SecProbe.io

CORRESP
 1
 filename1.htm

 Correspondence

Tradewinds Universal

 501 Mercury Ln

 Brea, CA 92821

 May 4, 2026

 Via EDGAR

 Division of Corporation Finance\Office of Manufacturing

 U.S. Securities and Exchange Commission

 100 F Street NE

 Washington, DC 20549

 Re:

 Tradewinds Universal
 Acceleration Request for Registration Statement on Form S-1/A
 File No. 333-293457

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended
(the "Act"), Tradewinds Universal (the "Company") hereby requests that the effective date and time of
the above-referenced registration statement (the "Registration Statement") be accelerated to May 6, 2026 at 10:00 a.m.,
Eastern Time or such later time or date as is practical.

 We hereby acknowledge that:

 ·
 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;

 ·
 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 federal securities laws of the United States.

 Thank you for your consideration.

 Sincerely,

 By:
 /s/ Andrew
 Read ,
 President Tradewinds Universal

CORRESP
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 filename1.htm

 CORRESP

 Correspondence

 Tradewinds Universal
501 Mercury Lane
Brea, CA 92821
855-434-4488
TradewindsUniversal.com

 February 24, 2026

 U.S. Securities and Exchange Commission
Division of Corporation Finance

 Re: Tradewinds Universal
Registration Statement on Form S-1
File No. 333-276233

 Dear Sir or Madam:

 In response to the Staff's correspondence dated
February 19, 2026, the Company hereby withdraws its request for acceleration of the effective date of the above-referenced Registration
Statement on Form S-1, which was originally filed on February 13, 2026.

 The Company respectfully requests that the Commission
not declare the Registration Statement effective until further notice.

 Please contact the undersigned with any questions
regarding this request.

 Sincerely,
/Andrew Read/
CEO

 Tradewinds Universal

CORRESP
 1
 filename1.htm

 Correspondence

Tradewinds Universal

 501 Mercury Ln

 Brea, CA 92821

 February 20, 2026

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporate Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 RE: Tradewinds Universal
 Registration Statement on Form S-1
 Filed February 13, 2026
 File No. 333-293457

 Ladies and Gentlemen:

 Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Tradewinds Universal (the "Company")
hereby requests that the above-captioned registration statement (the "Registration Statement") be declared effective at 4:00
p.m., Eastern Time, on Tuesday, February 24, 2026, or as soon thereafter as may be practicable.

 We acknowledge that a declaration
by the Securities and Exchange Commission (the "Commission") or the staff, acting pursuant to delegated authority, that the
Registration Statement is effective does not foreclose the Commission from taking any action with respect to the Registration Statement.
We further acknowledge that such a declaration of effectiveness does not relieve the Company from our full responsibility for the adequacy
and accuracy of the disclosure in the Registration Statement. We understand that we may not assert staff comments to the Registration
Statement or the declaration of effectiveness by the Commission as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

 Should you have any questions
regarding this matter or need any additional information, please contact the Company's legal counsel, Mont E Tanner Esq. at (702)
369-9614.

 Sincerely,

 /s/ Andrew Read

 ________________________________________

 Andrew Read

 Chief Executive Officer

 cc: Mont E Tanner Esq.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 February 19, 2026

Andrew Read
Chief Executive Officer
Tradewinds Universal
501 Mercury Lane
Brea, CA 92821

 Re: Tradewinds Universal
 Registration Statement on Form S-1
 Filed February 13, 2026
 File No. 333-293457
Dear Andrew Read:

 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 Jenny O'Shanick at 202-551-8005 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
cc: Mont E Tanner
</TEXT>
</DOCUMENT>

CORRESP
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Tradewinds Universal

501 Mercury Lane

Brea, CA. 92821

855-434-4488

July 12, 2024

Via EDGAR

Eranga Dias

Geoffrey Erlanger

Division of Corporation Finance\Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street NE

Washington, DC 20549

    Re:

    Tradewinds Universal

    Acceleration Request for Registration Statement on Form S-1

    File No. 333-276233

Dear Eranga Dias and Geoffrey Erlanger

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the
“Act”), Tradewinds Universal (the “Company”) hereby requests that the effective date and time of the above-referenced
registration statement (the “Registration Statement”) be accelerated to July 17, 2024, at 10:00 a.m., Eastern Time or such
later time or date as is practical.

We hereby acknowledge that:

    •
    Should the Commission of 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;

    •
    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 federal securities laws of the United States.

Thank you for your consideration.

