December 12, 2019

Govinda Giri
Chief Executive Officer
Sagoon Inc.
1980 Teasel Ct.
Woodbridge, VA 22192

       Re: Sagoon Inc.
           Offering Statement on Form 1-A
           Filed November 26, 2019
           File No. 024-11120

Dear Mr. Giri:

       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.

Offering Statement on Form 1-A

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources, page 22

1.    During the years ended December 31, 2018 and 2017, you had operating
expenses of
      $1.97 million and $1.93 million, respectively. For the six months ended
June 30, 2019,
      you had operating expenses of $487,624. Please discuss the nature of the
general and
      administrative expenses, sales and marketing expenses, and the research
and development
      expenses you incurred. Clarify whether you have any material agreements
for research
      and development.
Plan of Operations, page 23

2.    You state that you believe you may reach profitability within three years
"based on
      projections." For context, please disclose the assumptions on which such
belief is based.
      In this regard, you should provide quantitative or qualitative disclosure
that addresses the
 Govinda Giri
Sagoon Inc.
December 12, 2019
Page 2
       underlying projections that are referenced.
General

3.     You state that your platform has been used by more than 3,000,000 people
across the
       globe; hundreds of thousands of people visit your site on a monthly
basis; and the number
       of users of your services has increased by approximately 400% between
2016 and 2019.
       Please clarify the extent to which you have had success in attracting
more users to your
       platform by providing this data for each period presented, as opposed to
providing it on an
       aggregate basis. Disclose whether you are able to distinguish unique
users of your
       platform, and if not, address the risk that such limitation poses to
your business. Also, to
       the extent there is a measure of user activity that you consider in
managing your business
       (e.g., average monthly active users), please provide such information
for each period
       presented.
        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. We also remind you that, following qualification of your
Form 1-A, Rule 257
of Regulation A requires you to continue to file periodic and current reports,
including a Form 1-
K that will be due within 120 calendar days after the end of the fiscal year
covered by the report.

        You may contact Ryan Rohn, Staff Accountant, at (202) 551-3739 or
Stephen Krikorian,
Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the
financial statements and related matters. Please contact Bernard Nolan,
Attorney-Adviser, at
(202) 551-6516 or, in his absence, Jan Woo, Legal Branch Chief, at (202)
551-3453 with any
other questions.



                                                             Sincerely,
FirstName LastNameGovinda Giri
                                                             Division of
Corporation Finance
Comapany NameSagoon Inc.
                                                             Office of
Technology
December 12, 2019 Page 2
cc:       Jamie Ostrow
FirstName LastName