing to be an EGC. Provide a cross-reference on the prospectus cover page to this discussion.

Response:

We have added the following cross-reference
on the prospectus cover page:

“Mercalot Inc. qualifies as
an “emerging growth company” as defined in the Jumpstart our Business Startups Act (the “JOBS Act”). As such,
we are eligible for certain reduced reporting requirements. Please see 'Prospectus Summary – Emerging Growth Company Status' for
a discussion of these exemptions and the conditions that could cause us to lose this status. As a result, there is a possibility that
the Company may not be successful in having its securities listed and traded on these exchanges. Investors should be aware of this inherent
uncertainty, and the offering is not conditioned on receipt of listing approval.”

We have also added the following section
to the Prospectus Summary:

“Emerging growth company status

Mercalot Inc. qualifies as an "emerging
growth company" as defined under the Jumpstart Our Business Startups Act (the "JOBS Act"). As an "emerging growth
company", we are permitted to take advantage of certain exemptions from various reporting requirements that apply to other public
companies that are not emerging growth companies. These exemptions include, but are not limited to:

 - exemption from the requirement to have our
independent registered public accounting firm attest to the effectiveness of our internal control over financial reporting under Section
404(b) of the Sarbanes-Oxley Act of 2002;

 - reduced disclosure obligations regarding executive
compensation in our periodic reports and proxy statements;

 - exemptions from certain financial disclosure
requirements, including not being required to comply with any new or revised financial accounting standards until those standards would
otherwise apply to private companies.

We will continue to be an "emerging
growth company" until the earliest of:

 - the end of the fiscal year in which our annual
gross revenues exceed $1.235 billion;

 - the date we become a "large accelerated
filer," which means the market value of our common equity that is held by non-affiliates exceeds $700 million as of the last business
day of our most recently completed second fiscal quarter;

 - the date on which we have issued more than
$1 billion in non-convertible debt during the previous three years;

 - the end of the fiscal year following the fifth
anniversary of the date of the first sale of common equity securities under this registration statement.”

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Prospectus Summary

General Information About Our Company, page
4

 4. Please prominently disclose that your auditor has raised substantial doubt as to your ability to continue
as a going concern. In addition, please disclose that your status as a development-stage company means that you have no or limited active
business operations, no revenues, and no significant assets.

Response:

We have added the following disclosure
“General Information About Our Company” section on the page 5:

“Our independent auditor has
expressed substantial doubt regarding our ability to continue as a going concern. We are a development-stage company, and as such, we
currently have limited active business operations, no revenues, and no significant assets. These factors raise concerns about our ability
to fund ongoing operations and achieve profitability in the foreseeable future. If we are unable to raise sufficient capital or generate
revenues, our business may fail.”

Our director will continue to exercise significant
control over our operations…, page 13

 5. We note your disclosure that "[a]fter the completion of this offering, our management will own a
majority of our common stock" and that "[i]t will have a significant influence in determining the outcome of all corporate transactions."
Please revise to disclose management's percentage ownership of your common stock assuming the sale of all shares being registered and
characterize such ownership as a controlling interest. Additionally, please include comparable disclosure on the prospectus cover page.

Response:

We have revised our disclosure in this
risk factor.

We have also included the following
disclosure on the prospectus cover page:

“After the completion of this
offering, management will own approximately 20% of our outstanding common stock, representing a controlling interest. This control gives
management significant influence over corporate decisions, including the election of directors and approval of major transactions, which
could adversely affect the interests of minority shareholders.”

Risk Factors

We are selling this offering without an
underwriter . . ., page 13

 6. Please revise this risk factor to explain that no underwriter has engaged in any due diligence activities
and that an underwriter’s due diligence obligations go to confirming the accuracy of the disclosure in the prospectus as well as
providing input as to the offering price.

Response:

We have revised the risk
factor and included the following information to the title:

“Additionally, no underwriter
has engaged in any due diligence activities, which typically help confirm the accuracy of the disclosure in the prospectus and provide
input on the offering price.”

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And the following disclosure
to the risk factor:

“Since we are not using an
underwriter, no underwriter has conducted any due diligence to verify the information contained in this prospectus. An underwriter typically
performs due diligence to confirm the accuracy and completeness of the prospectus disclosures and provides input into determining the
offering price. Without this input, there may be additional risks to investors regarding the accuracy of the disclosures and the appropriateness
of the offering price.”

Use of Proceeds, page 15

 7. Please revise the Use of Proceeds table to reflect the order of priority of your proceeds and discuss
your plans if substantially less than the maximum proceeds are obtained. Refer to Instruction 1 to Item 504 of Regulation S-K.

Response:

We have revised the Use of Proceeds
table and included the following disclosures:

“We will allocate funds in
the following order of priority:

 1. General and Administrative Costs (to cover costs associated with compliance, accounting, and legal
fees necessary for reporting obligations).