    Sincerely,

    By:
    /s/  Andrew Read, President Tradewinds Universal

CORRESP
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Tradewinds Universal

501 Mercury Lane

Brea, CA. 92821

855-434-4488

July 12, 2024

Via EDGAR

Eranga Dias

Geoffrey Erlanger

Division of Corporation Finance\Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street NE

Washington, DC 20549

    Re:

    Tradewinds Universal

    Acceleration Request for Registration Statement on Form S-1

    File No. 333-276233

Dear Eranga Dias and Geoffrey Erlanger

Reference is made to our letter, filed as correspondence
via EDGAR on July 11, 2024 in which we requested the acceleration of the effective date of the above-referenced Registration Statement
for Friday, July 12, 2024, at 10 a.m. Eastern Time, in accordance with Rule 461 under the Securities Act of 1933, as amended. We are no
longer requesting that such Registration Statement be declared effective at this time and we hereby formally withdraw our request for
acceleration of the effective date.

Thank you for your consideration.

    Sincerely,

    By:
    /s/  Andrew Read, President Tradewinds Universal

CORRESP
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Correspondence

Tradewinds Universal

501 Mercury Lane

Brea, CA. 92821

855-434-4488

July 11, 2024

Via EDGAR

Eranga Dias

Geoffrey Erlanger

Division of Corporation Finance\Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street NE

Washington, DC 20549

    Re:

    Tradewinds Universal

    Acceleration Request for Registration Statement on Form S-1

    File No. 333-276233

Dear Eranga Dias and Geoffrey Erlanger

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the
“Act”), Tradewinds Universal (the “Company”) hereby requests that the effective date and time of the above-referenced
registration statement (the “Registration Statement”) be accelerated to July 12, 2024, at 10:00 a.m., Eastern Time or such
later time or date as is practical.

We hereby acknowledge that:

    •
    Should the Commission of 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;

    •
    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 federal securities laws of the United States.

Thank you for your consideration.

    Sincerely,

    By:
    /s/  Andrew Read, President Tradewinds Universal

July 1, 2024
Andrew Read
Chief Executive Officer
Tradewinds Universal
501 Mercury Lane
Brea, CA, 92821
Re:Tradewinds Universal
Amendment No. 3 to Registration Statement on Form S-1
Filed June 21, 2024
File No. 333-276233
Dear Andrew Read:
            We have reviewed your amended registration statement and have the following
comment(s).
            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 April 3, 2024 letter.
Amendment No. 3 to Registration Statement on Form S-1 filed June 21, 2024
General
1.We note your disclosure on page 10 regarding the distribution of the shares by the selling
shareholders.  Please confirm your understanding that the retention by a selling
shareholder of an underwriter would constitute a material change to your plan of
distribution requiring a post-effective amendment.  Refer to your undertaking provided
pursuant to Item 512(a)(1)(iii) of Regulation S-K.
            Please contact Dale Welcome at 202-551-3865 or Claire Erlanger at 202-551-3301 if you
have questions regarding comments on the financial statements and related matters. Please
contact Eranga Dias at 202-551-8107 or Geoffrey Kruczek at 202-551-3641 with any other
questions.

July 1, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
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Correspondence

Tradewinds Universal

501 Mercury Lane

Brea, CA. 92821

855-434-4488

TradewindsUniversal.com

Andrewreadtw@gmail.com

July 1, 2024

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. SECURITIES AND EXCHANGE COMMISSION

100 F Street, N.E.

Washington, DC 20549

Attention:  Eranga Dias

                                                                                Geoffrey Kruczek

RE:  Tradewinds Universal

                                                                                Registration Statement on Form S-1

                                                                                Filed December 22, 2023

                                                                                File No. 333-276233

Dear Ms. Dias and Mr. Kruczek:

We are hereby responding to the letter dated July 1, 2024 (the“Comment
Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission regarding the Company’s S-1 Registration
Statement Filed December 22, 2023, File No. 333-276233.

Amendment No. 3 to Registration Statement on Form S-1 filed June 21,
2024

General

1. We note your disclosure on page 10 regarding the distribution of the
shares by the selling shareholders. Please confirm your understanding that the retention by a selling shareholder of an underwriter would
constitute a material change to your plan of distribution requiring a post-effective amendment. Refer to your undertaking provided pursuant
to Item 512(a)(1)(iii) of Regulation S-K

RESPONSE:

We confirm that it is our understanding that the retention by a selling
shareholder of an underwriter would constitute a material change to our plan of distribution and would require a post-effective amendment
pursuant to Item 512(a)(1)(iii) of Regulation S-K.

