SecProbe.io

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 Qualification Request

 RAADR, INC.
 1680 Michigan Avenue, Suite 700
 Miami Beach, Florida 33139

 April 10, 2025

 VIA EDGAR

 Ms. Aliya Ishmukhamedova
 Mr. Matthew Derby
 Office of Technology
 Division of Corporation Finance
 Securities and Exchange Commission
 100 F Street, N.E.
 Washington, D.C. 20549

 Re: Raadr, Inc.
 Offering Statement on Form 1-A (the “Offering Statement”)
 File No. 024-12538

 Dear Ms. Ishmukhamedova and Mr. Derby:

 On behalf of the Company, I respectfully request that the qualification date of the Offering Statement be accelerated and that the Offering Statement be declared qualified Friday, April 11, 2025, at 4:00 p.m. EDT, or as soon thereafter as is reasonably practicable.

 In making this request, the Companys represents that the Offering Statement will be approved in the State of Colorado, upon qualification by the Securities and Exchange Commission (the “Commission”), and acknowledges the following:

 · should the Commission or the Staff, acting pursuant to delegated authority, declare the filing qualified, 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, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy of disclosure in the filing; and

 · the Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

 Very truly yours,

 /s/ Daniel Contreras

 Daniel Contreras
 Chief Executive Officer
 Raadr, Inc.

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 Comment Response Letter

 NEWLAN LAW FIRM, PLLC
 2201 Long Prairie Road, Suite 107-762
 Flower Mound, Texas 75022

 April 8, 2025

 Aliya Ishmukhamedova
 Office of Technology
 Division of Corporation Finance
 Securities and Exchange Commission
 100 F Street, N.E.
 Washington, D.C. 20549

 Re: RAADR, INC.
 Amendments No. 2 and No. 3 to Offering Statement on Form 1-A
 Filed March 3, 2025, and March 26, 2025, respectively
 File No. 024-12538

 Dear Ms. Ishmukhamedova:

 Contemporaneously with this letter, Raadr, Inc. (the “Company”) has filed a pre-qualification amendment (the “Amendment”) to its Offering Statement on Form 1-A.

 In the Amendment, no promissory note conversions are contemplated nor are any selling shareholders listed. This offering now only contemplates the Company’s offering qualified shares of common stock to potential investors.

 With the revised presentation, we believe that this filing is now in order for qualification.

 Please feel free to contact the undersigned at (940) 367-6154, should you have any questions regarding this letter or the Amendment.

 Thank you for your attention in this matter.

 Sincerely,

 NEWLAN LAW FIRM, PLLC

 By: /s/ Eric Newlan
 Eric Newlan
 Managing Member

 cc: Raadr, Inc.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 19, 2025

Daniel Contreras
Chief Executive Officer
RAADR, INC.
1680 Michigan Avenue, Suite 700
Miami Beach FL, 33139

 Re: RAADR, INC.
 Amendment No. 2 to Offering Statement on Form 1-A
 Filed March 3, 2025
 File No. 024-12538
Dear Daniel Contreras:

 We have reviewed your amended offering statement and have the following
comments.

 Please respond to this letter by amending your offering 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 offering 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 February 7,
2025 letter.

Amendment No. 2 to Offering Statement on Form 1-A
General

1. We reissue prior comment 1 regarding the Subject Convertible Notes. If
your offering
 statement is not being used for the conversion of the Subject
Convertible Notes,
 please revise to clarify whether this offering statement is qualifying
the shares
 underlying the notes for resale.
2. To the extent you are qualifying the shares for resale using Securities
Act Rule
 251(d)(3)(i)(A), please provide your analysis regarding whether those
shareholders
 are underwriters. If more than one paragraph of Rule 251(d)(3)(i) is
being used to
 qualify securities, revise your cover page to clearly identify each
subparagraph of
 Rule 251(d)(3)(i) being used and the amounts being qualified pursuant to
such
 paragraph. In addition, clarify whether and how the Company and Daniel
Contreras
 March 19, 2025
Page 2

 will determine, and investors will know, if shares are being acquired
from the
 Company or the selling shareholders, and provide your analysis as to why
this
 transaction is not an indirect primary offering. If the selling
stockholders are engaged
 in an indirect primary offering, then the selling stockholders would be
statutory
 underwriters under Section 2(a)(11) of the Securities Act of 1933, as
amended, and
 must therefore be identified in the offering statement as an underwriter.
For guidance,
 please refer to Securities Act Rules Compliance and Disclosure
Interpretation 612.09.
3. We note that many of the Subject Convertible Notes were issued on
November 15,
 2024, that this offering statement on Form 1-A was initially filed on
November 29,
 2024, and that the selling shareholders may be selling shares
concurrently with the
 company. Please provide a detailed legal analysis regarding whether or
not the
 offerings are part of one integrated offering. Refer to Rule 152 of the
Securities Act.
 Please contact Aliya Ishmukhamedova at 202-551-7519 or Matthew Derby at
202-
551-3334 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Eric Newlan
</TEXT>
</DOCUMENT>