 2. Marketing and Advertising (to promote our platform to increase user acquisition and market awareness).

 3. Mobile Application improvement (enhancements to our app to improve functionality).

 4. General working capital (for operational flexibility and unforeseen expenses).

 5. Equipment and Data Storage servers (to support our platform infrastructure and data storage needs).”

“If we raise less than the
maximum proceeds, our first priority will be to cover General and Administrative Costs necessary to maintain reporting compliance. Additional
funds will be allocated to Marketing and Advertising to drive platform growth, followed by Mobile Application improvement to enhance functionality.
General working capital and Equipment will receive remaining funds based on available proceeds. If substantially less than 50% is raised,
we will focus primarily on regulatory obligations and targeted marketing to drive user growth.”

Dilution, page 16

 8. It appears you have included your intangible asset balance in your net tangible book value. Please revise
to remove the intangible assets from your net tangible book value calculation.

Response:

We have revised the value and updated
the table.

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Description of Our Business, page 21

 9. Please revise to disclose what types of goods and services will be sold on your marketplace.

Response:

We have included the following description:

“Diverse Product and Service
Offerings: our marketplace platform offers a comprehensive range of services and products, organized into the following categories:

•	Services:

 - Design (services in graphic design, logo creation,
and branding, catering to businesses and individuals looking to enhance their visual identity);

 - Development and IT (web and software development,
app development, IT support, and other technology services for clients seeking custom digital solutions);

 - SEO and Traffic (services to improve website
search engine rankings, drive traffic, and optimize digital presence for businesses aiming to enhance online visibility);

 - Social Media and Advertising (social media
management, digital marketing strategies, and online advertising services for brands looking to grow their audience and reach);

 - Audio, Video, and Shooting (professional services
for video production, audio editing, photography, and videography for personal or commercial projects);

 - Texts and Translations (writing, copywriting,
editing, and translation services across multiple languages for diverse content needs);

 - Business and Life (consulting services for
business strategy, personal development, life coaching, and other professional advice tailored to personal and business growth).

•	Products:

 - iTunes & App Store (digital products and
services available for purchase through major app platforms like iTunes and the App Store);

 - Audiobooks (audio versions of books across
genres, catering to listeners seeking educational or recreational content);

 - Databases (collections of data and resources,
including educational materials, industry data, and research tools);

 - Video and Audio Courses, Lessons (digital
courses and lessons covering a wide range of topics, from professional skills to personal hobbies);

 - Web Sites (pre-built websites and templates
for individuals and businesses looking to establish an online presence quickly);

 - Mobile Applications (access to and downloads
of mobile applications for a variety of uses, from productivity to entertainment);

 - Access to Resources (subscriptions or one-time
purchases for exclusive access to digital libraries, educational content, and other resources);

 - Game Accounts and Currency (virtual items
such as game accounts and in-game currency for popular video games, catering to gaming enthusiasts);

 - Gift Certificates and Invitations (digital
gift certificates for various services and personalized invitations for events and special occasions);

 - Forecasts and Social Networks (industry trend
forecasts, market research reports, and tools to grow and manage social media presence);

 - Hosting (web hosting services for individuals
and businesses, enabling them to host websites, applications, and digital content online);

 - Miscellaneous (user-uploaded products such
as secondhand clothes, handmade crafts, and other physical items, creating a versatile marketplace for unique and personalized goods).

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By offering a diverse selection of
goods and services, our platform aims to serve a wide range of consumer preferences, from individual creators and small businesses to
consumers looking for unique products and professional services. This diversity enhances our marketplace’s inclusiveness and caters
to both digital and physical product needs.”

Certain Relationships and Related Transactions,
page 41

 10. We note your disclosure on page F-9 that "[a]s of June 30, 2024, the Company owed $49,230 to the
Company’s directors, Blas Mayor Reyes and Isabel Marin Vargas, for the Company’s working capital purposes." Please revise
to disclose the amount outstanding as of the most recent practicable date. Refer to Item 404(d) and Item 404(a)(5) of Regulation S-K.
We also note your disclosure on page 31 that your business office "was provided by our officer and president Mr. Mayor Reyes for
free use, without any payment." Please revise to include the approximate dollar value of such office space. Refer to Item 404(d)
and Item 404(a)(3) of Regulation S-K.

Response:

We have disclosed the amount outstanding
as of September 30, 2024.

We have also added the following information
on the page 31 (in the section Description of Property. Offices):

“Based on current market rates
for similar office spaces in the Valencia area, the approximate dollar value of this office space is $600 per month or $7,200 per year.”

Notes to the Financial Statements

Note 5. Related Party Transactions, page
F-9

 11. Please disclose the amount at which you valued the services of Blas Mayor Reyes that are included in General
and Administrative Expenses.

Response:

We have included the following disclosure:

“This issuance was in exchange
for the provision of services to the Company. The services provided by Mr. Reyes were valued at $300, which has been recorded under General
and Administrative Expenses for the period ending June 30, 2024.”

General

 12. We note that you intend to be listed and traded on the Nasdaq Stock Market. We also note that this is
a best-efforts, self-underwritten offering. Please supplementally tell us the listing standard you intend to rely upon in listing your
common stock and specifically confirm whether and how you meet each of the quantitative requirements. If you do not meet such quantitative
requirements, please explain how you expect to do s