Sincerely,

/s/ Andrew Read

President, Tradewinds Universal

CORRESP
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Correspondence

Tradewinds Universal

501 Mercury Lane

Brea, CA. 92821

855-434-4488

TradewindsUniversal.com

Andrewreadtw@gmail.com

June 20, 2024

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. SECURITIES AND EXCHANGE COMMISSION

100 F Street, N.E.

Washington, DC 20549

Attention:  Eranga Dias

                                                                                Geoffrey Kruczek

RE:  Tradewinds Universal

                                                                                Registration Statement on Form S-1

                                                                                Filed December 22, 2023

                                                                                File No. 333-276233

Dear Ms. Dias and Mr. Kruczek:

We are hereby responding to the letter dated April 3, 2024 (the“Comment
Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission regarding the Company’s S-1 Registration
Statement Filed December 22, 2023, File No. 333-276233.

For ease of reference, the text of the Staff’s comment is included
in boldface type below, followed by the Company’s response.

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

Financial Statements, page F-1

1. Please update your financial statements and related information. Refer
to Rule 8-08(b) of

Regulation S-X for guidance.

RESPONSE:

The S-1/A3 was updated to include the Financial Statements for 12-31-23
and 3-31-24.

Sincerely,

/s/ Andrew Read

President, Tradewinds Universal

United States securities and exchange commission logo
April 3, 2024
Andrew Read
Chief Executive Officer
Tradewinds Universal
501 Mercury Lane
Brea, CA, 92821
Re:Tradewinds Universal
Amendment No. 2 to Registration Statement on Form S-1
Filed March 25, 2024
File No. 333-276233
Dear Andrew Read:
            We have reviewed your amended registration statement and have the following
comment(s).
            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 February 27, 2024 letter.
Amendment No. 2 to Registration Statement on Form S-1
Financial Statements, page F-1
1.Please update your financial statements and related information. Refer to Rule 8-08(b) of
Regulation S-X for guidance.
            Please contact Dale Welcome at 202-551-3865 or Claire Erlanger at 202-551-3301 if you
have questions regarding comments on the financial statements and related matters. Please
contact Eranga Dias at 202-551-8107 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,

 FirstName LastNameAndrew Read
 Comapany NameTradewinds Universal
 April 3, 2024 Page 2
 FirstName LastName
Andrew Read
Tradewinds Universal
April 3, 2024
Page 2
Division of Corporation Finance
Office of Manufacturing

CORRESP
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filename1.htm

Tradewinds
Universal

501
Mercury Lane

Brea, CA. 92821

855-434-4488

TradewindsUniversal.com

Andrewreadtw@gmail.com

March
25, 2024

Via
EDGAR

Division
of Corporation Finance

Office
of Manufacturing

U.S.
SECURITIES AND EXCHANGE COMMISSION

100
F Street, N.E.

Washington,
DC 20549

Attention:  Eranga Dias

                                                                                Geoffrey Kruczek

RE:  Tradewinds Universal

                                                                                Registration Statement on Form S-1

                                                                                Filed December 22, 2023

                                                                                File No. 333-276233

Dear
Ms. Dias and Mr. Kruczek:

We
are hereby responding to the letter dated February 27, 2024 (the“Comment Letter”) from the staff (the “Staff”)
of the Securities and Exchange Commission regarding the Company’s Amendment No. 1 to S-1 Registration Statement Filed on February
14, 2024, File No. 333-276233.

For
ease of reference, the text of the Staff’s comment is included in boldface type below, followed by the Company’s response.

Amendment
1 to Registration Statement on Form S-1 Filed February 14, 2024 Certain Relationships, page 22

1.
We note your response to prior comment 2; however, the first two bullets of this section continue to use transaction thresholds that
are inconsistent with the requirements of Item 404(d) of Regulation S-K. Please revise.

Response
The section referred to is revised according to your comments.

General

2.
We reissue previous comment 5 in its entirety. Please revise your management's discussion and analysis section according to previous
comment 5 and identify the revisions made.

Response:
We have revised the Management’s Discussion and Analysis of Financial Condition and Results of Operations section in its entirety.

3.
We note your response to previous comment 6 and reissue comment 6. Please revise your disclosure to fully address the comment, including,
but not limited to, describing the material terms of your agreement with the third party who conducts the manufacturing. Also clarify
what you mean by the statement that you are "currently in production" for the manufacturing of your product.

Response:
We have revised the Management’s Discussion and Analysis of Financial Condition and Results of Operations section in its entirety
per your comments.

