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 July 23, 2025

Gvantsa Chumburidze
Principal Executive Officer
Somitos Corp.
34 Pekini Ave
Tbilisi, Georgia 0160

 Re: Somitos Corp.
 Registration Statement on Form S-1
 Filed June 30, 2025
 File No. 333-288418
Dear Gvantsa Chumburidze:

 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 filed June 30, 2025
Preliminary Prospectus, page 1

1. We note the following disclosure: "After the completion of this
offering, management
 will own approximately 20% of our outstanding common stock, representing
a
 controlling interest." We also note similar disclosure on page 11. On
page 12,
 however, you state that, "[a]fter the completion of this offering,
assuming the sale of
 all shares being registered, our management will own approximately 33.3%
of our
 outstanding common stock, which represents a controlling interest."
Please revise for
 consistency.
Market Information, page 18

2. Include a risk factor informing investors that, as a company with a
reporting
 obligation under Section 15(d) of the Exchange Act, you will not be
subject to the
 proxy rules under Section 14 of the Exchange Act, the prohibition of
short-swing
 July 23, 2025
Page 2

 profits under Section 16 of the Exchange Act, the beneficial ownership
requirements
 of Sections 13(d) and (g) of the Exchange Act, and certain tender offer
rules. Also
 provide risk factor disclosure, if appropriate, that discusses the
possibility that your
 periodic reporting obligations will be suspended under Section 15(d) if
you have less
 than 300 holders of record in the fiscal year after the year of
effectiveness of the
 registration statement.
Description of Our Business
Government and Industry Regulation, page 29

3. We note your disclosure that you "hold the view that government
regulation will not
 significantly affect our business operations." Please revise to provide
the basis for
 your view, or advise.
Directors, Executive Officers, Promoters and Control Persons
Background Information About Our Officers and Directors, page 38

4. Please revise to disclose the business experience during the past five
years of Gvantsa
 Chumburidze, including her principal occupations and employment and the
name and
 principal business of any corporation or other organization in which
such occupations
 and employment were carried on. In this regard, we note your disclosure
throughout
 the registration statement that Chumburidze "has actively participated
in investment
 opportunities across various sectors," that, "[p]rior to joining the
Company as a
 Director, she gained valuable experience as a self-employed entrepreneur
and part-
 time worker in various business and technology-related roles," and that
she "currently
 devotes approximately thirty hours per week to manage [y]our affairs."
Refer to Item
 401 of Regulation S-K.
Executive Compensation
Summary Compensation Table, page 39

5. We note your disclosure indicating that Gvantsa Chumburidze's salary for
2025 is
 $3,000 and she was awarded 300 stock awards. However, your disclosure
elsewhere
 states that you have not paid any compensation to your officers and
directors, and
 "[s]he has agreed to work with no remuneration until such time as we
generate profits
 from operations." Please revise to clarify the discrepancies, or advise.
General

6. You disclose in various sections of your prospectus that your
educational application
 is "already working and available as a web application." However, we
note your risk
 factor disclosure that you have not yet commenced offering online
marketplace
 services through your application. Please revise throughout to clearly
present the
 current status of operations and the availability of your educational
application.
7. Please file as an exhibit a specimen stock certificate to the extent it
defines the rights
 of holders of the shares being registered. Refer to Item 601(b)(4) of
Regulation S-K.
8. It appears that you may be a shell company as defined in Rule 405 under
the
 Securities Act. We note that, among other things, you have nominal
operations
 and assets consisting of cash and cash equivalents and nominal other
assets, and no
 July 23, 2025
Page 3

 revenues as of May 31, 2025, and it appears that you do not have any
current
 operations. Provide us with a detailed legal analysis explaining why you
are not a
 shell company or otherwise disclose on the cover page and in the
description of
 business section that you are a shell company, and add a risk factor
that highlights the
 consequences of your 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 limitations on the ability of your security holders
to resell their
 securities in reliance on Rule 144.
 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 Eddie Kim at 202-551-8713 or Erin Jaskot at 202-551-3442
with any
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
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