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 July 7, 2025

Michael Ssebugwawo Muyingo
Chief Executive Officer
SUN
10 Lily Pond Lane
East Hampton, New York 11937

 Re: SUN
 Registration Statement on Form S-1
 Filed June 9, 2025
 File No. 333-287884
Dear Michael Ssebugwawo Muyingo:

 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 disclose the concentration of ownership of your common stock by
your Chief
 Executive Officer.
Prospectus Summary, page 4

2. We note a graphic on page 4 mentioning "Immersive Virtual Reality
Experience" and
 "Direct Sales" involving Microsoft and Meta. We also note your
disclosure on page 2
 that "although we aim to license or sell these productions to major tech
platforms such
 as Meta, Microsoft, and other prominent tech companies, this has not yet
been
 achieved." Please note that graphic presentations should accurately
represent your
 current business. Accordingly, you should remove those portions of your
graphic that
 depict sales to Microsoft and Meta. For guidance, refer to our
Securities Act Forms
 Compliance and Disclosure Interpretation 101.02.
 July 7, 2025
Page 2

3. You disclose that you secured funds of $37,500 to invest in a film
production
 company, Back to The Present LLC a subsidiary of JSL STUDIOS. Please
expand
 your disclosure regarding the origination of such funds and the nature
and terms of the
 investment agreement.
Risk Factors, page 8

4. Please expand your risk factors section to include a discussion of the
material factors
 that make an investment in the company or offering speculative or risky.
In this
 regard, your risk factors section should address, among other risks, the
risks
 associated with your Chief Executive Officer's concentration of
ownership of your
 common stock, your dependence upon Muy House, LLC, risks related to
intellectual
 property, potential difficulties for shareholders in enforcing judgments
against your
 Chief Executive Officer due to him residing outside of the United States
and your
 status as an emerging growth company. Refer to Item 105(a) of Regulation
S-K.
5. Please tell us whether you plan to register your class of common stock
under the
 Exchange Act. If you do not plan to file an Exchange Act registration
statement, such
 as Form 8-A, before the effective date of your Securities Act
registration statement,
 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, Section 16 of the Exchange Act and the majority of the
tender offer
 regulations. Please make similar revisions to the disclosure under
Available
 Information on page 31.
Plan of Distribution
Procedures and Requirements for Subscription, page 12

6. Please file the subscription agreement as an exhibit to your
registration statement.
 Refer to Item 601(b)(4) of Regulation S-K.
Description of Business, page 14

7. According to the prospectus summary, you are in the process of building
dance and
 theatrical experiences that fuse the performing arts with virtual
reality (VR)
 technology. You also note that you have generated revenue and contracted
partners.
 On page 15, you state that you generate revenue through direct sales and
licensing of
 your VR experiences to tech platforms and content distributors and have
realized
 $17,475 in revenue. However, from your disclosure it does not appear
that you
 have began operations. Revise your disclosure to explain how and when
this revenue
 was generated.
Intellectual Property, page 15

8. We note your disclosure that SUN holds a registered trademark and has
secured the
 rights to various digital assets, and your statement that "these
assets will become
 increasingly valuable, contributing to our competitive edge and market
 position." Please disclose the nature of your material intellectual
property and, to the
 July 7, 2025
Page 3

 extent you rely on agreements that provide you with the rights to use
such trademarks,
 disclose the terms of such agreements. See Item 101(c)(iii)(B) of
Regulation S-
 K. Additionally, please consider whether any agreements to the rights to
use a
 trademark should be filed as an exhibit to the registration statement.
Liquidity and Capital Resource, page 20

9. You stated that the timing to complete the development of the first
operating version
 is estimated to be Q1 of 2026. However, later in the same paragraph you
disclose that
 the anticipated completion date is Q1 2024. Please revise to resolve the
inconsistency
 and clarify the development progress of your platform's architecture as
of the date of
 the filing.
Changes in and Disagreements with Accountants on Accounting and Financial
Disclosure,
page 23

10. Please tell us whether there has been a change in accountant during the
two most
 recent fiscal years or any subsequent period. If there has been a change
in accountant,
 revise to provide all of the disclosures required by Item 304 of
Regulation S-K. If
 there has not been a change in accountant please explain the basis for
providing the
 disclosures in this section and tell us who the "Auditor Entity" is.
Directors, executive officers, promoters and control persons, page 24

11. Please briefly describe Mr. Muyingo's business experience during the
past five years.
 Refer to Item 401(e)(1) of Regulation S-K.
12. We note your disclosure that Karolina Muyingo, Dwight Wittmer and Olga
 Kokoshynska FinLit are members of your audit committee. Please provide
us with a
 legal analysis of the basis upon which you concluded that your audit
committee may
 include individuals that are not members of your board of directors.
Ensure that in
 your analysis you discuss the applicable provisions of your articles of
incorporation
 and the Wyoming Business Corporation Act.
Transactions With Related Persons, Promoters, and Certain Control Persons, page
29

13. Please revise your related party disclosure to include the information
required by
 Item 404(d) of Regulation S-K for each related party transaction during
the relevant
 time period. Specifically, we note that the partnership agreement with
Muy House,
 LLC, filed as exhibit 10.6, identifies the Director and founder of Muy
House, LLC as
 Nicole Muyingo. Given that this party shares the same last name as your
CEO,
 explain the nature of the relation between these individuals and revise
your related
 party disclosure accordingly.
14. Please disclose the amount due to Mr. Muyingo under the loan agreement
as of a
 recent practicable date. In this regard, we note your disclosure on page
F-21 that the
 company returned a portion of this loan in January 2025. Also, file this
agreement as
 an exhibit to your registration statement. Refer to Item
601(b)(10)(ii)(A) of
 Regulation S-K.
 July 7, 2025
Page 4
Report of Independent Registered Public Accounting Firm, page F-2

15. Please explain the reference to the period ended October 31, 2024 in the
going
 concern paragraph of Boladale Lawal's opinion or revise as necessary. We
refer to you
 PCAOB Auditing Standard 2415.
Audited Financial Statements of Sun
Notes to the Financial Statements, page F-8

16. We note you have a note receivable, long-term investments, unearned
revenue, and
 long-term business loans in your financial statements as of October 31,
2024 and/or
 January 31, 2025; however, there is no disclosure explaining what these
line items
 represent. Please tell us the nature of these amounts and revise your
footnotes
 accordingly.
General

17. 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 Chen Chen at 202-551-7351 or Chris Dietz at 202-551-3408
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Mariam Mansaray at 202-551-6356 or Jeff Kauten at 202-551-3447 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Sharon D. Mitchell
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