Sincerely,

/s/
Andrew Read

President,
Tradewinds Universal

United States securities and exchange commission logo
February 27, 2024
Andrew Read
Chief Executive Officer
Tradewinds Universal
501 Mercury Lane
Brea, CA, 92821
Re:Tradewinds Universal
Amendment No. 1 to Registration Statement on Form S-1
Filed February 14, 2024
File No. 333-276233
Dear Andrew Read:
            We have reviewed your amended registration statement and have the following
comment(s).
            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 January 17, 2024 letter.
Amendment 1 to Registration Statement on Form S-1 Filed February 14, 2024
Certain Relationships, page 22
1.We note your response to prior comment 2; however, the first two bullets of this section
continue to use transaction thresholds that are inconsistent with the requirements of Item
404(d) of Regulation S-K.  Please revise.
General
2.We reissue previous comment 5 in its entirety. Please revise your management's
discussion and analysis section according to previous comment 5 and identify the
revisions made.
3.We note your response to previous comment 6 and reissue comment 6. Please revise your
disclosure to fully address the comment, including, but not limited to, describing the

 FirstName LastNameAndrew Read
 Comapany NameTradewinds Universal
 February 27, 2024 Page 2
 FirstName LastName
Andrew Read
Tradewinds Universal
February 27, 2024
Page 2
material terms of your agreement with the third party who conducts the
manufacturing. Also clarify what you mean by the statement that you are "currently in
production" for the manufacturing of your product.
            Please contact Dale Welcome at 202-551-3865 or Claire Erlanger at 202-551-3301 if you
have questions regarding comments on the financial statements and related matters. Please
contact Eranga Dias at 202-551-8107 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
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filename1.htm

Correspondence

Tradewinds Universal

501 Mercury Lane

Brea, CA. 92821

855-434-4488

TradewindsUniversal.com

Andrewreadtw@gmail.com

February 14, 2024

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. SECURITIES AND EXCHANGE COMMISSION

100 F Street, N.E.

Washington, DC 20549

Attention:  Eranga Dias

                                                                                Geoffrey Kruczek

RE:  Tradewinds Universal

                                                                                Registration Statement on Form S-1

                                                                                Filed December 22, 2023

                                                                                File No. 333-276233

Dear Ms. Dias and Mr. Kruczek:

We are hereby responding to the letter dated January 17, 2024 (the“Comment
Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission regarding the Company’s S-1 Registration
Statement Filed December 22, 2023, File No. 333-276233.

For ease of reference, the text of the Staff’s comment is included
in boldface type below, followed by the Company’s response.

Registration Statement on Form S-1

Risk Factors

Our auditors have issued a going concern opinion, page 5

1. Your disclosure states that “our auditors have issued a going
concern opinion on our audited financial statements…” However, the auditor’s report on page F-2 does not contain a
going concern paragraph. Please revise your registration statement as appropriate.

Response The paragraph relating to going concern was deleted on Page 5.

Directors, Executive Officers, Promoters and Control Persons, page 20

2. Please revise this section to provide disclosure required by paragraphs
(a) and (e)(4) of Item 407 of Regulation S-K, or tell us why you are not required to do so. See paragraphs (l) and (n) of Item 11 of
Form S-1.

RESPONSE:

We have revised the section per your comments.

Employment Agreements, page 20

3. Reconcile your disclosure about no employment agreements with Exhibit
10.1 and disclosure on page II-3.

RESPONSE: Correction was made on Page 20. An amended employment agreement
is attached as an exhibit.

Certain Relationships, page 22

4. Please revise to provide disclosure consistent with the thresholds
in Item 404(d) of Regulation S-K.

RESPONSE:

We have revised the section per your comments.

Management's Discussion and Analysis of Financial Condition and Results
of Operations, page

24

5. Please revise this section to substantially expand your management's
discussion and analysis to include information required by Item 303 of Regulation S-K. This section should provide disclosure in the
form of a discussion and analysis from management's perspective and should not merely contain factual statements about your company and
its operations. Provide the discussion and analysis in a format that facilitates easy understanding and that supplements, and does not
merely duplicate, disclosure already provided in the filing. The objective of the discussion and analysis is to provide material information
relevant to an assessment of the financial condition and results of operations of Tradewinds Universal including an evaluation of the
amounts and certainty of cash flows from operations and from outside sources. A discussion and analysis that meets the requirements of
Item 303 of Regulation S-K is expected to better allow investors to view Tradewinds Universal from management's perspective.

RESPONSE:

We have revised the section per your comments.

Management's Discussion and Analysis, page 24

6. Please update the disclosure on page 24 regarding the initiation
of sales in the fourth quarter of 2023. Please also clarify what you mean by the statement that you are "currently in production"
for the manufacture of your product. Describe the material terms of your agreement with the third party who conducts the manufacturing,
the sources and availability of the raw materials and how you intend to distribute your product.

