SecProbe.io

CORRESP
 1
 filename1.htm

 Office
of Trade & Services

 Division
of Corporation Finance

 US
Securities and Exchange Commission

 Washington,
DC 20549

 Request
for Acceleration of Effectiveness Under Rule 461

 Dear
Sir or Madam:

 On
behalf of Radiant Strategies Corp, (the "Company"), pursuant to Rule 461 under the Securities Act of 1933, as amended, the
Company respectfully requests that the U.S. Securities and Exchange Commission (the "Commission") accelerate the effectiveness
of the Company's Registration Statement on Form S-1 (File No. 333-288165) (the "Registration Statement") to 12.00 PM
Eastern Time on December 8, 2025, or as soon as practicable thereafter.

 The
Company hereby acknowledges the following:

 1. Responsibility
 for Disclosure. The Company is responsible for the adequacy and accuracy of the disclosures
 contained in the Registration Statement.

 2. No
 SEC Approval or Clearance. Staff comments on the Registration Statement, or changes made
 in response to those comments, do not foreclose the Commission from taking any action with
 respect to the filing.

 3. No
 Defence Based on Staff Comments. The Company may not assert Staff comments, or the absence
 of comments, as a defense in any proceeding initiated by the Commission or any person under
 the federal securities laws of the United States.

 Thank
you for your attention to this matter.

 Very
 truly yours,

 Fooi
 Chen, Chai

 Chief
 Executive Officer

 cc:
 Jackson
 L. Morris

CORRESP
 1
 filename1.htm

 Office
of Trade & Services

 Division
of Corporation Finance

 US
Securities and Exchange Commission

 Washington,
DC 20549

 Re:
 Radiant
 Strategies Corp Registration Statement on Form S-1 Filed October 23, 2025

 File
No. 333-288165

 Amendment
No. 3

 Ladies
and Gentlemen:

 Radiant
Strategies Corp (the "Company") respectfully submits this letter to follow up on the status of our Registration Statement
on Form S-1.

 1.
 We
 acknowledge the latest comment letter issued by the Staff of the Securities and Exchange Commission ("SEC") dated August
 22, 2025. In response, the Company filed Amendment No. 2 to Form S-1, together with a correspondence letter addressing each of the
 Staff's comments, on August 28, 2025.

 2.
 We
 understand that due to the U.S. government shutdown, the SEC Staff may have been unable to respond within the usual review timelines.
 In the interest of keeping our filing current, the Company subsequently filed Amendment No. 3 to Form S-1 to update our financial
 statements through July 31, 2025, replacing the stale financial period included in our prior submission.

 3.
 We
 kindly request an update regarding the status of the effectiveness of our Registration Statement. We would greatly appreciate it
 if the Staff could provide a notice of effectiveness at its earliest convenience, if appropriate.

 We
thank the Staff for their time and continued assistance. Please do not hesitate to contact us should any additional information or clarification
be required.

 Very
 truly yours,

 /s/
 Fooi Chen, Chai

 Fooi
 Chen, Chai

 Chief
 Executive Officer

 cc:

 Jackson
 L. Morris

CORRESP
1
filename1.htm

Office
of Trade & Services

Division
of Corporation Finance

US
Securities and Exchange Commission

Washington,
DC 20549

    Re:
    Radiant
    Strategies Corp Registration Statement on Form S-1 Filed July 28, 2025

File
No. 333-288165

Amendment
No. 2

Filed
August 28, 2025

Ladies
and Gentlemen:

Thank
you for your comment letter dated August 22, 2025 on the above referenced registration statement. This letter accompanies amendment no.
2, responsive to your comments. Each of your specific comments are repeated below, followed by the registrant’s responses
to your comments. The registrant is also submitting a “red lined” copy of the amendment, indicating all insertions and deletions
as compared to the original filing.

Amendment
No. 1 to Registration Statement on Form S-1 filed July 28, 2025 Industry Overview, page 7

 1. We
                                            note your response to prior comment 3. We also note your reference to an article about your
                                            industry and the IPRM website. Where you disclose a fact please cite the related reports,
                                            articles, or other sources that support your statement. Alternatively, if a statement is
                                            based upon management’s belief, please indicate that this is the case and include an
                                            explanation for the basis of such belief.

