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 March 31, 2025

Roman Zhezhel
President
Alixo-Yolloo Corp.
Business Center Sunkar
Building 47B, Aktau
130002 Kazakhstan

 Re: Alixo-Yolloo Corp.
 Form 10-K and Form 10-K/A for the Year Ended February 29, 2024
 File No. 333-272825
Dear Roman Zhezhel:

 We have completed our review of your filing. 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.

 Sincerely,

 Division of Corporation
Finance
 Office of Technology
</TEXT>
</DOCUMENT>

CORRESP
1
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Converted by EDGARwiz    February 7, 2025

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Technology

 100 F Street, N.E.

 Washington, D.C. 20549-4561

 Re: Alixo-Yolloo Corp.
Form 10-K for the Year Ended February 29, 2024

 File No. 333-272825

 Dear Melissa Kindelan and Kathleen Collins:

 Enclosed please find our response to the comments of the staff of the Commission set forth in your letters dated December 17, 2024 with respect to ALIXO-YOLLOO CORPORATION (the “Company”). This response addresses comments to the Form 10-K for the fiscal year ended February 29, 2024 and an audit report for the year ended February 28, 2023.

  The responses below have been organized in the same order the Commission’s comments were organized.

 Form 10-K for the Year Ended February 29, 2023

 Report of Independent Registered Public Accounting Firm, page 13

 1. Please amend your filing to include an audit report for the company which is compliant with Public Company Accounting Oversight Board (“PCAOB”) standards for the year ended February 28, 2023. In this regard, please note that the PCAOB revoked the registration of your prior auditor, Gries & Associates, LLC. You can find a copy of the order on the PCAOB’s website at https://assets.pcaobus.org/pcaob- dev/docs/default-source/enforcement/decisions/documents/105-2024-011- gries.pdf?sfvrsn=b9b25830_4. As this auditor is no longer registered with the PCAOB, you may not include their audit reports or consents in your filings with the Commission on or after the date of deregistration. Therefore, you should have a firm that is currently registered with the PCAOB re-audit the impacted years that are required to be included in your filings with the Commission.

 RESPONSE:

 The Company is re-auditing the Form 10-K to ensure the inclusion of a report from a firm currently registered with the PCAOB. The Company plans to file a 10-K/A for the fiscal year ended February 29, 2024, including an audit report for the year ended February 28, 2023, within 45 days of this letter's date.

                                                                                                  ALIXO-YOLLO CORPORATION

 By: /s/ Roman Zhezhel

                                                                                                          Roman Zhezhel,

 Chief Financial Officer/

 Chief Accounting Officer/Director

 Principle Financial Officer

CORRESP
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filename1.htm

January 10, 2024

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, D.C. 20549-4561

Re: Alixo-Yolloo Corp.

Form 10-K for the Year Ended February 29, 2024

File No. 333-272825

Dear Melissa Kindelan and Kathleen Collins:

Enclosed please find our response to the comments
of the staff of the Commission set forth in your letters dated December 17, 2024 with respect to ALIXO-YOLLOO CORPORATION (the “Company”).
This response addresses comments to the Form 10-K for the fiscal year ended February 29, 2024.

The responses below have
been organized in the same order the Commission’s comments were organized.

Form 10-K for the Year Ended
February 29, 2024

Report of Independent Registered
Public Accounting Firm, page 13

1. Please amend your filing
to include an audit report for the company which is compliant with Public Company Accounting Oversight Board (“PCAOB”) standards
for the year ended February 28, 2023. In this regard, please note that the PCAOB revoked the registration of your prior auditor, Gries
& Associates, LLC. You can find a copy of the order on the PCAOB’s website at https://assets.pcaobus.org/pcaob- dev/docs/default-source/enforcement/decisions/documents/105-2024-011-
gries.pdf?sfvrsn=b9b25830_4. As this auditor is no longer registered with the PCAOB, you may not include their audit reports or consents
in your filings with the Commission on or after the date of deregistration. Therefore, you should have a firm that is currently registered
with the PCAOB re-audit the impacted years that are required to be included in your filings with the Commission.

RESPONSE:

The Company is re-auditing the Form 10-K to ensure
the inclusion of a report from a firm that maintains current registration with the PCAOB.

ALIXO-YOLLO CORPORATION

By:	/s/ Roman Zhezhel

Roman Zhezhel,

Chief Financial Officer/

Chief Accounting Officer/Director

Principle Financial Officer

December 17, 2024
Roman Zhezhel
President
Alixo-Yolloo Corp.
Business Center Sunkar
Building 47B, Aktau
130002 Kazakhstan
Re:Alixo-Yolloo Corp.
Form 10-K for the Year Ended February 29, 2024
File No. 333-272825
Dear Roman Zhezhel:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe the
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Year Ended February 29, 2024
Report of Independent Registered Public Accounting Firm, page 13
1.Please amend your filing to include an audit report for the company which is
compliant with Public Company Accounting Oversight Board (“PCAOB”) standards
for the year ended February 28, 2023. In this regard, please note that the PCAOB
revoked the registration of your prior auditor, Gries & Associates, LLC. You can find
a copy of the order on the PCAOB’s website at https://assets.pcaobus.org/pcaob-
dev/docs/default-source/enforcement/decisions/documents/105-2024-011-
gries.pdf?sfvrsn=b9b25830_4. As this auditor is no longer registered with the
PCAOB, you may not include their audit reports or consents in your filings with the
Commission on or after the date of deregistration. Therefore, you should have a firm
that is currently registered with the PCAOB re-audit the impacted years that are
required to be included in your filings with the Commission.

December 17, 2024
Page 2
            In closing, 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 Melissa Kindelan at 202-551-3564 or Kathleen Collins at 202-551-
3499 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
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ALIXO-YOLLOO CORPORATION

Business Center Sunkar,
Building 47B, Aktau

130002 Kazakhstan

October 13, 2023

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC  20549-5561

    Re:
    ALIXO-YOLLOO CORPORATION

    REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933

    Registration No.  333-272825

Request For Acceleration of Effectiveness

Dear Edwin S. Kim,

Pursuant
Rule 461 promulgated under the Securities Act of 1933, as amended, ALIXO-YOLLOO CORPORATION (the “Registrant”) hereby
requests an acceleration of the effective date of the above-referenced Registration Statement
so that it will become effective at 05:00 p.m., Eastern time, on Friday, October 13, 2023 or as soon as possible thereafter.

The Registrant confirms that it is aware of its obligations under the Act.

The Registrant hereby acknowledges that:

(i) should the Securities and Exchange Commission
(the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective,
it does not foreclose the Commission from taking any action with respect to the Registration Statement;

(ii) the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full
responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

(iii) the Registrant may not assert comments of the Commission
or the staff and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

Please
contact Roman Zhezhel, Director, at
(252)-34-66-180 with any questions you may have concerning this request.

    Sincerely,

    ALIXO-YOLLOO CORPORATION

By: /s/ Roman Zhezhel

Name: Roman Zhezhel

Title: Director, President, Treasurer and Secretary

(Principal Executive, Financial and Accounting Officer)

By: /s/ Rassul
Sadukbayev

Name: Rassul
Sadukbayev

Title: Director

United States securities and exchange commission logo
September 21, 2023
Roman Zhezhel
President
Alixo-Yolloo Corporation
1065 SW 8th St
Miami, FL 33130
Re:Alixo-Yolloo Corporation
Amendment No. 2 to Registration Statement on Form S-1
Filed August 31, 2023
File No. 333-272825
Dear Roman Zhezhel:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No 2 to Form S-1
Signatures, page 66
1.We note that you have two directors but only one director has signed the registration
statement.  Please note that the registration statement must be signed by at least a majority
of the board of directors.  See Instruction 1 to Signatures in Form S-1.
Exhibits
2.Your legality opinion filed as Exhibit 5.1 relates to 5,000,000 shares of common stock
being offered by the selling shareholders.  This registration statement is for the initial
offering of common stock by the company.  Please file a revised opinion that indicates, if
true, that the shares of common stock when issued will be validly issued, fully paid and
non-assessable.

 FirstName LastNameRoman Zhezhel
 Comapany NameAlixo-Yolloo Corporation
 September 21, 2023 Page 2
 FirstName LastName
Roman Zhezhel
Alixo-Yolloo Corporation
September 21, 2023
Page 2
            You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments
on the financial statements and related matters.  Please contact Edwin Kim, Staff Attorney, at
(202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Blaze Gries, CPA

United States securities and exchange commission logo
August 25, 2023
Roman Zhezhel
President
Alixo-Yolloo Corporation
1065 SW 8th St
Miami, FL 33130
Re:Alixo-Yolloo Corporation
Amendment No. 1 to Registration Statement on Form S-1
Filed August 11, 2023
File No. 333-272825
Dear Roman Zhezhel:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our July 19, 2023 letter.
Amendment No. 1 to Registration Statement on Form S-1
Risk Factors
We Solely Dependent Upon the Funds Raised In This Offering ..., page 11
1.You indicate on page 11 that "Mr. Sadakbayev has no formal commitment, arrangement,
or legal obligation to advance or loan funds to the company. "  Your loan agreement filed
as Exhibit 10.1, indicates that Mr. Sadakbayev "has agreed to loan the Loan Amount [up
to $43,000] to the Company in the event of not raising sufficient amount of funds from the
offering in accordance to the Form S-1 registration statement of the Company."  Please
revise to reconcile.

 FirstName LastNameRoman Zhezhel
 Comapany NameAlixo-Yolloo Corporation
 August 25, 2023 Page 2
 FirstName LastName
Roman Zhezhel
Alixo-Yolloo Corporation
August 25, 2023
Page 2
Management's Discussion and Analysis or Plan of Operation
Results of Operations, page 23
2.We note your response to prior comment 3 regarding the source of your revenue in fiscal
year 2022, which appears to be selling a piece of discontinued software for $2,245.  Please
incorporate this response into your registration statement in your Results of Operations
discussion.  Further, we note that your revenues for the fiscal quarter ended May 31, 2023
was $7,933.  Similarly, please disclose the source of this revenue given your mobile app
has not been monetized yet and has not generated revenue according to your response to
prior comment 4.
Description of Business, page 25
3.Please incorporate your response to prior comment 4 in your registration statement
regarding your business plan and the development of the app.  In particular, please
disclose that the Alixo app has not experienced any downloads or registered users.
            You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments
on the financial statements and related matters.  Please contact Edwin Kim, Staff Attorney, at
(202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Blaze Gries, CPA

United States securities and exchange commission logo
July 19, 2023
Roman Zhezhel
President
Alixo-Yolloo Corporation
1065 SW 8th St
Miami, FL 33130
Re:Alixo-Yolloo Corporation
Registration Statement on Form S-1
Filed June 22, 2023
File No. 333-272825
Dear Roman Zhezhel:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-1 filed June 22, 2023
Summary Financial Information, page 10
1.We note that total stockholder's deficit at February 28, 2023 in the table here does not
agree with total stockholders' equity in the balance sheet.  Please revise.
Risk Factors
Because Our Board of Directors Outside of the United States..., page 13
2.You state that your principal office is in Miami, FL but your principal operations are
located outside of the United States and your directors are not residents of the United
States.  Please disclose the location of your principal operations and the location of your
directors in the prospectus summary and risk factors.

 FirstName LastNameRoman Zhezhel
 Comapany NameAlixo-Yolloo Corporation
 July 19, 2023 Page 2
 FirstName LastName
Roman Zhezhel
Alixo-Yolloo Corporation
July 19, 2023
Page 2
Management's Discussion and Analysis or Plan of Operation
Results of Operations, page 23
3.We note that you generated $2,245 revenue in fiscal year 2022, but $0 revenue in fiscal
year 2023. Please clarify the nature of that revenue and if it is related to your ongoing
business of the Alixo app. or the API rental business.
Description of Business, page 25
4.We note that you refer to yourself as a development stage company on page 27 and that
your business plan includes continuously improving the user experience of your products
and services.  Please address the following:
•Clarify the completeness of the development of Alixo and whether it is still in the
beta or testing stage, or if it is available for full commercialization.
•Clarify whether there is a cost to currently download the Alixo app from Google Play
store or any application distributor.
•Clarify the number of downloads and registered users of your Alixo app.
•Clarify whether your API library currently exists and the size and scope of the APIs
currently available for rent.
•Clarify whether you must have an agreement with popular music streaming services
for your app. to operate, such as licenses for their APIs.
•Clarify how or who maintains, services, updates, or provides support for the Alixo
app or API rental service.
5.Please briefly describe how the Alixo app was developed.  We note, for example, that you
have nearly $35,000 in acquired intangible assets on your balance sheet.  Please clarify if
the Alixo app was developed internally, either by your founders or through a contractor,
or if it was primarily acquired.  If it was acquired, please describe the terms of that
acquisition as appropriate.
6.Please clarify the basis for your belief that the Alixo app “will be widely popular,”
“gaining popularity,” or “the app’s popularity will continue to rise.”  Provide actual user
or revenue information to support such assertions.
Director, Executive Officer, Promoter and Control Person, page 30
7.Please describe the role of your management as to the operations of your company.  Your
sole officer is listed as Roman Zhezhel, but you disclose that your director Rassul
Sadakbayev is responsible for all your operations.  Please clarify the role of Zhezhel in the
development and operation of your business.
8.Please revise your management biographies to clarify whether Mr. Zhezhel has any full-
time employment or business ventures that require a material amount of time outside of
his duties at Alixo-Yolloo.

 FirstName LastNameRoman Zhezhel
 Comapany NameAlixo-Yolloo Corporation
 July 19, 2023 Page 3
 FirstName LastName
Roman Zhezhel
Alixo-Yolloo Corporation
July 19, 2023
Page 3
Certain Relationships and Related Transactions, page 33
9.Please disclose whether Mr. Sadakbayev may demand repayment of his loans to you at
any time.  Also, clarify your disclosure that "Mr. Sadakbayev has no formal commitment,
arrangement, or legal obligation to advance or loan funds to the company."  We note that
you filed a loan agreement made in 2019 between the company and Mr. Sadakbayev.
Clarify whether the loan agreement is non-binding and/or whether the agreement has been
amended.
Plan of Distribution, page 34
10.You state that the offering will continue for one year (365 days) but state elsewhere that
the offering is for 240 days.  Please revise.
General
11.Please supplementally provide us with copies of all written communications, as defined
in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your
behalf, present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communications.
            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.
            You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments
on the financial statements and related matters.  Please contact Edwin Kim, Staff Attorney, at
(202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Blaze Gries, CPA