RESPONSE:

Management's Discussion and Analysis was revised per your comments.

Exhibits

7. Because this Form S-1 purports to register the resale of common
stock, the legal opinion you file must opine that the shares are validly issued, fully paid and non-assessable. Currently, your opinion
states that the shares "will when sold" be validly issued, fully paid and non-assessable. Please file a revised opinion.

RESPONSE:

The Opinion was revised and attached as an exhibit.

General

8. In the second paragraph on the prospectus cover page, you disclose
that the selling shareholders will resell at a fixed price of $0.01 per share, contrary to your disclosure elsewhere regarding a $0.40
price per share. Please reconcile.

RESPONSE: Adjusted per comment

9. Please update your compensation disclosure for the year ended December
31, 2023.

RESPONSE:

Compensation disclosure was updated per your comment on page 20 and page
22.

Sincerely,

/s/ Andrew Read

President, Tradewinds Universal

United States securities and exchange commission logo
January 17, 2024
Andrew Read
Chief Executive Officer
Tradewinds Universal
501 Mercury Lane
Brea, CA, 92821
Re:Tradewinds Universal
Registration Statement on Form S-1
Filed December 22, 2023
File No. 333-276233
Dear Andrew Read:
            We have reviewed your registration statement and have the following comment(s).
            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
Risk Factors
Our auditors have issued a going concern opinion, page 5
1.Your disclosure states that “our auditors have issued a going concern opinion on our
audited financial statements…” However, the auditor’s report on page F-2 does not
contain a going concern paragraph. Please revise your registration statement as
appropriate.
Directors, Executive Officers, Promoters and Control Persons, page 20
2.Please revise this section to provide disclosure required by paragraphs (a) and (e)(4) of
Item 407 of Regulation S-K, or tell us why you are not required to do so. See paragraphs
(l) and (n) of Item 11 of Form S-1.

 FirstName LastNameAndrew Read
 Comapany NameTradewinds Universal
 January 17, 2024 Page 2
 FirstName LastName
Andrew Read
Tradewinds Universal
January 17, 2024
Page 2
Employment Agreements, page 20
3.Reconcile your disclosure about no employment agreements with Exhibit 10.1 and
disclosure on page II-3.
Certain Relationships, page 22
4.Please revise to provide disclosure consistent with the thresholds in Item 404(d) of
Regulation S-K.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
24
5.Please revise this section to substantially expand your management's discussion and
analysis to include information required by Item 303 of Regulation S-K. This section
should provide disclosure in the form of a discussion and analysis from management's
perspective and should not merely contain factual statements about your company and its
operations. Provide the discussion and analysis in a format that facilitates easy
understanding and that supplements, and does not merely duplicate, disclosure already
provided in the filing. The objective of the discussion and analysis is to provide material
information relevant to an assessment of the financial condition and results of operations
of Tradewinds Universal including an evaluation of the amounts and certainty of cash
flows from operations and from outside sources. A discussion and analysis that meets the
requirements of Item 303 of Regulation S-K is expected to better allow investors to view
Tradewinds Universal from management's perspective.
Management's Discussion and Analysis, page 24
6.Please update the disclosure on page 24 regarding the initiation of sales in the fourth
quarter of 2023.  Please also clarify what you mean by the statement that you are
"currently in production" for the manufacture of your product.  Describe the material
terms of your agreement with the third party who conducts the manufacturing, the sources
and availability of the raw materials and how you intend to distribute your product.
Exhibits
7.Because this Form S-1 purports to register the resale of common stock, the legal opinion
you file must opine that the shares are validly issued, fully paid and non-assessable.
Currently, your opinion states that the shares "will when sold" be validly issued, fully paid
and non-assessable.  Please file a revised opinion.
General
8.In the second paragraph on the prospectus cover page, you disclose that the selling
shareholders will resell at a fixed price of $0.01 per share, contrary to your disclosure
elsewhere regarding a $0.40 price per share.  Please reconcile.

 FirstName LastNameAndrew Read
 Comapany NameTradewinds Universal
 January 17, 2024 Page 3
 FirstName LastName
Andrew Read
Tradewinds Universal
January 17, 2024
Page 3
9.Please update your compensation disclosure for the year ended December 31, 2023.
            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 Dale Welcome at 202-551-3865 or Claire Erlanger at 202-551-3301 if you
have questions regarding comments on the financial statements and related matters. Please
contact Eranga Dias at 202-551-8107 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing