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Edgemode, Inc.
CIK: 0001652958  ·  File(s): 333-291054  ·  Started: 2026-01-02  ·  Last active: 2026-01-02
Orphan - no UPLOAD in window 1 company response(s) Low - unmatched response
CR Company responded 2026-01-02
Edgemode, Inc.
Offering / Registration Process
File Nos in letter: 333-291054
Edgemode, Inc.
CIK: 0001652958  ·  File(s): 333-255168  ·  Started: 2021-04-13  ·  Last active: 2021-04-19
Response Received 1 company response(s) High - file number match
UL SEC wrote to company 2021-04-13
Edgemode, Inc.
File Nos in letter: 333-255168
↓
CR Company responded 2021-04-19
Edgemode, Inc.
Offering / Registration Process Regulatory Compliance Financial Reporting
File Nos in letter: 333-255168
Edgemode, Inc.
CIK: 0001652958  ·  File(s): 333-236023  ·  Started: 2020-02-03  ·  Last active: 2020-02-03
Orphan - no UPLOAD in window 1 company response(s) Low - unmatched response
CR Company responded 2020-02-03
Edgemode, Inc.
Offering / Registration Process Regulatory Compliance Financial Reporting
File Nos in letter: 333-236023
Edgemode, Inc.
CIK: 0001652958  ·  File(s): 333-227286  ·  Started: 2018-09-24  ·  Last active: 2018-10-02
Response Received 2 company response(s) High - file number match
UL SEC wrote to company 2018-09-24
Edgemode, Inc.
File Nos in letter: 333-227286
↓
CR Company responded 2018-09-27
Edgemode, Inc.
File Nos in letter: 333-227286
References: September 24, 2018
Filing - Correspondence from Edgemode, Inc.
CORRESP · 2018-09-27
Generating summary...
↓
CR Company responded 2018-10-02
Edgemode, Inc.
File Nos in letter: 333-227286
Filing - Correspondence from Edgemode, Inc.
CORRESP · 2018-10-02
Generating summary...
Edgemode, Inc.
CIK: 0001652958  ·  File(s): N/A  ·  Started: 2015-11-20  ·  Last active: 2015-12-09
Response Received 1 company response(s) Medium - date proximity
UL SEC wrote to company 2015-11-20
Edgemode, Inc.
Filing - SEC Comment Letter to Edgemode, Inc.
UPLOAD · 2015-11-20
Generating summary...
↓
CR Company responded 2015-12-09
Edgemode, Inc.
File Nos in letter: 333-207047
Filing - Correspondence from Edgemode, Inc.
CORRESP · 2015-12-09
Generating summary...
Edgemode, Inc.
CIK: 0001652958  ·  File(s): N/A  ·  Started: 2015-10-16  ·  Last active: 2015-11-10
Response Received 1 company response(s) Medium - date proximity
UL SEC wrote to company 2015-10-16
Edgemode, Inc.
Filing - SEC Comment Letter to Edgemode, Inc.
UPLOAD · 2015-10-16
Generating summary...
↓
CR Company responded 2015-11-10
Edgemode, Inc.
File Nos in letter: 333-207047
Filing - Correspondence from Edgemode, Inc.
CORRESP · 2015-11-10
Generating summary...
DateTypeCompanyLocationFile NoLink
2026-01-02 Company Response Edgemode, Inc. NV N/A
Offering / Registration Process
Read Filing View
2021-04-19 Company Response Edgemode, Inc. NV N/A
Offering / Registration Process Regulatory Compliance Financial Reporting
Read Filing View
2021-04-13 SEC Comment Letter Edgemode, Inc. NV N/A Read Filing View
2020-02-03 Company Response Edgemode, Inc. NV N/A
Offering / Registration Process Regulatory Compliance Financial Reporting
Read Filing View
2018-10-02 Company Response Edgemode, Inc. NV N/A Read Filing View
2018-09-27 Company Response Edgemode, Inc. NV N/A Read Filing View
2018-09-24 SEC Comment Letter Edgemode, Inc. NV N/A Read Filing View
2015-12-09 Company Response Edgemode, Inc. NV N/A Read Filing View
2015-11-20 SEC Comment Letter Edgemode, Inc. NV N/A Read Filing View
2015-11-10 Company Response Edgemode, Inc. NV N/A Read Filing View
2015-10-16 SEC Comment Letter Edgemode, Inc. NV N/A Read Filing View
DateTypeCompanyLocationFile NoLink
2021-04-13 SEC Comment Letter Edgemode, Inc. NV N/A Read Filing View
2018-09-24 SEC Comment Letter Edgemode, Inc. NV N/A Read Filing View
2015-11-20 SEC Comment Letter Edgemode, Inc. NV N/A Read Filing View
2015-10-16 SEC Comment Letter Edgemode, Inc. NV N/A Read Filing View
DateTypeCompanyLocationFile NoLink
2026-01-02 Company Response Edgemode, Inc. NV N/A
Offering / Registration Process
Read Filing View
2021-04-19 Company Response Edgemode, Inc. NV N/A
Offering / Registration Process Regulatory Compliance Financial Reporting
Read Filing View
2020-02-03 Company Response Edgemode, Inc. NV N/A
Offering / Registration Process Regulatory Compliance Financial Reporting
Read Filing View
2018-10-02 Company Response Edgemode, Inc. NV N/A Read Filing View
2018-09-27 Company Response Edgemode, Inc. NV N/A Read Filing View
2015-12-09 Company Response Edgemode, Inc. NV N/A Read Filing View
2015-11-10 Company Response Edgemode, Inc. NV N/A Read Filing View
2026-01-02 - CORRESP - Edgemode, Inc.
CORRESP
 1
 filename1.htm

 Edgemode, Inc.

 110 East
Broward Blvd

 Fort Lauderdale,
Florida, 33301

 January 2, 2026

 Via EDGAR

 Division of Corporation Finance

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D. C. 20549

 Re:
 Edgemode, Inc.

 Registration Statement on Form S-1

 File No. 333-291054

 Ladies and Gentlemen:

 In accordance with Rule 461
promulgated pursuant to the Securities Act of 1933, Edgemode, Inc. is hereby requesting that the effective date of the above-referenced
Registration Statement be accelerated so that the same will become effective at 4:30 p.m. on Tuesday, January 6, 2026, or as soon thereafter
as is practicable.

 If you have any questions
regarding this request, please contact either Brian Pearlman or Brian Bernstein, our legal counsel, at (954) 880-9484.

 Very truly yours,

 /s/ Simon Wajcenberg

 Simon Wajcenberg

 Chief Financial
Officer

 cc:

 Brian A. Pearlman, Esq.

 Brian S. Bernstein, Esq.
2021-04-19 - CORRESP - Edgemode, Inc.
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                            FOURTH WAVE ENERGY, INC.
                        75 E. Santa Clara St., 6th Floor
                               San Jose, CA 95113
                                 (408) 213-8874

                                 April 19, 2021

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

      Re:   Fourth Wave Energy, Inc.
            Registration Statement on Form S-1
            Filed April 9, 2021
            File No. 333-255168

     Fourth Wave Energy,  Inc. (the "Company")  requests that the effective date
of the above captioned Registration Statement be accelerated to Wednesday, April
21, 2021 at 2:00 P.M. Eastern time, or as soon as practicable thereafter.

     The Company understands that:

o    should the Commission or the staff, acting pursuant to delegated authority,
     declare the filing  effective,  it does not foreclose the  Commission  from
     taking any action with respect to the filing;

o    the action of the  Commission  or the staff,  acting  pursuant to delegated
     authority, in declaring the filing effective,  does not relieve the Company
     from  its  full  responsibility  for  the  adequacy  and  accuracy  of  the
     disclosure in the filing; and

o    the  Company  may  not  assert  staff  comments  and  the   declaration  of
     effectiveness as a defense in any proceeding initiated by the Commission or
     any person under the federal securities laws of the United States.

                                     Very Truly Yours,

                                     FOURTH WAVE ENERGY, INC.

                                     /s/ J. Jacob Isaacs
                                     ---------------------------
                                     J. Jacob Isaacs,
                                     Principal Executive Officer

</TEXT>
</DOCUMENT>
2021-04-13 - UPLOAD - Edgemode, Inc.
United States securities and exchange commission logo
April 13, 2021
J. Jacob Isaacs
Chief Executive Officer
Fourth Wave Energy, Inc.
75 E. Santa Clara St., 6th Floor
San Jose, CA 95113
Re:Fourth Wave Energy, Inc.
Registration Statement on Form S-1
Filed April 9, 2021
File No. 333-255168
Dear Mr. Isaacs:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact David Gessert at 202-551-2326 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
2020-02-03 - CORRESP - Edgemode, Inc.
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                                  PIERRE CORP.
                       750 N. San Vincente, Suite 800 West
                            West Hollywood, CA 90069
                                 (818) 855-8199

                                February 3, 2020

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

      Re:   Pierre Corp.ration
            Form S-1
            SEC File No. 333-236023

     Pierre Corp. (the "Company")  requests that the effective date of the above
captioned Registration  Statement be accelerated to Thursday,  February 6, 2020,
2:00 P.M. Eastern time, or as soon as practicable thereafter.

     The Company understands that:

     o    should the  Commission  or the staff,  acting  pursuant  to  delegated
          authority,  declare the filing  effective,  it does not  foreclose the
          Commission from taking any action with respect to the filing;

     o    the  action  of  the  Commission  or the  staff,  acting  pursuant  to
          delegated  authority,  in  declaring  the filing  effective,  does not
          relieve the Company from its full  responsibility for the adequacy and
          accuracy of the disclosure in the filing; and

     o    the Company  may not assert  staff  comments  and the  declaration  of
          effectiveness  as  a  defense  in  any  proceeding  initiated  by  the
          Commission  or any person  under the  federal  securities  laws of the
          United States.

                                   Very Truly Yours,

                                   PIERRE CORP.

                                   /s/ J. Jacob Isaacs
                                   _______________________________
                                   J. Jacob Isaacs, Principal Executive Officer

</TEXT>
</DOCUMENT>
2018-10-02 - CORRESP - Edgemode, Inc.
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                                  WADENA CORP.
                       750 N. San Vicente, Suite 800 West
                            West Hollywood, CA 90069
                                 (818) 855-8199

                                 October 2, 2018

Michael Killoy
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

      Re:   Wadena Corp.
            Form S-1
            File No. 333-227286

     Wadena Corp. (the "Company")  requests that the effective date of the above
captioned  Registration  Statement be accelerated to October 5, 2018,  3:00 P.M.
Eastern time, or as soon as practicable thereafter.

     The Company understands that:

     o    should the  Commission  or the staff,  acting  pursuant  to  delegated
          authority,  declare the filing  effective,  it does not  foreclose the
          Commission from taking any action with respect to the filing;

     o    the  action  of  the  Commission  or the  staff,  acting  pursuant  to
          delegated  authority,  in  declaring  the filing  effective,  does not
          relieve the Company from its full  responsibility for the adequacy and
          accuracy of the disclosure in the filing; and

     o    the Company  may not assert  staff  comments  and the  declaration  of
          effectiveness  as  a  defense  in  any  proceeding  initiated  by  the
          Commission  or any person  under the  federal  securities  laws of the
          United States.

                                     Very Truly Yours,

                                     WADENA CORP.

                                     /s/ J. Jacob Isaacs
                                     -----------------------
                                     J. Jacob Isaacs
                                     Chief Executive Officer
</TEXT>
</DOCUMENT>
2018-09-27 - CORRESP - Edgemode, Inc.
Read Filing Source Filing Referenced dates: September 24, 2018
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                                HART & HART, LLC
                                ATTORNEYS AT LAW
                             1624 Washington Street
                                Denver, CO 80203
William T. Hart, P.C.              ________                   harttrinen@aol.com
Will Hart                       (303) 839-0061               Fax: (303) 839-5414

                               September 27, 2018

Michael Killoy
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

      Re:   Wadena Corp.
            Registration Statement on Form S-1 Amendment No. 1
            File No. 333-227286

     This office represents Wadena Corp. (the "Company"). Amendment No. 1 to the
Company's Registration Statement on Form S-1 has been filed with the Commission.
This letter provides the Company's  responses to the comments  received from the
staff by letter dated  September 24, 2018. The paragraph  numbers in this letter
correspond  with the numbered  paragraphs  in the staff's  comment  letter.  The
number  under  the  "page  number"  column  indicates  the  page  number  in the
Registration Statement where the response to the comment can be found.

                                                                    Page Number
                                                                    -----------

     1. Comment complied with.                                        3, 4, 20

     If you should have any questions  concerning the  foregoing,  please do not
hesitate to contact the undersigned.

                                     Very Truly Yours,

                                     HART & HART, LLC

                                     /s/ William T. Hart

                                     By
                                        William T.  Hart
</TEXT>
</DOCUMENT>
2018-09-24 - UPLOAD - Edgemode, Inc.
September 24, 2018
Josoeph Isaacs
Chief Executive Officer
Wadena Corp.
750 N. San Vicente, Suite 800 West
West Hollywood, CA 90069
Re:Wadena Corp.
Registration Statement on Form S-1
Filed September 11, 2018
File No. 333-227286
Dear Mr. Isaacs:
            We have limited our review of your registration statement to those issues we have
addressed in our comment.  In our comment, we may ask you to provide us with information so
we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our 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 comment, we may have additional comments.
Form S-1 filed September 11, 2018
Cover Page
1.Please provide the pricing information on the prospectus cover page as required by Item
501(b)(3) of Regulation S-K.  We note your disclosure in the summary that "until a
market develops for our common stock, these shares may be sold at a price of $0.05 per
share. If and when our common stock becomes quoted on the over-the-counter market, the
shares...may be sold at prices and terms then prevailing...."  Please note that we do not
consider the OTC Pink sheets to constitute a sufficient existing market for selling
shareholders to offer their shares at market prices.  Therefore, please revise to indicate on
the cover page which OTC Market system you plan to have your shares quoted on.

 FirstName LastNameJosoeph Isaacs
 Comapany NameWadena Corp.
 September 24, 2018 Page 2
 FirstName LastName
Josoeph Isaacs
Wadena Corp.
September 24, 2018
Page 2
            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 Michael Killoy at (202) 551-7576 or Pamela Howell at (202) 551-
3357 with any questions.
Sincerely,
Division of Corporation Finance
Office of Beverages, Apparel and
Mining
2015-12-09 - CORRESP - Edgemode, Inc.
CORRESP
1
filename1.htm

Acceleration Letter

 BARNETT & LINN

 ATTORNEYS AT LAW

 23564 Calabasas Road, Suite 205 • Calabasas, CA 91302

 www.barnettandlinn.com

WILLIAM B. BARNETT

 TELEPHONE: 818-436-6410

Attorney/Principal

 FACSIMILE: 818-223-8303

 wbarnett@wbarnettlaw.com

December 8, 2015

Division of Corporation Finance

SECURITIES AND EXCHANGE COMMISSION

100 F Street NE

Washington D.C.  20549

Attn:

John Reynolds, Asst. Director

Michael Killoy, Staff Attorney

Jim Lopez, Staff Attorney

Steve Lo, Staff Accountant

Craig Arakawa, Staff Accountant

Re:

Wadena Corp. (“Registrant”)

Amendment No. 2 to Registration Statement on Form S-1

Filed on September 18, 2015

File No.  333-207047

Gentlepersons:

On behalf of the Registrant, we hereby request “acceleration” of the effective date of the Registration Statement to 12:00 p.m., Washington, D.C. time, on Tuesday, December 15, 2015.

Thank you for your cooperation and courtesies in this matter.

Very truly yours,

BARNETT & LINN

William B. Barnett

WBB: scc

cc/ Mr. St. George
2015-11-20 - UPLOAD - Edgemode, Inc.
Mail Stop 3561
November 20, 2015
Via E -mail
Cort St. George
Chief Executive Officer
Wadena Corp.
1540 South C oast Highway, Suite 206
Laguna Beach, CA 92651

Re: Wadena Corp.
Amendment No. 1 to Registration Statement on Form S-1
Filed November 5 , 2015
  File No. 333 -207047

Dear Mr. St. George :

We have reviewed your amended registration statement  and have the following
comments .  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply 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 these  comments, we may have  additional comments.   Unless  we note
otherwise , our references to prior comments are to comments in our October 15, 2015  letter .

Business, page 12

1. We note your revised disclosure and response to comments 3, 5 an d 6.  We also note the
statement on page 13 that you plan to “connect individuals with participating physicians
and other licensed healthcare practitioners.”   Please revise to clarify, if true, that New
Benefits does not directly provide medical services, describe (by number, location, nature
of practice, etc.) the physicians who “have independently contracted to be in a network
operated by New Benefits,” and describe the material terms of their contracts to provide
medical services.

Financial Statements, page 31

2. We note your revisions to your year -end financial statements in response to our prior
comments 9 and 10.   Please also provide corresponding revisions in your interim
financial statements to address these comments.

Cort St. George
Wadena, Corp.
November 20, 2015
Page 2

 You may contact  Steve Lo  at 202-551-3394 or Craig Arakawa  at 202-551-3650 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Michael Killoy  at 202-551-7576 or Jim Lopez at 202 -551-3536 with any other questions.

Sincerely,

 /s/ Jim Lopez (for)

John Reynolds
Assistant Director
Office of Beverages, Apparel and
Mining

cc:  William B. Barnett
2015-11-10 - CORRESP - Edgemode, Inc.
CORRESP
1
filename1.htm

Request to Withdraw Acceleration

 BARNETT & LINN

 ATTORNEYS AT LAW

 23564 Calabasas Road, Suite 205 • Calabasas, CA 91302

 www.barnettandlinn.com

WILLIAM B. BARNETT

 TELEPHONE: 818-436-6410

Attorney/Principal

 FACSIMILE: 818-223-8303

 wbarnett@wbarnettlaw.com

November 10, 2015

Division of Corporation Finance

SECURITIES AND EXCHANGE COMMISSION

100 F Street NE

Washington D.C.  20549

Attn:

John Reynolds, Asst. Director

Michael Killoy, Staff Attorney

Jim Lopez, Staff Attorney

Steve Lo, Staff Accountant

Craig Arakawa, Staff Accountant

Re:

Wadena Corp. (“Registrant”)

Amendment No. 1 to Registration Statement on Form S-1

Filed on September 18, 2015

File No.  333-207047

Gentlepersons:

On behalf of the Registrant we hereby withdraw our request for acceleration to declare Registration Statement File No. 333-207047 effective as contained in our November 5, 2015 Response Letter to the Commission.

Should you require any further information regarding this matter, please do not hesitate to call or email me.

Very truly yours,

BARNETT & LINN

William B. Barnett

WBB: scc

cc/ Mr. St. George
2015-10-16 - UPLOAD - Edgemode, Inc.
Mail Stop 3561
October 15,  2015
Via E -mail
Cort St. George
Chief Executive Officer
Wadena Corp.
1540 South coast Highway, Suite 206
Laguna Beach, CA 92651

Re: Wadena Corp.
Registration Statement on Form S-1
Filed September 18, 2015
  File No. 333 -207047

Dear Mr. St. George :

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amen dment 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 these  comments, we may have  additional comments.

General

1. 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.

2. We note the statement  on page 20 that your former president , Rodney McLellan , is your
promoter.  Please revise to identify your promoters.  In this regard, it is unclear why Mr.
St. George is not your promoter.

Prospec tus Summary , page 4

3. Please disclose your plan of operations, including the significant milestones and
approximate timeframe to the point of generating revenues.  Include a discussion of the

Cort St. George
Wadena Corp.
October 15, 2015
Page 2

 impact that lack of funding would have upon the timing.  Addition ally, please  revise to
disclose whether the operating estimate for the next 12 months  includes only
implementation of the marketing plans or if it includes all of your required business
expenses.  If it is only the marketing  plans, please additionally incl ude a breakdown of
the estimates for your entire business operations expenses for the same timeframe.

4. In this regard, we note the statement on page 17 that the “first phase” of your business
plan is 80% completed.  Please revise to provide more detail regarding the intended
phases of your business, including the estimated timelines, specific work to be completed
and phase(s) in which you expect to begin operations and generating revenues.

Description of Business, page 12

Business, page 12

5. We note the  statement on page F -4 that you intend to offer membership to healthcare
benefits packages as a reseller for New Benefits, Inc.  Please revise to clarify the steps
you have taken and plan to take in order to become a reseller.  For example, please revise
to state whether you have entered into a contract with New Benefits, Inc.  Additionally, if
such a contract has been entered into and it is material, please provide the contract as an
exhibit under Item 601(b)(10) of Regulation S -K.

6. Please revise to clearl y explain your intended product.  The following descriptions do not
clearly explain how you intend to generate revenues and incur expenses: “a fixed digital
gateway presence,” “an enterprise -level Telemedicine platform,” a “dual -channel
approach,” and a “f ixed digital gateway for telehealth services and internet interface.”  In
this regard, you also state that you intend to be a reseller of New Benefits, Inc.  It is
unclear (1) if you intend to operate or pay for another entity to operate a website and
video production service and (2) whether and how you r intend ed resales  of New Benefits
would be in addition to or part of your “platform.”  It is also unclear w hy you refer to
yourself as an “internet dating service” on page 16.  Please revise accordingly.

Security Ownership of Certain Beneficial Owners and Management, page 20

7. Please revise to clarify the ownership of Mr. McLellan’s shares.  It is unclear if such
shares were transferred  in connection with Mr. St. George  becoming president of
Wadena .

Certain Relationships  and Related Transactions , page 21

8. It is un clear why you do not address the transactions and relationships identified on page
F-5.  Please revise or advise.

Cort St. George
Wadena Corp.
October 15, 2015
Page 3

Wadena Corp’s Balance sheets, page F -1

Development Stage Company, page F -11

9. We note you early adopted ASU 2014 -10.  Please disclose the  risks and uncertainties
related to the nature of your operations in which you are currently engaged if principal
operations have not commenced.  Refer to ASC 275 -10-50-2A.

Note 8 Subsequent Events, page F -14

10. Please disclose the date through which you ha ve evaluated subsequent events and
whether that date is either the date the financial statements were issued or availab le to be
issued.  Refer to ASC 855 -10-50-1.

Item 26 - Recent Sales of Unregistered Securities, page II -3

11. Please advise us why you do not  include in this section the $64,000 promissory note
dated February 9, 2015, as disclosed on page F -14.  Please also advise us regarding the
notes payable referenced on page F -13.

Exhibits

12. We note your reference to the unsecured, non -interest bearing loa ns which have no
specific terms of repayment throughout your filing.  Please provide the loan documents as
an exhibit to your filing pursuant to Item 601(b)(10) as a material contract.

13. We note that exhibit 3.2 refers to 205,000,000 authorized shares, howev er, your
prospectus refers to 200,000,000 authorized.  Please revise to reconcile the apparent
inconsistenc y.  Additionally, please revise to provide exhibit 3.2 in proper electronic
form.

14. We note the disclosure on pag e 20 that Wadena  has an employment a greem ent with Mr.
St. George but  “the Company has no written employment agreements with its officers or
directors.”  We also note the reference on page 16 to your executive office lease
arrangement where the space is offered “free of charge.”   Please file copies of all written
agreements or summaries of any oral arrangements pursuant to Item 601(b)(10) of
Regulation S -K.  In this regard, we refer you to the Regulation S -K Compliance and
Disclosure Interpretation Question  146.04  available on the Commission’s website.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in

Cort St. George
Wadena Corp.
October 15, 2015
Page 4

 possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event  you request acceleration of the effective date
of the pending regist ration statement , please provide  a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing e ffective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the feder al
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that thos e requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement .  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact  Steve Lo  at 202-551-3394  or Craig Arakawa  at 202-551-3650  if you
have questions regarding comments on th e financial statements and related matters.  Please
contact Michael Killoy  at 202-551-7576  or Jim Lopez at 202 -551-3536  with any other questions.

Sincerely,

 /s/ James Lopez (for)

John Reynolds
Assistant Director
Office of Beverages, Apparel and
Mining

cc:  William B. Barnett

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