SecProbe.io

May 27, 2025
Edgar Ulises Rodriguez Velazquez
President
Dankon Corporation
66 W. Flagler Street, Suite 900
Miami, FL 33130
Re:Dankon Corporation
Registration Statement on Form S-1
Filed on April 30, 2025
File No. 333-286856
Dear Edgar Ulises Rodriguez Velazquez:
            We have reviewed your registration statement and have the following comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form S-1
Cover Page
1.Please check the box to indicate that you are an emerging growth company.
2.Please disclose that your Chief Executive Officer, Edgar Ulises Rodriguez Velazquez,
controls 100% of the voting power of the company.
On the cover page you indicate that you are not a “shell Company” within the
meaning of Rule 405 because you have more than nominal operations. However, you
appear to be a shell company as defined in Rule 405, because you appear to have no
or nominal operations and no or nominal assets. As such, you should disclose that you
are a shell company on your prospectus cover page and add a risk factor that
highlights the consequences of shell company status. Discuss the prohibition on the
use of Form S-8 by shell companies, enhanced reporting requirements imposed on
shell companies, and the conditions that must be satisfied before restricted and control
securities may be resold in reliance on Rule 144. Also, describe the potential impact 3.

May 27, 2025
Page 2
on your ability to attract additional capital through subsequent unregistered offerings.
Alternatively, explain to us why you believe that your business operations are more
than nominal.
The Offering, page 7
4.You indicate that you plan to engage a market maker to file an application with
FINRA for your common stock to trade on the OTC Bulletin Board (OTCBB). Please
remove all references to the OTCBB as FINRA ceased operation of the OTCBB on
November 8, 2021. See FINRA Regulatory Notice 21-38.
Risk Factors, page 8
5.Please confirm to us that you intend to file a Form 8-A to register your common stock
under the Exchange Act. If not, include a risk factor alerting investors that because
your common stock will not be registered under the Exchange Act, you will not be a
fully reporting company but only subject to the reporting obligations imposed by
Section 15(d) of the Exchange Act. The risk factor should explain the effect on
investors of the automatic reporting suspension under Section 15(d) of the Exchange
Act, as well as the inapplicability of the proxy rules and Section 16 of the Exchange
Act. Please make similar revisions to the disclosure under “Where You Can Find
More Information” on page 34.
6.We note that your sole officer and director appears to reside outside the United States.
Please include a risk factor addressing the risk to U.S. stockholders of effecting
service of process, enforcing judgments, and bringing original actions in foreign
courts to enforce liabilities based on the U.S. federal securities laws.
Because our sole officer and director, Edgar Ulises Rodriguez Velazquez, has other
interests..., page 8
7.Your disclosure in the heading of this risk factor that Mr. Rodriguez has other
interests is inconsistent with your disclosure elsewhere in the prospectus that Mr.
Rodriguez's only occupation at the moment is managing the business processes of
Dankon Corporation.
Our business is highly dependent on the reliability and functionality of our proprietary
technology..., page 11
8.Please clarify whether your technology utilizes intellectual property from a third-party
and, if so, provide risk factor disclosure addressing potential IP risks associated with
utilizing third-party IP within your platform.
Management's Discussion and Analysis or Plan of Operation, page 18
9.Please expand your disclosure in this section to include a discussion about the
company’s anticipated sources of revenue and how it expects to generate such
revenue.

May 27, 2025
Page 3
Description of Business
Company Overview, page 22
10.Please ensure that your prospectus accurately reflects the current status of any
products or services that you offer or plan to offer and carefully distinguishes actual
accomplishments from your plans. For example, please revise this section to clarify
the status of your platform. In this regard, we note the statement that your "cutting-
edge technology empowers both consumers and enterprise clients to streamline their
content creation processes, saving time, improving efficiency, and enhancing overall
campaign performance.” To the extent any products or services you hope to provide
are not fully developed, revise to describe the status of your developmental efforts,
any potential difficulties that may preclude you from completing development and the
expected costs of development.
Certain Relationships and Related Activities, page 29
11.Please disclose the interest rate of the loan from Mr. Rodriguez. Refer to Item 404(d)
of Regulation S-K.
General
12.Please supplementally provide us with copies of all written communications, as
defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so
on your behalf, present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not they retain copies of the communications.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Amanda Kim at 202-551-3241 or Stephen Krikorian at 202-551-3488
if you have questions regarding comments on the financial statements and related
matters. Please contact Uwem Bassey at 202-551-3433 or Jeff Kauten at 202-551-3447 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Devin W. Bone