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 August 4, 2025

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

 Re: SUN
 Amendment No. 1 to Registration Statement on Form S-1
 Filed July 21, 2025
 File No. 333-287884
Dear Michael Ssebugwawo Muyingo:

 We have reviewed your amended 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. Unless
we note
otherwise, any references to prior comments are to comments in our July 7, 2025
letter.

Amendment No. 1 to Registration Statement on Form S-1
Description of Business
Business Model, page 16

1. We note your response to prior comment 7. Please revise your disclosure
to
 discuss the nature of your revenues earned as of the most recent interim
period
 presented rather than as of October 31, 2024.
Management's Discussion and Analysis and Plan of Operations
Results of Operations, page 20

2. Revise to also provide a discussion of the results of operations for the
six-month
 interim period ended April 30, 2025 compared to the six-month interim
period ended
 April 30, 2024. Refer to Item 303(c) of Regulation S-K.
 August 4, 2025
Page 2

Liquidity and Capital Resource, page 21

3. We note the changes you made in response to prior comment 9. However,
you did not
 remove the references to Q1 2024 as the anticipated completion date as
well as the
 period in which material net cash inflows are expected to commence.
Please revise.
Financial Statements of SUN
Balance Sheet, page F-4

4. Please revise to separately present any amounts related to MUY HOUSE or
any other
 related parties on the face of the balance sheet, statement of
comprehensive income,
 or statement of cash flows. Similar concerns apply to your interim
financial
 statements. Refer to Rule 4-08(k) of Regulation S-X.
Condensed Unaudited Financial Statements, page F-14

5. Please provide interim financial statements between the latest audited
balance sheet
 (i.e., October 31, 2024) and the date of the most recent interim balance
sheet being
 filed (i.e., April 30, 2025). Please remove the interim financial
statements for the
 three-month periods ended January 31, 2025 and April 30, 2025,
respectively. Refer
 to Rule 3-02(b) of Regulation S-X.
Exhibits

6. Please provide a currently dated consent from your independent
registered public
 accounting firm.
 Please contact Chen Chen at 202-551-7351 or Christine Dietz at
202-551-3408 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jeff Kauten at 202-551-3447 or Matthew Derby at 202-551-3334 with any
other
questions.

 Sincerely,

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