Response:
We have revised industry overview on page 7. The updated disclosure now cites specific reports, articles, and external links directly
within the relevant paragraphs to substantiate the statements presented. In instances where information reflects management’s belief
rather than third-party data, we have clearly indicated this and included the basis for such belief

Our
Business, page 7

 2. We
                                            note your amended disclosure in response to prior comment 4 and we reissue it in part. Please
                                            revise your disclosure to elaborate further on your current operations and revenue-generating
                                            activity. Refer to Item 101(h)(4) of Regulation S-K.

Response:
We have revised our business on page 7 to further elaborate on our current operations and revenue-generating activities, including details
on our PR advisory services, target client base, methods of client engagement, and sources of revenue.

    Very
    truly yours,

    Fooi
    Chen, Chai

    Chief
    Executive Officer

    cc:

    Jackson
    L. Morris

August 22, 2025
Fooi Chen Chai
Chief Executive Officer
Radiant Strategies Corp
No.15, Jalan 17/42, Taman Kok Doh, Segambut 51200
Kuala Lumpur, Malaysia
Re:Radiant Strategies Corp
Amendment No. 1 to Registration Statement on Form S-1
Filed July 28, 2025
File No. 333-288165
Dear Fooi Chen Chai:
            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 17, 2025 letter.
Amendment No. 1 to Registration Statement on Form S-1 filed July 28, 2025
Industry Overview, page 7
1.We note your response to prior comment 3. We also note your reference to an article
about your industry and the IPRM website. Where you disclose a fact please cite the
related reports, articles, or other sources that support your statement. Alternatively, if
a statement is based upon management's belief, please indicate that this is the case and
include an explanation for the basis of such belief.
Our Business, page 7
2.We note your amended disclosure in response to prior comment 4 and we reissue it in
part. Please revise your disclosure to elaborate further on your current operations and
revenue-generating activity. Refer to Item 101(h)(4) of Regulation S-K.

August 22, 2025
Page 2
            Please contact Blaise Rhodes at 202-551-3774 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related
matters. Please contact Scott Anderegg at 202-551-3342 or Cara Wirth at 202-551-7127 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Jackson L. Morris

CORRESP
1
filename1.htm

Office
of Trade & Services

Division
of Corporation Finance

US
Securities and Exchange Commission

Washington,
DC 20549

Attn:
Scott Anderegg and Dara Wirth

Re: Radiant
                                            Strategies Corp Registration Statement on Form S-1 Filed June 20, 2025

                                                                                File
                                            No. 333-288165

                                                                                Amendment
                                            No. 1

                                                                                Filed
                                            July 28, 2025

Ladies
and Gentlemen:

Thank
you for your comment letter dated July 17, 2025 on the above referenced registration statement. This letter accompanies amendment no.
1, responsive to your comments. Each of your specific comments are repeated below, followed by the registrant’s responses to your
comments. The registrant is also submitting a “red lined” copy of the amendment, indicating all insertions and deletions
as compared to the original filing

Registration
Statement on Form S-1 filed June 20, 2025

Prospectus Summary, page 1

1. Please
                                            add a Prospectus Summary, compliant with Item 503 of Regulation S-K. In the summary, please
                                            also revise to state that:

 ● Ms.
                                            Chai will have the ability to determine all matters requiring approval by stockholders, including
                                            the election of directors, amendment of organizational documents, and approval of major corporate
                                            transactions, such as a change in control, merger, consolidation, or sale of assets;

 ● you
                                            have minimal operations, revenues, and customers to date; and

 ● as
                                            disclosed on page 2, you do not have the financial resources required to operate as a public
                                            company.

Response:
we have added a Prospectus Summary and included necessary information as outlined.

Estimated
Dilution to Purchasers of Our Common Stock, page 5

2. Reference
                                            is made to your disclosure that expenses of the offering will be $20,000 in the previous
                                            tables. Please tell us why these expenses were not considered in your table of estimated
                                            dilution at the bottom of page 5.

Response:
we have revised the dilution table to take into account of offering expenses on page 5.

Industry
Overview, page 7

3. Please
revise to include sources for the claims that you make in this section.

Response:
we have revised to include sources on page 7.

