United States securities and exchange commission logo





                             April 7, 2021

       Raymond Firth
       Chief Executive Officer
       Findit, Inc.
       5051 Peachtree Corners Circle #200
       Peachtree Corners, GA 30092

                                                        Re: Findit, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed March 11,
2021
                                                            File No. 333-254128

       Dear Mr. Firth:

              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.

       Registration Statement on Form S-1 filed on March 11, 2021

       Use of Proceeds, page 19

   1.                                                   Please provide a
description of your estimated use of your net offering proceeds at the
                                                        varying levels of funds
raised. While we note that you will have discretion as to how net
                                                        offering proceeds are
used, please show how the funds will be allocated to implement
                                                        your growth and
business plans.
       Description of Business, page 28

   2.                                                   Please clarify the
amount of revenue that you generate through your Findit App and Findit
                                                        members, your CBD oil
business, and revenue for services unrelated to the Findit App or
                                                        CBD oil.
 Raymond Firth
FirstName
Findit, Inc. LastNameRaymond Firth
Comapany
April        NameFindit, Inc.
       7, 2021
April 27, 2021 Page 2
Page
FirstName LastName
3.       With respect to your Findit App, please clarify the number of
downloads of your Findit
         App, define the term Findit members, quantify the number of Findit
members, and
         disclose the number of Findit members who generated revenues in fiscal
year 2020.
         Further, please clarify how you determine if Findit members are active
members that
         regularly use your app and services.
4.       Your disclosure references the number of active users of several
social media websites
         and the market capitalizations of those companies. Please explain
whether you have a
         relationship with Facebook, Pinterest, Twitter, LinkedIn, Instagram
and Snapchat, and, if
         not, why you believe that this information is material to investors.
Management's Discussion and Analysis or Plan of Operation
Summary Overview, page 37

5.       Please include a separate section on Results of Operations describing
the underlying
         cause for material changes in revenue and cost of revenue in order to
provide investors a
         better understanding of your business as a whole. In this regard,
please provide a
         narrative discussion of the extent to which such increases are
attributable to increases in
         prices or to increases in the volume or amount of goods or services
being sold or to the
         introduction of new products or services. Additionally, address why
cost of
         revenue significantly declined as a percentage of revenue during 2020.
Refer to Item
         303(a) of Regulation S-K.
6.       Please include a separate section on Liquidity and Capital Resources.
Identify any known
         trends or any known demands, commitments, events or uncertainties that
will result in or
         that are reasonably likely to result in your liquidity increasing or
decreasing in any
         material way. If a material deficiency is identified, indicate the
course of action that you
         have taken or plan to take to remedy the deficiency. Refer to Item
303(a)(1) of Regulation
         S-K.
Executive Compensation, page 41

7.       You indicate that your executive officer and directors did not receive
any compensation in
         2019 and 2020. You further disclose on page 35 that you have no
employees beyond your
         executive officer and directors. However, in Note 5 of your fiscal
year 2020 financial
         statements, you describe receiving a $150,000 loan from the Small
Business
         Administration   s Payroll Protection Program. Please discuss the
basis on which you
         received the loan.
Security Ownership of Certain Beneficial Owners and Management, page 43

8.       Please add a voting power column that includes the votes for all of
your voting securities
         voting as a single class. We note that your super voting rights for
your Series A and
         Series B Preferred Stock will concentrate ownership with your
President Raymond Firth
         and shares of entities affiliated with Holly Andrews. Please add a
risk factor that
         addresses the risks associated with this concentration of ownership,
such as the ability of
 Raymond Firth
Findit, Inc.
April 7, 2021
Page 3
         Mr. Firth and Ms. Andrews to may make all material decisions regarding
the operation
         and corporate governance of Findit, Inc. Discuss whether common
stockholders have
         separate class voting rights for matters that affect their rights and
privileges.
Certain Relationships and Related Transactions, page 44

9.       Please provide a complete description of all of your related party
transactions for the past
         3 fiscal years, pursuant to Instruction 1 to Item 404 of Regulation
S-K. We note that you
         have a list of undisclosed related party transactions for fiscal years
2019 and 2020 in Note
         6 of your fiscal 2020 financial statements. We also note that you list
related party
         revenues and cost of goods sold in your income statement. Please also
include all of these
         related party transactions and related party transactions from fiscal
year 2018. Further,
         please ensure the related party for each transaction is identified and
disclose all material
         terms of such agreements and arrangements.
Experts, page 45

10.      If true, please confirm to us and revise to name BF Burgers CPA PC as
your auditors upon
         whom you relied as experts in accounting and auditing in connection
with the
         accompanying financial statements.
Note 1 - Organization & Summary of Significant Accounting Policies
Basis of Presentation, page F-7

11.      Please disclose your intended plans to mitigate the conditions that
raise substantial doubt
         about your Company's ability to continue as a going concern and your
conclusion
         regarding their mitigating effect. Refer to ASC 205-40-50-6 through
10.
12.      We note your auditor refers to Note 2 to the financial statements in
their audit report
         however, this note is missing from the financial statements. Please
correct your financial
         statements accordingly.
Recent Sales of Unregistered Securities, page II-2

13.    Please provide a more detailed description of your sales of unregistered
securities for the
       past 3 fiscal years, as required by Item 701 of Regulation S-K. For
shares that were issued
FirstName LastNameRaymond Firth
       for services rendered, please provide a materially complete description
of such services.
Comapany    NameFindit,
       For example,       Inc. you issued shares to Calvin Corzine. Please
clarify whether these
                       we note
April 7,shares
         2021 were
               Page issued
                     3      to promote your stock and/or app to a social media
influencer.
FirstName LastName
 Raymond Firth
FirstName
Findit, Inc. LastNameRaymond Firth
Comapany
April        NameFindit, Inc.
       7, 2021
April 47, 2021 Page 4
Page
FirstName LastName
General

14.      You have references to a selling shareholder or selling stockholders
on your cover page
         and pages 23, 25, and II-1 of your registration statement, but do not
provide any
         disclosure required under Item 507 of Regulation S-K. Please advise
whether you intend
         for this registration statement to provide a resale offering for
selling shareholders in
         addition to the primary offering 10,000,000 shares of common stock
offered on a best
         efforts basis.
15.      We note that you intend to be an emerging growth company. In light of
your current
         amount of revenue, please also clarify if you intend to be a smaller
reporting company as
         well. We note you did not indicate so on your cover page. If so,
please also provide a
         brief description of the scaled disclosure required for smaller
reporting companies.
16.      You disclose that you intend to be quoted on the OTCQB through a
registered broker-
         dealer market maker. Please clarify prominently that your application
to be quoted on the
         OTCQB may not be accepted and the result is your common stock will
continue to be
         quoted on the OTC Pink.
17.      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 Kathryn Jacobson, Senior Staff Accountant, at (202)
551-3365 or
Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have
questions regarding
comments on the financial statements and related matters. Please contact Edwin
Kim, Attorney
Advisor, at (202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3450
with any other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Technology
cc:      Thomas C. Cook, Esq.