February 7, 2025
Daniel Contreras
Chief Executive Officer
RAADR, INC.
1680 Michigan Avenue, Suite 700
Miami Beach FL, 33139
Re:RAADR, INC.
Amendment No. 1 to Offering Statement on Form 1-A
Filed January 13, 2025
File No. 024-12538
Dear Daniel Contreras:
            We have reviewed your amended offering statement and have the following
comments.
            Please respond to this letter by amending your offering 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 offering 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 December 19,
2024 letter.
Amendment No. 1 to Form 1-A
Cover page
1.Please advise how the Subject Convertible Notes are convertible into Offered Shares.
Securities Act Rule 251(d)(3)(i)(F) is only available for issuances of securities after an
offering statement has been qualified. Given that the Subject Convertible Notes are
presently exercisable and your offering statement is not yet qualified, it appears that
Regulation A is not available for conversion of such securities. Please refer to
Securities Act Sections Compliance and Disclosure Interpretations 139.01 and 134.03.

February 7, 2025
Page 2
Investment Dilution, page 16
2.We note your disclosure here that dilution is presented "without giving effect to the
acquisitions of the Mexedia Companies." Given that those are central to the company,
please revise your dilution table to give affect to the acquisitions, or explain.
Use of Proceeds, page 18
3.We note your disclosure here that you "may issue Offered Shares in this offering for
non-cash consideration, including, without limitation, promissory notes, services
and/or other consideration without notice to subscribers in this offering." Please revise
to disclose all forms of non-cash consideration you intend to accept, how you
determine the value of non-cash consideration, and how you intend to comply with the
fixed price requirements. Refer to the Note to Rule 251(a)(1) of Regulation A. Please
also substantially revise your offering document, including the Cover Page, Summary
and Use of Proceeds sections, which all assume the offering will be made for cash
only, to discuss the non-cash consideration in more detail and to address how issuing
some or all shares for non-cash consideration would impact your offering. Finally,
revise your risk factors to address the potential consequences to the company if a
substantial amount of shares is sold for non-cash consideration.
Procedures for Subscribing, page 19
4.We note that the Company has not set a maximum period of time to decide whether to
accept or reject a subscription. We also note that the Company reserves the right
to reject "subscription in whole or in part, for any reason or for no reason".
Furthermore, in your Subscription Agreement, you state "[t]he Company reserves the
right, in its sole discretion and for any reason whatsoever, to modify, amend and/or
withdraw all or a portion of the Offering and/or accept or reject, in whole or in part,
for any reason or for no reason, any prospective investment in the Offered Shares."
Please revise your disclosure to disclose the details of your process for accepting or
rejecting subscriptions and the mechanics of settlement, including how soon after
receipt of a subscription you will accept or reject such subscription, what factors will
go into deciding whether to accept or reject a subscription, what factors will go into
deciding when to settle subscriptions, how you will inform investors of the settlement
cycle, how soon after you make final determination to accept or reject a subscription
will that settlement occur, and the process and timeline for returning proceeds to
investors for those subscriptions that are rejected.
Business, page 22
5.We note your response to prior comment 4. Please revise the chart on page 5 and 24 to
add Mexedia S.p.A, and for each entity in the chart, include the ownership and voting
control held.
6.We note your response to prior comment 6 and reissue in part. Please disclose when
these individuals commenced their activities at these locations. Supplementally
provide the expiration dates of the working visas of Messrs. Taddeo and Gilcher to
allow these individuals to work in the United States.

February 7, 2025
Page 3
General
7.We note your response to prior comment 7. Please provide a more complete analysis
explaining your conclusion that your principal place of business is in the United States
and whether you expect it will be in the United States for the foreseeable future.
Please provide a more complete analysis explaining whether your officers and
directors primarily direct, control, and coordinate your activities from the United
States. In that regard, your disclosures suggest that only Mr. Contreras is based in the
United States, and that Messrs. Taddeo and Gilcher, who appear to have the authority
to make material decisions for the Company, are predominantly based in Europe. As
part of your analysis, consider the fact that Messrs. Taddeo and Gilcher are the Chief
Executive Officer and Chief Financial Officer, respectively, of Mexedia SPA,
an Italian company listed on the Euronext Growth Paris exchange that holds voting
control of the company. Also, please include, as part of your analysis, what effect
Mexedia SPA’s right to rescind the Acquisition Agreements depending on the amount
of proceeds received in this offering could have on your conclusion. Refer to Rule
251(b)(1) and Compliance and Disclosure Interpretations 182.03
            Please contact Aliya Ishmukhamedova at 202-551-7519 or Matthew Derby at 202-
551-3334 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Eric Newlan

December 19, 2024
Daniel Contreras
Chief Executive Officer
RAADR, INC.
1680 Michigan Avenue, Suite 700
Miami Beach FL, 33139
Re:RAADR, INC.
Offering Statement on Form 1-A
Filed November 29, 2024
File No. 024-12538
Dear Daniel Contreras:
            We have reviewed your offering statement and have the following comments.
            Please respond to this letter by amending your offering 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 offering statement and the information you
provide in response to this letter, we may have additional comments.
Offering Statement on Form 1-A
Business, page 22
1.Please revise your discussion in this section and throughout to clarify the principal
market(s) for your products and services. Refer to Item 7(a)(1)(i) of Form 1-A.
2.You state on page 30 that your monthly lease for the Florida office is $4,750 and for
the Dublin office is $5,240. However, your disclosures on pages F-38 and F-52
indicate you have a monthly lease of $350. Please revise. In addition, please explain
why you believe the office space is adequate given your annual revenue and
operations. Refer to Item 8(a) of Form 1-A.
3.We note your disclosure that Mexedia, Inc., a Florida Corporation, was organized in
2020. We further note that on January 1, 2023, Mexedia, Inc. acquired all the shares
of Phonetime, Inc. and Matchcom Telecommunications, Inc. Please provide a more
complete discussion regarding corporate history and operations of the subsidiaries.

December 19, 2024
Page 2
4.We note your disclosure that Mexedia Limited is a wholly owned subsidiary of
Mexedia S.p.A S.B, an Italian company. Please revise the chart on page 24 to add
Mexedia S.p.A S.B.
Directors, Executive Officers, Promoters and Control Persons, page 37
5.We note that at least two of your officers and directors are also officers and directors
of Mexedia S.p.A. Please include an appropriately captioned risk factor to discuss, if
true, that your officers/directors serve in their position on a part- time basis and/or
otherwise clarify the number of hours they have agreed to dedicate to the business
affairs of your company. To the extent material, please also identify and describe any
potential conflicts of interest that exist, or may exist, as a result of your executive
officers' outside business relationships. Refer to Item 10 of Form 1-A.
6.Please identify the current location(s) from where your officers, partners, or managers
primarily direct, control and coordinate your activities, and when these individuals
commenced their activities at this location(s).
General
7.Please provide us with an analysis that supports your belief that your principal place
of business would be in the United States or Canada for purposes of establishing your
eligibility to conduct an offering under Regulation A. In this regard, we note the
change in control of your company and that Mexedia S.p.A. S.B. is a publicly-held
Italian corporation listed for trading on the Euronext Growth Paris exchange, that
Messrs. Taddeo and Gilcher are officers of Mexedia S.p.A, and that Mexedia S.p.A
identifies Mexedia Inc. as a 100% wholly owned subsidiary in their June 30, 2024
financial statements. Refer to Securities Act Rule 251(b)(1). For additional guidance,
see Securities Act Rules Compliance and Disclosure Interpretation 182.03.
8.In addition to qualifying a Regulation A offering with the Commission, issuers in Tier
1 offerings must register or qualify their offering in any state in which they seek to
offer or sell securities pursuant to Regulation A. Please provide a written
representation confirming that at least one state has advised the company that it is
prepared to qualify or register the offering.

December 19, 2024
Page 3
            We will consider qualifying your offering statement at your request. In connection
with your request, please confirm in writing that at least one state has advised you that it is
prepared to qualify or register your offering. If a participant in your offering is required to
clear its compensation arrangements with FINRA, please have FINRA advise us that it has no
objections to the compensation arrangements prior to qualification.
            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 Aliya Ishmukhamedova at 202-551-7519 or Matthew Derby at 202-
551-3334 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Eric Newlan

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Request for Qualification

Raadr, Inc.

7950 E. Redfield Road, Unit 210

Scottsdale, Arizona 85260

March 12, 2024

VIA EDGAR

Office of Technology

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:Raadr, Inc. (the “Company”)

Post-qualification Amendment No. 9 to

Offering Statement on Form 1-A (the “Post-Qualification Amendment”)

Filed February 28, 2024

Commission File No. 024-11519

Ladies and Gentlemen:

On behalf of the Company, I respectfully request that the qualification date of the Post-Qualification Amendment be accelerated and that the Post-Qualification Amendment be declared qualified Wednesday, March 13, 2024, at 4:00 p.m. EDT, or as soon thereafter as is reasonably practicable.

In making this request, the Company represents that the Post-Qualification Amendment will be approved in the State of New York, upon qualification by the Securities and Exchange Commission (the “Commission”), and acknowledges the following:

-should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the filing qualified, 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, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy of disclosure in the filing; and

-the Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

Very truly yours,

/s/ Jacob DiMartino

Jacob DiMartino

Chief Executive Officer

Raadr, Inc.

United States securities and exchange commission logo
February 6, 2024
Jacob DiMartino
Chief Executive Officer
RAADR, INC.
7950 E. Redfield Road, Unit 210
Scottsdale, Arizona 85260
Re:RAADR, INC.
Post-Qualification Amendment No. 8 to Offering Statement on Form 1-A
Filed January 12, 2024
File No. 024-11519
Dear Jacob DiMartino:
            We have reviewed your amendment and have the following comments.
            Please respond to this letter by amending your offering 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 offering statement and the information you provide in
response to this letter, we may have additional comments.
Post-Qualification Amendment No. 8 to Offering Statement on Form 1-A
Cover Page
1.We note that you have a dual class capital structure whereby Series E Preferred Shares
have a 66 2/3% voting control at all times and your Chief Executive Officer Jacob
DiMartino will have majority voting control of the company following this offering.
Please revise your cover page to discuss the dual class nature of your capital structure and
quantify the voting control that Mr. DiMartino will have following the offering. In
addition, revise your risk factor disclosure to address the risks associated with a dual class
capital structure and management's voting control of the company.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 21
2.Please disclose the minimum funding required to remain in business for at least the next
12 months, as well as the minimum number of months that you will be able to conduct
your planned operations using currently available capital resources. Describe, in detail, the

 FirstName LastNameJacob DiMartino
 Comapany NameRAADR, INC.
 February 6, 2024 Page 2
 FirstName LastName
Jacob DiMartino
RAADR, INC.
February 6, 2024
Page 2
company's plan of operation for the remainder of the fiscal year, including detailed
milestones and the anticipated time frame for beginning and completing each milestone.
Explain how you intend to meet each of the milestones if you cannot receive funding.
Refer to Form 1-A Item 9.
Business, page 24
3.Please substantially revise this section to provide a more complete discussion of your
RAADR product.  As part of your disclosure, clarify whether the product is operational
and available for download, and how many subscribers you currently have and have had
for each of the periods presented.  In addition, revise your discussion of the RAADR
application to clarify what information it collects and how it informs parents of potential
cyberbullying incidents if it is not installed on children's devices.  As a non-exclusive
example, clarify whether it would be able to detect cyber-bulling occurring on social
media accounts that are private or using aliases on a child's device, or if it is restricted to
publicly available data.
Executive Compensation, page 26
4.Please update your executive compensation disclosure for the fiscal year ended December
31, 2023.
            We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            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 Dave Edgar at 202-551-3459 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Matthew Derby at 202-551-3334 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Eric Newlan

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Request for Qualification

Raadr, Inc.

7950 E. Redfield Road, Unit 210

Scottsdale, Arizona 85260

October 10, 2023

VIA EDGAR

Office of Technology

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:Raadr, Inc. (the “Company”)

Post-qualification Amendment No. 7 to

Offering Statement on Form 1-A (the “Post-Qualification Amendment”)

Filed October 3, 2023

Commission File No. 024-11519

Ladies and Gentlemen:

On behalf of the Company, I respectfully request that the qualification date of the Post-Qualification Amendment be accelerated and that the Post-Qualification Amendment be declared qualified Friday, October 13, 2023, at 10:00 a.m. EDT, or as soon thereafter as is reasonably practicable.

In making this request, the Company represents that the Post-Qualification Amendment will be approved in the State of New York, upon qualification by the Securities and Exchange Commission (the “Commission”), and acknowledges the following:

-should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the filing qualified, 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, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy of disclosure in the filing; and

-the Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

Very truly yours,

/s/ Jacob DiMartino

Jacob DiMartino

Chief Executive Officer

Raadr, Inc.

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Qualification Request

Raadr, Inc.

7950 E. Redfield Road, Unit 210

Scottsdale, Arizona 85260

March 13, 2023

VIA EDGAR

Ms. Aliya Ishmukhamedova

Staff Attorney

Office of Technology

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

 Raadr, Inc. (the “Company”)

Post-qualification Amendment No. 6 to

Offering Statement on Form 1-A (the “Post-Qualification Amendment”)

Filed March 6, 2023

Commission File No. 024-11519

Dear Ms. Ishmukhamedova:

On behalf of the Company, I respectfully request that the qualification date of the Post-Qualification Amendment be accelerated and that the Post-Qualification Amendment be declared qualified Wednesday, March 15, 2023, at 9:00 a.m. EDT, or as soon thereafter as is reasonably practicable.

In making this request, the Company represents that the Post-Qualification Amendment will be approved in the State of New York, upon qualification by the Securities and Exchange Commission (the “Commission”), and acknowledges the following:

-should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the filing qualified, 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, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy of disclosure in the filing; and

-the Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

Very truly yours,

/s/ Jacob DiMartino

Jacob DiMartino

Chief Executive Officer

Raadr, Inc.

United States securities and exchange commission logo
March 13, 2023
Jacob DiMartino
Chief Executive Officer
RAADR, INC.
7950 E. Redfield Road, Unit 210
Scottsdale, Arizona 85260
Re:RAADR, INC.
Post-Qualification Amendment No. 6 to Offering Statement on Form 1-A
Filed March 6, 2023
File No. 024-11519
Dear Jacob DiMartino:
            This is to advise you that we do not intend to review your amendment.
            We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            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 Aliya Ishmukhamedova, Staff Attorney, at 202-551-7519, or Jan Woo,
Legal Branch Chief, at 202-551-3453 with any questions.

Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Eric Newlan

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Qualification Request

Raadr, Inc.

7950 E. Redfield Road, Unit 210

Scottsdale, Arizona 85260

January 12, 2023

VIA EDGAR

Ms. Charli Gibbs-Tabler

Staff Attorney

Office of Technology

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

 Raadr, Inc. (the “Company”)

Post-qualification Amendment No. 5 to

Offering Statement on Form 1-A (the “Post-Qualification Amendment”)

Filed January 5, 2023

Commission File No. 024-11519

Dear Ms. Gibbs-Tabler:

On behalf of the Company, I respectfully request that the qualification date of the Post-Qualification Amendment be accelerated and that the Post-Qualification Amendment be declared qualified Thursday, January 12, 2023, at 3:00 p.m. EDT, or as soon thereafter as is reasonably practicable.

In making this request, the Company represents that the Post-Qualification Amendment will be approved in the State of New York, upon qualification by the Securities and Exchange Commission (the “Commission”), and acknowledges the following:

-should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the filing qualified, 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, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy of disclosure in the filing; and

-the Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

Very truly yours,

/s/ Jacob DiMartino

Jacob DiMartino

Chief Executive Officer

Raadr, Inc.

United States securities and exchange commission logo
January 4, 2023
Jacob DiMartino
Chief Executive Officer
Raadr, Inc.
7950 E Redfield Road Unit 210
Scottsdale, Arizona 85260
Re:Raadr, Inc.
Post-Qualification Amendment No. 4 to Offering Statement on Form 1-A
Filed December 27, 2022
File No. 024-11519
Dear Jacob DiMartino:
            This is to advise you that we do not intend to review your amendment.
            We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            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 at Charli Gibbs-Tabler, Staff Attorney, at 202-551-6388 or Joshua
Shainess, Legal Branch Chief, at 202-551-7951 with any questions.

Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Eric Newlan

United States securities and exchange commission logo
June 28, 2022
Jacob DiMartino
Chief Executive Officer
Raadr, Inc.
7950 E. Redfield Road, Unit 210
Scottsdale, Arizona 85260
Re:Raadr, Inc.
Offering Statement on Form 1-A
Post-qualification Amendment No. 3
Filed June 27, 2022
File No. 024-11519
Dear Mr. DiMartino:
            This is to advise you that we do not intend to review your amendment.
            We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            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 Jeff Kauten, Staff Attorney, at (202) 551-3447, or in his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453, with any questions.  If you require further
assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815.

Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Eric Newlan

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Qualification Request

Raadr, Inc. Business Services Corp.

7950 E. Redfield Road, Unit 210

Scottsdale, Arizona 85260

June 28, 2022

VIA EDGAR

Mr. Jeff Kauten

Staff Attorney

Office of Technology

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

 Raadr, Inc. (the “Company”)

Post-qualification Amendment No. 3 to

Offering Statement on Form 1-A (the “Post-Qualification Amendment”)

Filed June 27, 2022

Commission File No. 024-11519

Dear Mr. Kauten:

On behalf of the Company, I respectfully request that the qualification date of the Post-Qualification Amendment be accelerated and that the Post-Qualification Amendment be declared qualified Wednesday, June 29, 2022, at 9:00 a.m. EDT, or as soon thereafter as is reasonably practicable.

In making this request, the Company represents that the Post-Qualification Amendment will be approved in the State of New York, upon qualification by the Securities and Exchange Commission (the “Commission”), and acknowledges the following:

-should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the filing qualified, 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, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy of disclosure in the filing; and

-the Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

Very truly yours,

/s/ Jacob DiMartino

Jacob DiMartino

Chief Executive Officer

Raadr, Inc.

United States securities and exchange commission logo
June 22, 2022
Jacob DiMartino
Chief Executive Officer
Raadr, Inc.
7950 E. Redfield Road, Unit 210
Scottsdale, Arizona 85260
Re:Raadr, Inc.
Offering Statement on Form 1-A
Post-Qualification Amendment No. 1
Filed June 17, 2022
File No. 024-11519
Dear Mr. DiMartino:
            This is to advise you that we do not intend to review your amendment.
            We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            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 Jeff Kauten, Staff Attorney, at (202) 551-3447, or in his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453, with any questions.  If you require further
assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815.

Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Eric Newlan

CORRESP
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Qualification Request

Raadr, Inc. Business Services Corp.

7950 E. Redfield Road, Unit 210

Scottsdale, Arizona 85260

June 22, 2022

VIA EDGAR

Mr. Jeff Kauten

Staff Attorney

Office of Technology

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

 Raadr, Inc. (the “Company”)

Post-qualification Amendment No. 2 to

Offering Statement on Form 1-A (the “Post-Qualification Amendment”)

Filed June 22, 2022

Commission File No. 024-11519

Dear Mr. Kauten:

On behalf of the Company, I respectfully request that the qualification date of the Post-Qualification Amendment be accelerated and that the Post-Qualification Amendment be declared qualified Thursday, June 23, 2022, at 4:00 p.m. EDT, or as soon thereafter as is reasonably practicable.

In making this request, the Company represents that the Post-Qualification Amendment will be approved in the State of New York, upon qualification by the Securities and Exchange Commission (the “Commission”), and acknowledges the following:

-should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the filing qualified, 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, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy of disclosure in the filing; and

-the Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

Very truly yours,

/s/ Jacob DiMartino

Jacob DiMartino

Chief Executive Officer

Raadr, Inc.

CORRESP
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Correspondence    RAADR INC.

  August 30, 2021

 United States Securities and Exchange Commission                              VIA: EDGAR

 Division of Corporation Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

    Re:

   Raadr Inc.

   Offering Statement on Form 1-A

   Filed May 5, 20021

   File No. 024-11519

   Qualification Request

   ATTN: Anna Abramson and Jan Woo

 To Whom It May Concern:

 Further to our receipt of confirmation from your office that there were no comments Raadr Inc.’s (the “Company”) Offering Statement on Form 1-A as well as any amendments as filed, we are now in a position to proceed with the Company’s Form 1-A Regulation A offering, subject to the SEC issuing a notice qualifying our Offering Statement and Amendment(s). The Offering Statement on Form 1-A has been approved by the state of Connecticut upon notice of such qualification by the SEC.

 Accordingly, we hereby request the SEC qualify our Offering Statement on Form 1-A effective 4:00 p.m. on Wednesday September 1, 2021 and issue a notice to that effect.

 In connection with the foregoing request, the Company hereby confirms and acknowledges that:

 1.should the Commission or the staff, acting pursuant to delegated authority, qualify the filing, it does not foreclose the Commission from taking any action with respect to the filing;

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

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

 We trust the foregoing is in order.

 Sincerely,

 /s/ Jacob DiMartino

 Jacob DiMartino, CEO

CORRESP
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RAADR INC.

July 23, 2021

United States Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

 VIA: EDGAR

Re:

 Raadr Inc.

 Qualification of Offering Statement on Form 1-A

 Filed July 23, 20021

 File No. 024-11519

 Withdrawal of Qualification Request

 ATTN: Anna Abramson and Jan Woo

To Whom It May Concern:

Further to our receipt of comments from your office that there were deficiencies preventing the Qualification of Raadr Inc.’s (the “Company”) Offering Statement on Form 1-A, we hereby request to withdraw such Qualification Request as was filed on July 23, 2021 until such time as any deficiencies may be amended.

We trust the foregoing is in order.

Sincerely,

/s/ Jacob DiMartino

Jacob DiMartino, CEO

CORRESP
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Qualification Request    RAADR INC.

  July 21, 2021

    United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

   VIA: EDGAR

    Re:

   Raadr Inc.

   Offering Statement on Form 1-A

   Filed May 5, 20021

   File No. 024-11519

   Qualification Request

   ATTN: Anna Abramson and Jan Woo

 To Whom It May Concern:

 Further to our receipt of confirmation from your office that there were no comments Raadr Inc.’s (the “Company”) Offering Statement on Form 1-A as well as any amendments as filed, we are now in a position to proceed with the Company’s Form 1-A Regulation A offering, subject to the SEC issuing a notice qualifying our Offering Statement and Amendment(s). Accordingly, we hereby request the SEC qualify our Offering Statement on Form 1-A effective 4:00 p.m. on Friday, July 23, 2021 and issue a notice to that effect.

 In connection with the foregoing request, the Company hereby confirms and acknowledges that:

 1.should the Commission or the staff, acting pursuant to delegated authority, qualify the filing, it does not foreclose the Commission from taking any action with respect to the filing;

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

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

 We trust the foregoing is in order.

 Sincerely,

 /s/ Jacob DiMartino

 Jacob DiMartino, CEO

United States securities and exchange commission logo
May 12, 2021
Jacob DiMartino
Chief Executive Officer
Raadr, Inc.
1 West Deer Valley Rd.
Suite 105
Phoenix, AZ 85027
Re:Raadr, Inc.
Offering Statement on Form 1-A
Filed May 5, 2021
File No. 024-11519
Dear Mr. DiMartino:
            We have reviewed your offering 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 offering 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 offering statement and the information you
provide in response to these comments, we may have additional comments.
Form 1-A submitted May 5, 2021
Executive Compensation, page 27
1.Please revise to provide executive compensation disclosure required by Item 11 of Form
1-A for the year ended December 31, 2020.
Principal Stockholders, page 28
2.Please revise the beneficial ownership table to reflect the total voting power of Jacob
DiMartino taking into account his shares of common stock and Series E Preferred Stock.
Exhibit Index, page 32
3.Please file your bylaws as an exhibit to this offering circular. Refer to Item 17 of Form 1-
A.

 FirstName LastNameJacob DiMartino
 Comapany NameRaadr, Inc.
 May 12, 2021 Page 2
 FirstName LastName
Jacob DiMartino
Raadr, Inc.
May 12, 2021
Page 2
            Please contact Anna Abramson, Staff Attorney, at 202-551-4969 or Jan Woo, Legal
Branch Chief, at 202-551-3453 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       William R. Eilers, Esq.

June 22 , 2015

Jacob DiMartino
President and  Chief Executive Officer
PITOOEY!, Inc .
1042 9 S. 51st Street, Suite 225
Phoenix, Arizona 85044

Re: PITOOEY!, Inc .
 Preliminary Information  Statement on Schedule 14 C
Filed May 20, 2015
File No. 000-53991

Dear Mr. DiMartino:

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing  and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We u rge 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 Exchange Act of 1934 and all applicable rules require .

Sincerely,

 /s/ Maryse Mills -Apenteng

Maryse Mills -Apenteng
Special Counsel

June 12 , 2015

Jacob DiMartino
President and  Chief Executive Officer
PITOOEY!, Inc .
1042 9 S. 51st Street, Suite 225
Phoenix, Arizona 85044

Re: PITOOEY!, Inc .
 Revised Preliminary Information  Statement on Schedule 14 C
Filed June 10 , 2015
File No. 000-53991

Dear Mr. DiMartino:

We have reviewed your filing an d 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.   References to prior comments are to comments in our May 27, 2015 letter.

General

1. We note your response to prior comment 2.  Consistent with your response, please
disclose in the information statement your delinquent filer status and the remedial steps
you intend to take in this regard.

Voting Securities & Ownership Thereof by Certain  Beneficial Owners and Management, page 3

2. Please revise to disclose the date on which beneficial ownership was calculated.

Please contact Ji Shin, Attorney -Advisor, at (202) 551 -3579, or in her absence, me at
(202) 551 -3457  with any questions.

Sincerely,

 /s/ Maryse Mills -Apenteng

Maryse Mills -Apenteng
Special Counsel

May 27, 2015

Jacob DiMartino
President and  Chief Executive Officer
PITOOEY!, Inc .
1042 9 S. 51st Street, Suite 225
Phoenix, Arizona 85044

Re: PITOOEY!, Inc .
 Preliminary Information  Statement on Schedule 14 C
Filed May 20, 2015
File No. 000-53991

Dear Mr. DiMartino:

We have reviewed your filing an d 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

General

1. Schedule 14C is appropriate only when there is no solicitation or the solicitation is
exempt.  Accordingly, pl ease tell us the basis for your belief that an information
statement on Schedule 14C is the appropriate schedule to be filed.   In this regard, we note
that you state that the board of directors and holders of a majority of your voting shares
approved the p roposal to change your corporate name.  However, the certificate of
amendment to your articles of incorporation in Exhibit A indicates that 48.22% of
shareholders voted to approve the proposal.  In your response letter, please identify the
stockholders who  approved the proposal, the percentage of votes  they each represent and
their relationships with the company.  Please also tell us the sequence of events through
which these consents were obtained and provide an analysis as to whether such activities
constitute a solicitation, as defined in Rule 14a -1(l).

2. We note that you have not filed an annual report for the fiscal year ended December 31,
2014 or a quarterly report for the period ended March 31, 2015 and therefore are not
current with respect to y our reporting obligations.  In addition, it appears that you may

Jacob DiMartino
PITOOEY!, Inc.
May 27, 2015
Page 2

 have failed to remain current with respect to other reports, including current reports on
Form 8 -K and proxy/information statements .  Please tell us what your plans are with
respect to addres sing your delinquent filing status and revise your information statement
to address this delinquency  and to discuss any remedial steps you intend to take in this
regard.

3. It appears that Mr. DiMartino was appointed as chief executive officer in 2015, but a
current report on Form 8 -K with respect to the appointment was not filed.  Please refer to
paragraph (c) of Item 5.02 of Form 8 -K and advise.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be ce rtain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

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

Please contact Ji Shin, Attorney -Advisor, at (202) 551 -3579, or in her absence, me at
(202) 551 -3457  with any questions.

Sincerely,

 /s/ Maryse Mills -Apenteng

Maryse Mills -Apenteng
Special Cou nsel

April 3 , 2014

Via E -mail
Jacob DiMartino
Chief Executive Officer
Pitooey!, Inc.
15685 N. Cave Creek Rd.
Suite 101
Scottsdale, AZ 85032

Re: Pitooey!, Inc.
 Form 8 -K
Filed March 25, 2014
File No. 000 -53991

Dear Mr. DiMartino:

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to t he company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We urge all persons who are responsible for the
accurac y and adequacy of the disclosure in the filing  to be certain that the filing  includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Myra Moosariparambil

Myra Moosariparambil
Staff Accountant

CORRESP
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Via email (proof of delivery and “read” requested):

MoosariparambilM@SEC.GOV

March 28, 2014

Ms. Myra Moosariparambil

Staff Accountant

Division of Corporation Finance

U.S. Securities and Exchange Commission

Washington, DC 20549

Dear Ms. Moosariparambil:

Re:	PITOOEY!, Inc.

Form 8-K

Filed March 25, 2014

File No. 000-53991

Regarding the comments by the Securities
and Exchange Commission (the “Commission”) in its correspondence, dated March 26, 2014, PITOOEY!, Inc. (the”
Company”) understands that:

 1. It is responsible for the adequacy and accuracy of the disclosures in our Form 8-K, filed

March
25, 2014 (the “Filing”);

 2. staff comments or changes to disclosure in response to staff comments do not foreclose the Commission
from taking any action with respect to the Filing; and

 3. the Company may not assert staff comments as a defense in any proceeding initiated by the Commission
or any person under the Federal securities laws of the United States.

Sincerely,

Jacob DiMartino 	 Chief Executive Officer

/clf

cc:	Robert L. Sonfield, Jr., Esq.

March 26 , 2014

Via E-mail
Jacob DiMartino
Chief Executive Officer
Pitooey! , Inc.
15685  N. Cave Creek Rd .
Suite 101
Scottsdale, AZ 85032

Re: Pitooey! , Inc.
 Form 8 -K
Filed March 25 , 2014
File No. 000-53991

Dear Mr. DiMartino :

We have reviewed your filing an d have the following comment s.  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 within five busines s days by amending your filing or by
advising us when you will provide the requested response.   If you do not believe our comment s
apply  to your facts and circumstances or do not belie ve an amendment is appropriate, please tell
us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 8 -K filed March 25 , 2014

1.  Please amend your form 8 -K to include the following:

 A statement whether the former accountant resigned, declined to stand for re -election
or was dismissed and the date thereof, as required by Item 304(a)(1)(i) of Regulation
S-K;

 A statement whether the change of accountant was recommended or approved by any
audit or similar committee of the board of directors or the board of directors, if you
have no audit or similar committee. Refer to Item 3 04(a)(1)(iii) of Regulation S -K;

Jacob DiMartino
Pitooey! , Inc.
March 26 , 2014
Page 2

  A statement whether your former accountant's report on the financial statements for
either of the past two years contained an adverse opinion or a disclaimer of opinion or
was qualified or modified as to uncertainty, audit scope or accounting principles; and
a description of the nature of each such adverse opinion, disclaim er of opinion,
modification or qualification.  Refer to Item 304(a)(1)(ii) of Regulation S -K;

 A statement whether there were any disagreements with your former accountant
during the two most recent fiscal years and any subsequent interim period through th e
date of resignation, declination or dismissal of your former accountant.  Refer to Item
304(a)(1)(iv) of Regulation S -K;

 In the event of disagreement(s) and/or reportable event(s), provide the specific
disclosures required by Item 304(a)(1)(iv) and (v) of Regulation S -K;

 A statement whether  during your two most recent fiscal years, and any subsequent
period pri or to engaging your new accountant you consulted the new accountant
regarding any matters identified in Item 304(a)(2) of Regulation S -K.

2.  In your amendment please also include a letter, as an Exhibit 16, from your former
accountant addressing to the Commission to state whether it agrees with the statements
made by you in  response to the required disclosure under Item 304(a)  of Regulation S -K
and if not, states the respects in which it does not agree.  Refer to Item 304(a)(3) of
Regulation S -K.

 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 Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the di sclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 The company is responsible for the adequacy and accuracy of the disclosure in the
filing;

 Staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

 The company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the fe deral securities laws of the United
States.

Jacob DiMartino
Pitooey! , Inc.
March 26 , 2014
Page 3

 If you have questions regarding these comments and related matters , please contact me at
202-551-3796 .

Sincerely,

 /s/ Myra Moosariparambil

Myra Moosariparambil
Staff Accountant