Our
Business, page 7

4. Please
                                            revise your disclosure here and throughout the registration statement to more clearly articulate
                                            the status of your operations and revenue-generating activity, including clear disclosure
                                            of any services or plans that are aspirational. Additionally, we note your disclosure on
                                            page F-11 that you have two customers and you disclose on page 4 the risks associated with
                                            your customers reducing or terminating their contracts. Please revise to describe the material
                                            terms of such contracts and file them as exhibits. Refer to Item 601(b)(10) of Regulation
                                            S-K.

Response:
All services discussed are not aspirational, we are actively serving customers. We have revised to our disclosure to distinguish
the difference of revenue from advisory and publishing in terms of pricing and highlighted our up-to-date revenue from these 2 sources
of revenue on page 7. In addition, we also highlighted the material terms of our service agreement and file sample of service
agreement as exhibit.

Related
Party Transactions and Relationships, page 10

5. Please
                                            clarify whether the $2,200 contributed by Ms. Chai was a loan and if so, whether it is interest-bearing
                                            with repayment terms. Additionally, please include the value of the executive office and
                                            business space provided to the company by Ms. Chai.

Response:
We have revised our disclosure on page 10 to state that the $2,200 contributed by Ms. Chai was a consideration for issuance of 22,000,000
shares of common stock at par value $0.0001 per share, and highlighted the acquisition of Radiant PR Solutions Sdn Bhd equity interest
and include the estimate market rental value of the executive office.

Description
of Securities, page 11

6. We
                                            note your statement that your description of common stock is “qualified in its entirety
                                            by reference to our Articles of Incorporation, as amended, our bylaws and Florida corporation
                                            law.” However, your organizational documents state that you are a Nevada corporation.
                                            Please revise for consistency.

Response:
We have revised our disclosure on page 11.

2.
Summary of Significant Accounting Policies

Revenue Recognition, page F-7

7. You
                                            disclose here that revenue is generated through website development and design services to
                                            customers. On page 6 you disclose that revenue was generated from providing advisory services
                                            to support clients’ public relations and communication efforts and drafting, editing, and
                                            publishing of press releases on various news channels and social media platforms. Please
                                            reconcile these disclosures for us and revise your disclosure for consistency. In addition,
                                            revise this note to provide disclosure pursuant to ASC 606-10-50-12 and 606-10-50-17 through
                                            19.

Response:
We have revised our disclosure on page F-7 to discuss details in our revenue recognition process.

Notes
to Condensed Consolidated Financial Statements

1.
Organization and Business Background, page F-7

8. We
                                            note your acquisition of 100% of the equity interest of Radiant PR Solutions Sdn. Bhd. on
                                            February 25, 2025. Please expand your disclosures in the notes to address the requirements
                                            of ASC 805-10-50-2(d) through 2(f) or ASC 805-50-50-1 through 4, as applicable.

Response:
We have revised our disclosure on page F-9 to include a note to discuss the acquisition of Radiant PR Solutions Sdn. Bhd., outline the
method and measurement of acquisition.

Item
16. Exhibits and Financial Statement Schedules, page II-1

9. Please
                                            file as an exhibit a specimen stock certificate and any other instruments defining the rights
                                            of shareholders. Refer to Item 601(b)(4) of Regulation S-K.

Response:
We have revised our disclosure on page 11 to stated that we do not have a transfer agent and we do not issue any stock certificate
at the moment, and we may authorize shares to be issued without certificates. We have included a sample of subscription agreement
as exhibit.

General

10. It
                                            appears that your officer and director is a non-U.S. resident. If applicable, in an appropriately
                                            captioned subsection of the business section, or in the risk factor section, please disclose
                                            an investor’s ability:

 ● to
                                            effect service of process within the United States against your non-U.S. resident officer
                                            and director;

 ● to
                                            enforce U.S. court judgments based upon the civil liability provisions of the U.S.
federal securities laws against the above referenced foreign person in the United States;

 ● to
                                            enforce in a Malaysian court, a U.S. court judgment based on the civil liability provisions
                                            of the U.S. federal securities laws against the above foreign person; and

 ● to
                                            bring an original action in a Malaysian court to enforce liabilities based upon the U.S.
                                            federal securities laws against the above foreign person.

Response:
We have revised to include such risk into our risk factor on Page 2.

Very truly yours,

    /s/ Fooi Chen, Chai

    Chief
                                            Executive Officer

    cc:
    Jackson
    L. Morris

July 17, 2025
Fooi Chen Chai
Chief Executive Officer
Radiant Strategies Corp
No.15, Jalan 17/42, Taman Kok Doh, Segambut 51200
Kuala Lumpur, Malaysia
Re:Radiant Strategies Corp
Registration Statement on Form S-1
Filed June 20, 2025
File No. 333-288165
Dear Fooi Chen Chai:
            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 20, 2025
Prospectus Summary, page 1
1.Please add a Prospectus Summary, compliant with Item 503 of Regulation S-K. In the
summary, please also revise to state that:
•Ms. Chai will have the ability to determine all matters requiring approval by
stockholders, including the election of directors, amendment of organizational
documents, and approval of major corporate transactions, such as a change in
control, merger, consolidation, or sale of assets;
•you have minimal operations, revenues, and customers to date; and
•as disclosed on page 2, you do not have the financial resources required to operate
as a public company.

July 17, 2025
Page 2
Estimated Dilution to Purchasers of Our Common Stock, page 5
2.Reference is made to your disclosure that expenses of the offering will be $20,000 in
the previous tables. Please tell us why these expenses were not considered in your
table of estimated dilution at the bottom of page 5.
Industry Overview, page 7
3.Please revise to include sources for the claims that you make in this section.
Our Business, page 7
4.Please revise your disclosure here and throughout the registration statement to more
clearly articulate the status of your operations and revenue-generating activity,
including clear disclosure of any services or plans that are aspirational. Additionally,
we note your disclosure on page F-11 that you have two customers and you disclose
on page 4 the risks associated with your customers reducing or terminating their
contracts. Please revise to describe the material terms of such contracts and file them
as exhibits. Refer to Item 601(b)(10) of Regulation S-K.
Related Party Transactions and Relationships, page 10
5.Please clarify whether the $2,200 contributed by Ms. Chai was a loan and if so,
whether it is interest-bearing with repayment terms. Additionally, please include the
value of the executive office and business space provided to the company by Ms.
Chai.
Description of Securities, page 11
6.We note your statement that your description of common stock is "qualified in its
entirety by reference to our Articles of Incorporation, as amended, our bylaws and
Florida corporation law." However, your organizational documents state that you are a
Nevada corporation. Please revise for consistency.
2. Summary of Significant Accounting Policies
Revenue Recognition, page F-7
7.You disclose here that revenue is generated through website development and design
services to customers. On page 6 you disclose that revenue was generated from
providing advisory services to support clients' public relations and communication
efforts and drafting, editing, and publishing of press releases on various news
channels and social media platforms. Please reconcile these disclosures for us and
revise your disclosure for consistency. In addition, revise this note to provide
disclosure pursuant to ASC 606-10-50-12 and 606-10-50-17 through 19.
Notes to Condensed Consolidated Financial Statements
1. Organization and Business Background, page F-7
8.We note your acquisition of 100% of the equity interest of Radiant PR Solutions Sdn.
Bhd. on February 25, 2025. Please expand your disclosures in the notes to address the
requirements of ASC 805-10-50-2(d) through 2(f) or ASC 805-50-50-1 through 4, as
applicable.

July 17, 2025
Page 3
Item 16. Exhibits and Financial Statement Schedules, page II-1
9.Please file as an exhibit a specimen stock certificate and any other instruments
defining the rights of shareholders. Refer to Item 601(b)(4) of Regulation S-K.
General
10.It appears that your officer and director is a non-U.S. resident. If applicable, in an
appropriately captioned subsection of the business section, or in the risk factor
section, please disclose an investor's ability:

•to effect service of process within the United States against your non-U.S.
resident officer and director;

•to enforce U.S. court judgments based upon the civil liability provisions of the
U.S. federal securities laws against the above referenced foreign person in the
United States;

•to enforce in a Malaysian court, a U.S. court judgment based on the civil liability
provisions of the U.S. federal securities laws against the above foreign person;
and

•to bring an original action in a Malaysian court to enforce liabilities  based upon
the U.S. federal securities laws against the above foreign person.

            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 Blaise Rhodes at 202-551-3774 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related
matters. Please contact Scott Anderegg at 202-551-3342 or Cara Wirth at 202-551-7127 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Jackson L. Morris